Attachment 20170829094223-467.p

20170829094223-467.p

SUPPLEMENT

Supplement

2006-12-14

This document pretains to ITC-214-20061214-00564 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142006121400564_1621337

                                                                                                                     Page 1 of 1
  Miketle Morra
  From:      Jabloner, Amy [Amy.Jabloner©usdoj.gov]
  Sent:      Friday, December29, 2006 12:08 PM
  To:        David Krech; George Li; Joann Ekblad; Mikelle Morra; Susan OConnell
  Cc:        James Ball
  Subject: RE: FCC application status update for week of 1/1/07 -- letter 2006-68
Hello all,
Due to timing concerns related to the impending federal holiday and the day of mourning in honor of former President Gerald R.
Ford, I am sending this email earlier than usual.
Please be advised that DOJ, FBI and DHS request that the following applications be REMOVED from streamline:
   1. Bridges Global Access Telecomms Limited - ITC-2 14-20061213-00551
   2. ABH Communications, Corp. - ITC-214-20061212-00552
   3. Telefonica International Wholesale Services, USA, Inc. / TI Wholesale Services Puerto Rico - SCL-MOD-
      20061207-000 12
    4. Affinity Mobile, LLC d/b/a Trumpet Mobile - ITC-214-20061214-00564
Contact me or Loimie Kishiyama if you have any questions.
Thank you,
Amy Jabloner
DOJ
1/4/2007


Message                                                                                             Page 1 of2
  Mikelle Morra
  From:          Griffin, Joan M. [JGriffin©KelleyDrye.com ]
  Sent:          Tuesday, January 02, 2007 4:14 PM
  To:            David Krech; Susan OConnell; George Li
  Cc:            Mikelle Morra; Brenner, Louis
  Subject:       RE: Possible edits to Affinity Mobile dba Trumpet Mobile S214 application
  Attachments: Affinity Mobile 214 application modifications letter. pdf
All:
The date-stamped copy of the filing referenced below is attached.
Joan M. Griffin
Of Counsel
Kelley Drye & Warren LLP
3050 K Street NW
Suite 400
Washington, DC 20007
phone: 1-202-342-8573
fax: 1-202-342-8451
cell: 1-240-687-5983
   -Original Message-----
From: Griffin, Joan M.
Sent: Friday, December 29, 2006 2:52 PM
To: David Krech'; Susan OConnell; George Li
Cc: Mikelle Morra; 'Brenner, Louis'
Subject: RE: Possible edits to Affinity Mobile dba Trumpet Mobile S214 application
David, Susan and George:
Attached for your information and review is a supplemental filing that I am making today via the Secretary's
office re the Affinity Mobile dba Trumpet Mobile 214 application (ITC-214-20061214-00564). I have restated
the response to item (h) and also revised and reattached Attachment 1 (the org chart) because of minor
changes in the ownership % that resulted from a stock distribution in mid December. I also note that the
spellings of the names of 2 of the 3 Al Sabah brothers who control Al Fawares have changed slightly but
these are the same people identified before.
I realize that next week is a short week, but anything you can do to get the application on PN next Friday
would be greatly appreciated.
Many thanks,
Joan M. Griffin
Of Counsel
Kelley Drye & Warren LLP
1/4/2007


Message                                                                                             Page 2 of 2
3050 K Street NW
Suite 400
Washington, DC 20007
phone: 1-202-342-8573
fax: 1-202-342-8451
ceH: 1-240-687-5983
      -Original Message-----
From: David Krech [ma ilto: David. Krech@fcc.gov ]
Sent: Thursday, December 21, 2006 3:08 PM
To: Griffin, Joan M.; Susan OConnell; George Li
Cc: Mikelle Morra
Subject: RE: Possible edits to Affinity Mobile dba Trumpet Mobile S214 application
Thanks.
We will hold off on the PN until you get back to us.
***                                       ***
      Non-Public: For Internal Use Only
From: Griffin, Joan M. [mailto:JGriffin©KelleyDrye.com ]
Sent: Thursday, December 21, 2006 11:11 AM
To: David Krech; Susan OConnell; George Li
Subject: Possible edits to Affinity Mobile dba Trumpet Mobile 5214 application
Importance: High
David, Susan, and George:
I have been alerted by the client this am that there may be some mistakes in the ownership info provided in
the Affinity Mobile dba Trumpet Mobile 214 application (ITC-214-20061214-00564). There may be some
minor changes in the % held by the Al Fawares chain. More importantly, there is some question whether the
Al Sabah family members who control Al Fawares are listed correctly.
I am working with Trumpet to get this resolved and will let you know when I do. I don't know if you were
planning on putting the application on PN tomorrow but you might want to hold off for now.
Thanks,
Joan M. Griffin
Of Counsel
Kelley Drye & Warren LLP
3050 K Street, NW
Suite 400
Washington, DC 20007
phone: 1-202-342-8573
fax: 1-945-342-8451
mobile: 1-240-687-5983
1/4/2007


