Attachment 20170105130826-347.p

20170105130826-347.p

SUPPLEMENT

Supplement

2000-04-04

This document pretains to ITC-214-20000404-00211 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142000040400211_1391138

_—Categories of Services for 214 Applications —(Streamline/Non—streamline) _—C LIMITED/GLOBALRESALESERVICE _LIMITED/GLOBALFACILITIES—BASEDSERVICE ACILITIES—BASED/RESALE SERVICE ITIES—BASED SERVICE TE LINE RESALE SERVICE ATELLITE SERVICE

KELLEY DRYE & WARREN cur ZGDD A LIMITED LIABILITY PARTNERSHIP % APR \;‘CC!MELLG%\ 200 I9"°" STREET, N.W. NEW YORK, NY sUIUE 5C D5 FACSIMILE LOS ANGELES, CA w is {INCTON, D. 3. 20036 fense> senge mele cHicaGgo, iL STAMFORD, CT 2 (202) ast «96 50 PARSIPPANY, NJ BRUSSELS, BELGIUM HONG KONG AFFILIATE OFFICES BANGKOK, THAILAND Apr] [3 2( 00 JAKARTA, INDONESIA MANILA, THE PHILIPPINES MUMBAI, INDIA TOKYO, JAPAN VIA COURIER Federal Communica:ions Commissic n IB—Telecommunications Division P.O. Box 358115 Pittsburgh, PA 15251—5115 Re: Application of 3N iP Link, L1 C ‘or Global Avthcrity Pursuant to Section 2 4 of he Com nt iic ations Act of 19.4, As Amended, To Operate as a 1 I ite nationa F ci ities—Basec ard tesale Carrier. Dear Sir or Madain: Enclosed for filing with the Cor im ss on are c rig in: l and six (¢) cop es of the application of SNiP Link, LLC requesting global authority t ) c »erate a: ai it ternational favilities—based and resale carrier between the United States and various i ite national p in s pursuant to Section 214 of the Communications Act of 1934, as amenc ed As required by the Commission‘s liu >s, a check in ‘he amount of $780.00 is enclosed. Please date— stamp the extra copy of this application an | return it in tl.e enclosed self—addressed, stamped envelope. Any questions regarding the enclosed application should be addressed to the undersigned. Respectfully Submitted, 7 ay y Michael C. Engel Counsel for SNiP Link, LLC Enclosures DCO1/ENGEM/109149.1

fh'-":v""':.”-i.#""-;‘;Lx“‘_t‘.)\"?“' M NEsavt Sn e TT e es aEhtR craad o hURAACREOERIEREO NEAAA Nee o o. c n oTA GNEARIDTIMAET1 ocaap KELLEY DRYE & WARREN LLP ""olMASHINGTON:BC °__~ ‘ i L ; 1200 19TH STREET, N.W. > 006030 WASHINGTON, DC 20036 68—122/540 00480 _April.4,.2000_ PAY TO THE ORDER or Federal Communications j i Commission i i $ 780 .00 Seven Hundred Eighty And No/100 DOLLARS puLiQe;74<( éiXéngjékEZf‘ t MEMO Chg. 0101720001 Flllng Fee -,I mmerourt t mrn ?0270b secunity IEAtUnES INCLUDED, OE TAILS on THL HBACK HOF! L. wb 5+ LA o e B t e oie Peee onl rarieeP n WDDEDEDW .DSLDDLEEDIEUDDDELEqDBS3W

APPROVED BY OMS 3060—0589 BEFORE PROCEEDING FEDERAL COMMUNICATIONS COMMISSION REMITTANCE ADVICE use Use LockBoxs 358115 paseno.__L. or _1 4 name as appears on your Kell & Warren 1200 ‘19th Street, N.W., Suite 500 —. Washi D.C.> 20036 955—9600 ,PAYER NAME HE APPLIGAN I N/ ; COMPLETESEC B:sz. > IF MORE ONE APPLICANT, USE:— CONTINUATION SHEETS RM 159—C) s w > io. name as appears on your SNIP Link, LLC 100—A Twinbridge Drive Pennsauken NJ 97119 1—888—764—7600 COMPLETE SECTION C FOR EACH SERVICE, IF MORE BOXES ARE NEEDED, USE CONTINUATION SHEETS(FORM 1 3. [if oL. § — 780.00 AYER TIN 0|1}3|5|3]|3|5|1|0| 7 CANT TIN 0}2]2)3]6)]0|2]4]4]7 4 Certify under penalty of perjury that the foregoing true and correct to the best of my knowledge, infomation and belief. SIGNATURE__ "———p hereby sutharize the PCC to charge my V.SA or MASTERCARD service(s)/sutmertssons(s) hervin described.

