Attachment RE_ StarVox - USWI L

RE_ StarVox - USWI L

SUPPLEMENT submitted by Department of Homeland Security

Supplement to Termination Request Letter

2018-07-23

This document pretains to ITC-214-20050407-00146 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142005040700146_1587491

From: Figueroa, Melissa (CTR) To: Figueroa, Melissa Subject: RE: StarVox - USWI LOA Update Date: Tuesday, November 24, 2015 10:48:07 AM From: Jonathan Marashlian [mailto:jsm@commlawgroup.com] Sent: Tuesday, November 24, 2015 10:23 AM To: Figueroa, Melissa (CTR) Cc: IP-FCC; FIRS-TT@usdoj.gov Subject: RE: StarVox - USWI LOA Update Melissa – Thank you for contacting me with your inquiry regarding StarVox. In response to your specific questions, I no longer represent StarVox and have no knowledge regarding the Company other than what is publically available. According to my recollection, as refreshed by research online, I would conclude that StarVox is bankrupt and no longer operational. See, for example: https://www.crmz.com/Report/ReportPreview.aspx?BusinessId=3168 However, since I have no specific knowledge of StarVox’s current status, I cannot confirm with absolute certainty that the company is non-operational and extinct. But signs would seem to indicate this is the case. I hope I have been helpful. Do not hesitate to contact me should you require more. Regards, Jonathan Jonathan S. Marashlian Managing Partner Marashlian & Donahue, PLLC                                                   The CommLaw Group                                                    1420 Spring Hill Road, Suite 401                              McLean, Virginia 22102                                              Office Tel: 703-714-1313 Office Fax: 703-563-6222 E-Mail: jsm@commlawgroup.com Website: www.CommLawGroup.com Named "Leading Customer Service Law Firm" and “Best Communications Law Firm” of the year in the U.S. AV Preeminent Peer Rated Attorney and Winner of Lexology/International Law Office Client Choice Awards Profiled in The Wall Street Journal as Capital Region’s Premier Telecom Lawyer* FOR INFORMATION ABOUT FIXED-FEE REGULATORY, TAX AND CORPORATE LICENSING, REGISTRATION AND

COMPLIANCE SERVICES, VISIT OUR AFFILIATED CONSULTING FIRM, THE COMMPLIANCE GROUP: www.CommplianceGroup.com Pursuant to Treasury Regulations, any U.S. federal tax advice contained in this communication, unless otherwise stated, is not intended and cannot be used for the purpose of avoiding tax-related penalties. This message contains confidential information belonging to the sender, which is intended to be legally privileged and confidential and/or a purely private communication between the sender and the recipient(s). The information contained herein, including any attachments, is intended only for the use of the recipient(s). If you are not a named recipient(s), or an employee or agent responsible for delivering it to a named recipient, you are advised and placed on notice that any disclosure, copying, distribution, the taking of any action or refraining from an action in reliance on the contents or information contained in this message and any attachment is strictly prohibited and may be legally actionable. If you have received this message or any portion of it in error, please immediately advise the sender by return email to jsm@commlawgroup.com delete the message and any attachments and destroy any hardcopies made by you or others. If you have forwarded this message or any portion of it to another or others, you must notify us immediately of their proper email or other addresses and you are to notify them of the privileged and confidential nature of this message and to take action to delete the message and its attachments and to destroy any hardcopies. Thank you. * No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers. The hiring of a lawyer is an important decision that should not be based solely upon advertisements. This message is not intended to be an advertisement or solicitation. From: Figueroa, Melissa (CTR) [mailto:Melissa.Figueroa@associates.hq.dhs.gov] Sent: Tuesday, November 24, 2015 10:16 AM To: Jonathan Marashlian Cc: IP-FCC; FIRS-TT@usdoj.gov Subject: StarVox - USWI LOA Update Mr. Marashlian, According to our records, you were listed as counsel for StarVox Communications, Inc. (StarVox) for its 2007 applications for consent to transfer control of StarVox and its direct, wholly-owned subsidiary, Capital Telecommunications, Inc., to U.S. Wireless Data, Inc. (USWI). In StarVox’s September 14, 2006 Letter of Assurance (LOA, attached here) with the U.S. Department of Justice (DOJ), the Federal Bureau of Investigation (FBI) and the U.S. Department of Homeland Security (DHS) (jointly, the USG Parties), and reconfirmed in USWI’s subsequent commitment letter dated July 25, 2007 (attached), StarVox designated Mr. Michael Sharman and Mr. Bryan Brooks as U.S. points of contact with the authority and responsibility for accepting and overseeing compliance with a wiretap order, pen/trap order, subpoena or other lawful demand by U.S. law enforcement authorities for the content of communications or U.S. Records. DHS would appreciate it if you could let us know if you are still counsel to StarVox, and, if so, if Mr. Sharman and Mr. Brooks remain the points of contact for such requests. If Mr. Sharman and Mr. Brooks are still the points of contact, please provide DHS with their updated contact information, or if there has been a change, please provide DHS with the new point of contact to include his or her contact information.

Additionally, DHS asks that StarVox and USWI confirm that there have been no unauthorized disclosures of, or access to, any U.S. Records and provide updates regarding any material changes to any of the facts as represented in the 2006 and 2007 LOAs. Finally, DHS requests an update on the current ownership structure of StarVox and USWI. Please provide the current owners with greater than 5% ownership interest, including the citizenship of each owner. DHS advises that the point of contact for all matters pertaining to the LOA for DHS is ip- fcc@hq.dhs.gov with a courtesy copy of all notices and correspondence to be forwarded to myself (Melissa.figueroa@associates.hq.dhs.gov). Please provide a response by December 8, 2015. Thank you for all of your assistance. Melissa Melissa Figueroa Team Telecom Foreign Investment Risk Management DHS Office of Policy CENTRA Technology, Inc. W – (781) 743-3864 C – (202) 445-1866 Melissa.figueroa@associates.hq.dhs.gov


Document Created: 2018-12-04 12:00:00
Document Modified: 2018-12-04 12:00:00
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