Message                                                                                             Page 1 of 2
  Mikelle Morra
  From:     Griffin, Joan M. [JGriffinKelleyDrye.com ]
  Sent:    Wednesday, January 03, 2007 7:09 PM
  To:       David Krech; Susan 000nnell; George Li
  Cc:       Mikelle Morra; Brenner, Louis
  Subject: RE: Possible edits to Affinity Mobile dba Trumpet Mobile S214 application
David:
Per my conversation with you this afternoon, Affinity Mobile withdraws its request for streamlined processing
for the application captioned below. I would very much appreciate whatever you can do to get the
application on PN this Friday.
Thanks
Joan M. Griffin
Of Counsel
Kelley Drye & Warren LLF
3050 K Street, NW
Suite 400
Washington, DC 20007
phone: l-202-3428573
fax: 19453428451
mobile: 1-24O-6875983
   -Original Message-----
From: Griffin, Joan M.
Sent: Friday, December 29, 2006 2:52 PM
To: 'David Krech; Susan OConnell; George Li
Cc: Mikelle Morra; 'Brenner, Louis'
Subject: RE: Possible edits to Affinity Mobile dba Trumpet Mobile S214 application
David, Susan and George:
Attached for your information and review is a supplemental filing that I am making today via the Secretary's
office re the Affinity Mobile dba Trumpet Mobile 214 application (ITC-214-20061214-00564). I have restated
the response to item (h) and also revised and reattached Attachment 1 (the org chart) because of minor
changes in the ownership % that resulted from a stock distribution in mid December. I also note that the
spellings of the names of 2 of the 3 Al Sabah brothers who control Al Fawares have changed slightly but
these are the same people identified before.
I realize that next week is a short week, but anything you can do to get the application on PN next Friday
would be greatly appreciated.
Many thanks,
Joan M. Griffin
Of Counsel
Kelley Drye & Warren LLP
3050 K Street NW
1/4/2007


Message                                                                                             Page 2 of 2
Suite 400
Washington, DC 20007
phone: 1-202-342-8573
fax: 1-202-342-8451
cell: 1-240-687-5983
    -Original Message-----
From: David Krech [mailto: David. Krech@fcc.gov ]
Sent: Thursday, December 21, 2006 3:08 PM
To: Griffin, Joan M.; Susan OConnell; George Li
Cc: Mikelle Morra
Subject: RE: Possible edits to Affinity Mobile dba Trumpet Mobile S214 application
Thanks.
We wifl hold off on the PN until you get back to us.
   Non-Public: For Internal Use Only ***
From: Griffin, Joan M. [mailto:JGriffin©KelleyDrye.com ]
Sent: Thursday, December 21, 2006 11:11 AM
To: David Krech; Susan OConneIJ; George Li
Subject: Possible edits to Affinity Mobile dba Trumpet Mobile S214 application
Importance: High
David, Susan, and George:
I have been alerted by the client this am that there may be some mistakes in the ownership info provided in
the Affinity Mobile dba Trumpet Mobile 214 application (ITC-214-20061214-00564). There may be some
minor changes in the % held by the Al Fawares chain. More importantly, there is some question whether the
Al Sabah family members who control Al Fawares are listed correctly.
I am working with Trumpet to get this resolved and will let you know when I do. I don't know if you were
planning on putting the application on PN tomorrow but you might want to hold off for now.
Thanks,
Joan M. Griffin
Of Counsel
Kelley Drye & Warren LLP
3050 K Street, NW
Suite 400
Washington, DC 20007
phone: 1-202-342-8573
fax: 1-945-342-8451
mobile: 1-240-687-5983
1/4/2007