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In th.é Matter of N Ne‘ Ne Nuner! Nn Ne N Nt Nus! Nus! Nt SNiP Link, LLC Application Under Section 214 File No. ITC of the Communications Act of 1934, as Amended, for Global Authority for the Provision of Resold and Facilities—Based International Switched and Private Line Services Between the U.S. and Various International Points APPLICATION SNiP Link, LLC ("SNiP" or "Applicant"), by its attorneys and pursuant to Section 214 of the Communications Act of 1934, as amended ("the Act"), 47 U.S.C. § 214, hereby requests global authority to (1) operate as a facilities—based carrier pursuant to the terms and conditions of Section 63.18(e)(1) of the Commission‘s Rules, 47 C.F.R § 63.18(e)(1), to all foreign points as authorizedby the Commission and (2) operate as a resale carrier pursuant to the terms and conditions of Section 63.18(e)(2) of the Commission‘s Rules to all foreign points as authorized by the Commission.‘ 47 C.F.R. § 63.18(e)(2). SNiP has no affiliation with any foreign carrier in any of the destination countries for which authority is requested nor is SNiP With respect to the provision of switched services over private lines, SNiP seeks authority in this Application to provide such services only to (1) those locations specifically approved by the Commission for the provision of such services, or (2) as specified in Section 63.22(e)(2) and 63.23(d)(2) of the Commission‘s Rules, 47 C.EF.R. §§ 63.22(e)(2), 63.23(d)(2), which permit the use of future lines to provide switched access services where the carrier is exchanging traffic with a foreign carrier that lacks market power at the foreign end. DCQOL/ENGEM/108573.1

affiliated with any dominant U.S. carrier whose services SNiP may resell. Thus, pursuant to Section 63.10(a)(1) of the Commission‘s Rules, 47 C.F.R. § 63.10(a)(1), SNiP should be classified as a non—dominant carrier in its provision of international service on all routes. Furt]héfmore, as explained herein, this Application is efititle:d to streamlined processing under Section 63.12 of the Commission‘s Rules. 47 C.F.R. § 63.12. Accordingto the FCC‘s fee schedule, Fee Code CUT, a check in the amount of $780.00 is attached hereto. In support ofits request for authority, SNiP submits the following information pursuant to Section 63.18 of the Commission‘s Rules, 47 C.F.R. 63.18: (a) The name, address and telephone number of the Applicant is: SNiP Link, LLC 100—A Twinbridge Drive Pennsauken, NJ 08110 1—888—764—7600 (b) SNiP is a limited liability company organized under the laws of the State of New Jersey. (c) Correspondence concerning this Application should be addressed to: Steven A. Augustino KELLEY DRYE & WARREN LLP 1200 19°" Street, N.W. Suite 500 Washington, D.C. 20036 (202) 955—9600 with copies to: Joseph Polito, Jr. Director of Telecommunications Sales SNiP Link, LLC 100—A Twinbridge Drive Pennsauken, NJ 08110 (856) 662—8640 DCOI/ENGEM/108573.1 2

