StarHub letter re Te

LETTER submitted by StarHub, Inc.

StarHub Letter

2010-04-28

This document pretains to ITC-214-20000731-00474 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142000073100474_813111

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                                                                        FIRM / AFFILIATE OFFICES
                                                                        Abu Dhabi       Moscow
                                                                        Barcelona       Munich
                                                                        Beijing         New Jersey
                                                                        Brussels        New York
                                                                        Chicago         Orange County
April 28, 2010                                                          Doha            Paris
                                                                        Dubai           Riyadh
                                                                        Frankfurt       Rome
VIA IBFS                                                                Hamburg         San Diego
                                                                        Hong Kong       San Francisco
Marlene H. Dortch                                                       Houston         Shanghai
                                                                        London          Silicon Valley
Secretary                                                               Los Angeles     Singapore
Federal Communications Commission                                       Madrid          Tokyo
445 12th Street, S.W.                                                   Milan           Washington, D.C.
Washington, D.C. 20554

       Re:       StarHub, Inc.; International Section 214 Authorizations (File Nos. ITC-214-
                 20000731-00473 and ITC-214-20000731-00474)

Dear Ms. Dortch:

        StarHub, Inc. (“StarHub”) submits this letter at the request of Commission staff, to
address one discrete aspect of its ownership structure. On April 21, 2010, the Commission
approved the pro forma transfer of control of StarHub from STT Communications Ltd (“STT
Communications”) to Asia Mobile Holdings Pte. Ltd. (“AMH”), both of which are indirect
subsidiaries of Temasek Holdings (Private) Limited (“Temasek”).1 In its filing concerning that
transfer of control, StarHub stated in a footnote that STT Communications’s prior interest in
StarHub was originally held by another indirect subsidiary of Temasek, TechPower
Communications Pte Ltd (“TechPower”), and that TechPower had transferred that interest to
STT Communications in November 2000. StarHub further stated that despite diligent review, it
had been unable to confirm whether a notice concerning that pro forma transfer of control was
filed with the Commission, and it thus noted the event out of prudence. Commission staff
subsequently requested that StarHub file this letter to ensure that the earlier pro forma transfer of
control of StarHub from TechPower to STT Communications is sufficiently documented in the
Commission’s records.

       Please contact me if you have any questions concerning this matter.

                                                  Sincerely,

                                                  /s/ Brian Murray

                                                  Brian Murray

cc:    Sumita Mukhoty

1
       Public Notice, International Authorizations Granted, DA No. 10-678, Report No. TEL-01422, at 5 (rel.
       Apr. 22, 2010) (noting April 21, 2010 approval for File No. ITC-T/C-20100412-00153).



Document Created: 2010-04-28 14:13:39
Document Modified: 2010-04-28 14:13:39

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