Mikelle Morra
From:                Kishiyama, Lonnie [Lonnie. Kishiyama@dhs.gov ]
Sent:                Tuesday, February 06, 2007 3:17 PM
To:                  Kishiyama, Lonnie; George Li; Susan 000nnell; Mikelle Morra; Joann Ekblad; David Krech
Cc:                  James Ball
Subject:             FCC application status update for week of 2/6/07
Good afternoon,
Please be advised that based on the information in its FCC application and discussions
with the company, the DOJ, FBI, and IJHS have NO COMMENT on the following application:
1. Affinity Mobile, LLC d/b/a Trumpet Mobile (2006-68) - ITC-2l4-200612l4-00564 Please be
advised that DOJ, FBI and DHS request that the following applications be REMOVED from
streamline:
1. Horizon Mobile Communications, Inc./BGAN - ITC-2l4-20070l10-0002l, SES-
LFS-20070109-00042, ISP-PDR-20070l29-0000l
Please contact me or Amy Jabloner if you have any questions.
Thank you,
Lonnie Kishiyama
DHS
                                                   1


                                                                                                           Page 1 of 1
 Mikelle Morra
  From:        Mikelle Maria
  Sent:        Thursday, February 08, 2007 5:55 PM
  To:          'Griffin, Joan M.'; 'dchengaffinitymobile.com'
  Cc:          David Krech; George Li; Susan OConnell; Joann Ekblad; Mikelle Morra; 'Kishiyama, Lonnie';
               Amy.Jabloner@usdoj.gov'; 'joseph.springsteenusdoj.gov'; 'Louis. brenner@dhs.gov '
  Subject:     FCC Section 214 Granted
 Attachments: TELO1 11 3.pdf
Affinity Mobile, L.L.C.
ITC-214-20061214-00564
The above listed application has been granted by Public Notice released February 8, 2007; Report No.
TEL-01113, DA 07-598 (attached).
Thank you,
Mikelle Morra
MUe..eMorra@fcc.gov
International Bureau! Policy Division
202-418-7151
2/8/2007


                                         KELLEY DRYE & WARREN LLP
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  AFFILIATE OFFICES
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                                                 December 29, 2006                          FILED/ACCEPTED
                                                                                                  DEC 29 2006
   BY HAND                                                                                FderaI Communjca          Commissj1n
                                                                                                 Office of the Secietasy
  Marlene H. Dortch, Secretary
  Federal Communications Commission
  Office of the Secretary
  445-12th Street SW
  Washington, DC 20554
                         Re:    Affinity Mobile, LLC dlb/a Trumpet Mobile
                                TB File No. ITC-214-20061214-00564
  Dear Ms. Dortch:
                   By this letter, Affinity Mobile, LLC dlb/a Trumpet Mobile ("Trumpet") makes
  minor modifications to the Section 214 application that is captioned above. As a result of mid
  December share distributions, some of the ownership interest percentages of the parties listed in
  item (h) have changed slightly. For the convenience of the Commission, item (h) is restated in
  its entirety below:
            (h)          The following individuals and entities hold a 10 percent or greater ownership
                         interest in Trumpet under the Commission's ownership attribution rules. A
                         corporate organization chart is provided in Attachment 1.
                      Affinity Investors Inc. Affinity Investors Inc. ("Affinity Investors") holds a direct
                      64 percent ownership interest in Trumpet. Affinity Investors is a corporation
                      organized under the laws of Delaware. Affinity Investors is a holding company
                      whose address is:
                      Affinity Investors Inc.
                      Trident Corporate Services (Bahamas) Limited
                      1St
                          Floor
                      Kings Court
                      Bay Street
  DCOI/GRIFJ/264 165.1