(d) SNiP has not previously received Section 214 authority from the Commission. (e) SNiP is applying for authority to operate as a facilities—based carrier pursuant to the terms and conditions of Section 63.18(e)(1), of the Commission‘s Rules 47 C.F.R. § 63.18(e)(1) and as a resale carrier pursuant to the term and conditions of Section 63.18(e)(2) of the Commission‘s Rules. 47 C.F.R. § 63.18(e)(2). SNiP requests authority to serve all countries permitted under a grant of global authority. As evidenced by the certification provided in Attachment A, SNiP will comply with the terms and conditions contained in Sections 63.21, 63.22 and 63.23 of the Commission‘s Rules. 47 C.F.R. §§ 63.21—.23. 8 At this time, Applicant does not seek authority to provide service not referenced under paragraph (e) of Section 63.18 of the Commission‘s Rules. 47 C.F.R. § 63.18(e). (g) SNiP will use previously authorized facilities to provide the services requested by this Application. Consequently, SNiP is categorically excluded from environmental assessment pursuant to Section 1.1306 of the Commission‘s Rules. 47 C.F.R. § 1. 1306. (b) SNiP is a New Jersey limited liability company. Messers Anthony Abate, Philip Abate, and Pete Cava each own 26.31 percent of the company. Mr. Ira Riklis owns 16.04 percent of the company. Messers Joseph Giacomelli and Marc Leibowitz each own 2.52 percent. As evidenced by the certification attached hereto as Attachment A, SNiPis not affiliated with a foreign carrier. 0) As evidenced by the certification attached hereto as Attachment A, SNiP does not seek to provide international telecommunications service to any destination where: (1) SNiP is a foreign carrier in that country; (2) SNiP controls a foreign carrier in that country; (3) anyentity that owns morethan a 25% interest in SNiP, or controls SNiP, controls a foreigncarrier in that country; or (4) two or more parties own, in the aggregate, more than 25% of SNiP and are parties to, or the beneficiaries of, a contractual relationship that affects the provision or marketing of international basic telecommunications sérvices in the United States. (k) Not applicable; SNiP is not affiliated or otherwise related to any foreign carrier on any of the routes which SNiP proposes to provide service in this Application. (1) Not applicable; SNiP is not a foreign carrier and is not affiliated with a foreign carrier on any of the routes it proposes to resell international telecommunications service. (m) Not applicable; SNiP is not affiliated with any foreign carrier on any of the routes it proposes to provide service. DCOL/ENGEM/108573.1 3

(n) As evidenced by the certification provided in Attachment A, SNiP has not agreed to accept special concessions directly or indirectly from any foreign carrier with respect to any U.S. international route where the foreign carrier possesses sufficient market power on the foreign end of the route to affect competition adversely in the U.S. market and will not enter into such agreements in the future. (0) As evidenced by the certification provided in Attachment A, no party to this application is subject to a denial of Federal benefits pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988. (p) SNiP respectfully requests streamlined processing of this Application pursuant to Section 63.12 of the Commission‘s Rules. 47 C.F.R. § 63.12 This Application qualifies for streamlined processing for the following reasons: (1) SNiP is not affiliated with a foreign carrier on any route for which authority is sought; (2) SNiP is not affiliated with any dominant U.S. carrier whose international switched or private lines services it seeks to resell; and (3) SNiPis not requesting authority to provide switched service over private lines to countries not previously authorized for service by the Commission. DCOI/ENGEM/108573.1 4

WHEREFORE, SNiP respectfully requests that the Commission grant it authority to provide international telecommunication services on a facilities and resale basis pursuant to Section 214 of the Communications Act of 1934, as amended. Respectfully submitted, SNiP Link, LLC By: A_ A /L:Wé—— U Steven A. Augustino KELLEY DRYE & WARREN LLP 1200 19°" Street, N.W. Suite 500 Washington, D.C. 20036 (202) 955—9600 Counsel for SNiP Link, LLC Dated: March 31, 2000 DCO1/ENGEM/108573.1 5

CERTIFICATE The undersigned hereby certifies, on behalf of SNiPLink, LLC("SNiP") with respect to the foregoing application for authority to provide international service, that: 1: SNiP is not affiliated with any foreign carrier in anyofthe countries to which SNiP proposes to provide service in the foregoing application. 2. SNiP will comply with the terms and conditions contained in Sections 63.21, 63.22, and 63.23 of the Commission‘s Rules. 47 C.F.R. §§ 63.21—23. 3. SNiP does not seek to provide international telecommunications service to any destination where: (1) SNiP is a foreign carrier in that country; (2) SNiP controls a foreign carrier in that country; (3) any entity that owns more than a 25%interest in SNiP, or controls SNiP, controls a foreign carrier in that country; or (4) two or more parties own, in the aggregate, more than 25% of SNiP and are parties to, or the beneficiaries of, a contractual relationship that affects the provision or marketing of international basic telecommunications services in the United States. 4. SNiP has not agreed to accept special concessions directly or indirectly from any foreign carrier with respect to any U.S. international route where the foreign carrier possesses sufficient market power on the foreign end of the route to affect competition adversely in the U.S. market and will not enter into such agreements in the future. 3. No party to this application is subject to a denial for Federal benefits pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988, 21 U.S.C. § 853(a). JP2 «fZ 7£ozzawé%u/uzcnwwfl> Date: LB[/5 Q/& O DCOL/ENGEM/108573.1


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Document Modified: 2019-04-18 01:40:09
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