                                     KELLEY DRYE & WARREN LLP
 Marlene H. Dortch, Secretary
 December 29, 2006
 Page Two
                       P0 Box N-3944
                       Nassau, Bahamas
                       Affinity Investors is a wholly-owned subsidiary of Affinity Ventures Ltd
                       ("Affinity Ventures") and thus is deemed to hold a 64 percent ownership interest
                       in Trumpet under the Commission's ownership attribution rules. Affinity
                       Ventures is a limited liability company organized under the laws of the Bahamas.
                       Affinity Ventures is a holding company whose address is as follows:
                       Affinity Ventures Ltd
                       Trident Corporate Services (Bahamas) Limited
                       1St Floor
                       Kings Court
                       Bay Street
                       P0 Box N-3944
                       Nassau, Bahamas
                       Al Fawares Construction & Development K.S.C. (closed) ("Al Fawares") holds
                       99.16 percent of the ownership interest in Affinity Ventures and thus is deemed to
                       hold a 64 percent ownership interest in Trumpet under the Commission's
                       ownership attribution rules. Al Fawares is a closed joint stock company
                       organized under the laws of Kuwait. Al Fawares is an investment company with
                       ownership interests in companies that participate in the investment banking,
                       construction and development, information technology and communication,
                       media and publishing, aviation, and oil field supply markets in the Middle East.
                       The address of Al Fawares is as follows:
                   Al Fawares Construction and Development Co, KSC
                   P0 Box 989
                   Safat 13010
                   Kuwait
                   No individual shareholder of Al Fawares holds ownership interests in Al Fawares
                   sufficient to constitute a 10 percent or greater ownership interest in Trumpet
                   under the Commission's ownership attribution rules. Three (3) sons of Shiekh Au
                   Al Khalifa Al Sabah ("Shiekh Au Al Sabah") - Khaleefah Ali Khalifa Al Sabah,
                   Abdullah Ali Khalifa Al Sabah, and Naser Au Khalifa Al Sabah - have defacto
                   control of Al Fawares. Shiekh Ali Al Sabah and his sons are citizens of Kuwait;
                   their principal business is investment. The address of Shiekh Ali Al Sabah and
                   his sons is as follows:
DCOI/GRIFJ/264 165.1


                                    KELLEY DRYE & WARREN LLP
 Marlene H. Dortch, Secretary
 December 29, 2006
 Page Three
                      do Al Fawares Construction and Development Co, KSC
                      P0 Box 989
                      Safat 13010
                      Kuwait
                      Among other things, Shiekh Au Al Sabah holds a 70 percent non-voting equity
                      interest in MDS Operations, Inc. ("MDS"). MDS holds approximately 80
                      licenses in the multichannel video distribution and data service ("MVDDS"). See,
                      e.g., call signs WQAR56O, et al., ULS File No. 0001619955.
                      Mobile Media Group, Inc. Mobile Media Group, Inc. ("MMG") holds a 31
                      percent direct interest in Trumpet. MMG is a corporation, organized under the
                      laws of Delaware, whose primary business is investment in mobile media
                      ventures. The address of MMG is as follows:
                      Mobile Media Group, Inc.
                      do Affinity Mobile, LLC
                      880 Apollo Street
                      Suite 237
                      El Segundo, CA 90245
                      DigaComm (MMG), L.L.C. ("DigaComm MMG") holds a 26.57 percent interest
                      in M.MG and thus an 8 percent ownership interest in Trumpet through MMG
                      under the Commission's ownership attribution rules. Because DigaComm MMG
                      holds a 2 percent interest in Trumpet directly, DigaComm MMG holds a total
                      ownership interest of 10 percent in Trumpet. DigaComm MMG is a limited
                      liability company, organized under the laws of Delaware, whose primary business
                      is investment in MMG. The address of DigaComm MMG is as follows:
                      DigaComm (MMG), L.L.C.
                      400 North Michigan Avenue
                      Suite 520
                      Chicago, IL 60611
                  Peter W. Smith holds a 66.67 percent ownership interest in DigaComm MMG and
                  thus is considered to hold a 10 percent interest in Trumpet under the FCC's
                  ownership attribution rules. Mr. Smith is a U.S. citizen whose principal business
                  is investment. The address of Mr. Smith is as follows:
                  Mr. Peter W. Smith
                  do DigaComm (MMG), L.L.C.
DCOI/GRIFJ/264165.1


                                     KELLEY DRYE & WARREN LLP
 Marlene H. Dortch, Secretary
 December 29, 2006
 Page Four
                       400 North Michigan Avenue
                       Suite 520
                       Chicago, IL 60611
                       No other shareholders of DigaComm MMG hold ownership interests in
                       DigiComm MMG sufficient to constitute a 10 percent or greater ownership
                       interest in Trumpet under the Commission's ownership attribution rules.
                       No other shareholder holds a 10 percent or greater ownership interest in Trumpet
                       under the FCC's ownership attribution rules. There are no interlocking
                       directorates with any foreign carriers.
                       A revised version of Attachment 1, edited to show these changes, is also attached.
                Please date-stamp the duplicate copy of this letter and return it to the bearer.
 Please contact the undersigned counsel if there are any questions regarding this matter.
                                                        Sincerely,
                                                        Its Attorney
                                                                       fE•'
DCOI/GRIFJ/264 165.1


                                                                                                  Attachment I
                                                                                                    (revised)
                        Affinity Mobile, LLC dibla Trumpet Mobile
                               Corporate Organization Chart


    Khaleefah All Khalifa            Abdullah Au Khalifa              Naser All Khalifa
         Al Sabah                         Al Sabah                       Al Sabah
         (Kuwait)*                        (Kuwait)*                      (Kuwait)*
                                                                                             -I


                              I-
                                   Al Fawares Construction
                                    & Development K S.C.               Peter W. Smith
                                                                          (US)***
                                          (Kuwait)

                                                 99.16%                       I   66.67%



                                     Affinity Ventures Ltd        DigiComm (MMG), L.L.C.
                                          (Bahamas)                       (DE)**

                                                 100%                             26.57%



DigaComm (MMG), L.L.C.              Affinity Investors Inc.       Mobile Media Group, Inc.
       (DE)**                             (Bahamas)                        (DE)
                                                              1
     2%    1                                                                      31




                                    Affinity Mobile L.L.C.
                                             (DE)


                   Affinity Mobile, LLC dibla Trumpet Mobile
                          Corporate Organization Chart


Notes

*Khaleefah All Khakifa Al Sabah, Abdullah Au Khalifa
                                                     Al Sabah, and Naser All
Khalifa Al Sabah have de facto control of Al Fawares Construction & Development
K.S.C.

** DigaComm (MMG), L.L.C. ("DigaComm MMG") holds a 26.57 percent interest in
MMG and thus an 8 percent ownership interest in Trumpet through MMG under the
Commission's ownership attribution rules. Because DigaComm MMG holds a 2
percent interest in Trumpet directly, DigaComm MMG holds a total ownership
interest of 10 percent in Trumpet.

***peter W. Smith holds a 66.67 percent ownership interest in DigaComm MMG
and thus is considered to hold a 10 percent interest in Trumpet under the FCC's
ownership attribution rules.


                                                               May 20, 2009
Federal Communications Commission
Policy Division, International Bureau
Attention: Sumita Mukhoty, Sr. Attorney
      12' Street, SW
Washington, DC 20552
Re:       Attachment 2, Special Temporary Authority (STA), Affinity Mobile, LLC
          File # ITC-STA-20090209-00087
          File # ITC-214-20061214-00564
In reference to the Commission rules and 47 C.F.R. Section 63.51, Affinity Mobile LLC is requesting a Special
Temporary Authority for a period of 60 days to complete the transaction and to allow time for the commission to
review our underlying application for Transfer of Assignment or Control as outlined in 47 C.F.R Section 63.18 (e)
(3). Affinity Mobile LLC sold its assets and customer base to HH Ventures LLCas of December 31, 2008. The
transaction between Affinity Mobile LLC and HH Ventures LLC was not approved by its board members prior to
December 31, 2008.
Affinity Mobile LLC, "the company", necessitates additional operating capital to satisfy its current financial
obligations. The company sought numerous resources to acquire additional funding to maintain its business
operations to support and provide service to the existing subscriber base. it was decided by the board members of
Affinity Mobile LLC to seek the most feasible solution to satisfy its debt obligations. The public is best served by
the granting of the STA to avoid uninterrupted prepaid wireless service to its existing subscriber base.
As per Section 63.25, Affinity Mobile, LLC is requesting special temporary authority to continue providing service to
its customers while the Commission processes the underlying assignment application for the international section
214 authority. Both parties, HH Ventures LLC and Affinity Mobile LLC are requesting the transfer of the
international section 214 authority to ensure uninterrupted service to the existing subscribers.
Affinity Mobile LLC is no longer in the phone subscriber business and HH Ventures LLC is now familiar with the
commission's rules and regulations and will no longer allow any lapses and will request authorization for pre-
approval of any transactions that they may have in the future.
The parties acknowledge that the grant of the STA will not prejudice any action the Commission may take on the
underlying application seeking Commission consent to the transfer/assignment. The parties further acknowledge
that this STA can be revoked by the Commission upon its own motion without a hearing. We seek Commission
action on the applications referenced.
Sincerely,
Mr. Ira D. L
Affinity Mobile, LLC
Managing Director & CFO


                                       Before the
                        FEDERAL COMMUNICATIONS COMMISSION
                                 Washington, D.C. 20554
In the Matter of
AFFINITY MOBILE, LLC                                                    File No. ITC-214-
d/b/a TRUMPET MOBILE
Application for Authority Under Section 214 of
the Communications Act of 1934, as Amended,
to Operate as a Resale Carrier
for the Provision of International Switched
and Private Line Services to
All International Points
                                          APPLICATION
          Affinity Mobile, LLC d/bla Trumpet Mobile ("Trumpet" or "Applicant"), pursuant to
Section 214 of the Communications Act of 1934, as amended ("the Act"), 47 U.S.C. § 214, and
Section 63.18 of the Commission's Rules, 47 CFR §63.18, hereby requests authority to operate
as a resale carrier on all international routes. Trumpet has no affiliation with any foreign carrier
in any of the destination countries for which authority is requested, nor is Trumpet affiliated with
any dominant U.S. carrier whose services Trumpet may resell. Thus, Trumpet qualifies as a non-
dominant carrier in its provision of international service on all routes under Section 63.1 O(a)( 1)
of the Commission's Rules and this Application is eligible for streamlined processing treatment
pursuant to Section 63.12.
          Pursuant to Section 63.18 of the Commission's Rules, Trumpet sets forth the following
information in support of this Application:
DCOI /GRIFJ/25 1 3491


           (a)         The name, address, and telephone number of the Applicant is:
                       Affinity Mobile, LLC
                       880 Apollo Street
                       Suite 237
                       El Segundo, CA 90245
                       Phone: (310) 648-7720
                       Fax: (310) 648-7721
          (b)          Trumpet is a limited liability company organized under the laws of Delaware.
          (c)          Correspondence concerning this Application should be sent to:
                       David Cheng
                       Director of Pricing and Financial Analysis
                       Affinity Mobile, LLC d/b/a Trumpet Mobile
                       880 Apollo Street, Suite 237
                       El Segundo, CA 90245
                       Phone: (310) 648-7724
                       Fax: (310) 648-7721
                       with copies to:
                    Joan M. Griffin
                    Kelley Drye & Warren, LLP
                    3050 K Street, NW
                    Suite 400
                    Washington, DC 20007
                   Phone: (202)342-8573
                   Fax: (202) 342-8451
                   jgriffin@kelleydrye.com
          (d)          Trumpet has not previously received Section 214 authority from the Commission.
          (e)      Trumpet requests authority in this Application to operate as a resale carrier,
                   pursuant to the terms and conditions of Section 63.18 (e)(2) of the Commission's
                   Rules, on all routes possible under a grant of global authority. As evidenced by
                   the signature of Trumpet's authorized representative to this Application, Trumpet
                   certifies that it will comply with the terms and conditions contained in Sections
                   63.21 and 63.23 of the Commission's Rules.
          (0       No response required.
          (g)      Not applicable.
                                                     -2-
DCOI/GRIFJ/251 349.1


           (h)          The following individuals and entities hold a 10 percent or greater ownership
                        interest in Trumpet under the Commission's ownership attribution rules. A
                        corporate organization chart is provided in Attachment 1.
                        Affinity Investors Inc. Affinity Investors Inc. ("Affinity Investors") holds a direct
                        63.3 percent ownership interest in Trumpet. Affinity Investors is a corporation
                        organized under the laws of Delaware. Affinity Investors is a holding company
                        whose address is:
                        Affinity Investors Inc.
                        Trident Corporate Services (Bahamas) Limited
                        1st Floor
                        Kings Court
                        Bay Street
                        P0 Box N-3944
                        Nassau, Bahamas
                        Affinity Investors is a wholly-owned subsidiary of Affinity Ventures Ltd
                        ("Affinity Ventures") and thus is deemed to hold a 65.26 percent ownership
                        interest in Trumpet under the Commission's ownership attribution rules. Affinity
                        Ventures is a limited liability company organized under the laws of the Bahamas.
                        Affinity Ventures is a holding company whose address is as follows:
                        Affinity Ventures Ltd
                        Trident Corporate Services (Bahamas) Limited
                        1St Floor
                        Kings Court
                        Bay Street
                        P0 Box N-3944
                        Nassau, Bahamas
                    Al Fawares Construction & Development K.S.C. (closed) ("Al Fawares") holds
                    99.16 percent of the ownership interest in Affinity Ventures and thus is deemed to
                    hold a 65.26 percent ownership interest in Trumpet under the Commission's
                    ownership attribution rules. Al Fawares is a closed joint stock company
                    organized under the laws of Kuwait. Al Fawares is an investment company with
                    ownership interests in companies that participate in the investment banking,
                    construction and development, information technology and communication,
                    media and publishing, aviation, and oil field supply markets in the Middle East.
                    The address of Al Fawares is as follows:
                    Al Fawares Construction and Development Co, KSC
                    P0 Box 989
                    Safat 13010
                    Kuwait
                                                         -3-
DCO1 /GRIFJ/25 1349.1


                      No individual shareholder of Al Fawares holds ownership interests in Al Fawares
                      sufficient to constitute a 10 percent or greater ownership interest in Trumpet
                      under the Commission's ownership attribution rules. Three (3) sons of Shiekh Ali
                      Al Khalifa Al Sabah ("Shiekh Ali Al Sabah") - Khalifa Ali Khalifa Al Sabah,
                      Abdullah Au Khalifa Al Sabah, and Nasser Ali Khalifa Al Sabah - have defacto
                      control of Al Fawares. Shiekh Ali Al Sabah and his sons are citizens of Kuwait;
                      their principal business is investment. The address of Shiekh Ali Al Sabah and
                      his sons is as follows:
                      do Al Fawares Construction and Development Co, KSC
                      P0 Box 989
                      Safat 13010
                      Kuwait
                      Among other things, Shiekh Ali Al Sabah holds a 70 percent non-voting equity
                      interst in MDS Operations, Inc. ("MDS"). MDS holds approximately 80 licenses
                      in the multichannel video distribution and data service ("MVDDS"). See, e.g.,
                      call signs WQAR56O, et al., ULS File No. 0001619955.
                      Mobile Media Group, Inc. Mobile Media Group, Inc. ("MMG") holds a 31.24
                      percent direct interest in Trumpet. MMG is a corporation, organized under the
                      laws of Delaware, whose primary business is investment in mobile media
                      ventures. The address of MMG is as follows:
                      Mobile Media Group, Inc.
                      do Affinity Mobile, LLC
                      880 Apollo Street
                      Suite 237
                      El Segundo, CA 90245
                  DigaComm (MMG), L.L.C. ("DigaComm MMG") holds a 26.57 percent interest
                  in MMG and thus an 8.3 percent ownership interest in Trumpet through MMG
                  under the Commission's ownership attribution rules. Because DigaComm MMG
                  holds a 2.1 interest in Trumpet directly, DigaComm MMG holds a total
                  ownership interest of 10.4 percent in Trumpet. DigaComm MMG is a limited
                  liability company, organized under the laws of Delaware, whose primary business
                  is investment in MMG. The address of DigaComm MMG is as follows:
                  DigaComm (MMG), L.L.C.
                  400 North Michigan Avenue
                  Suite 520
                  Chicago, IL 60611
                  Peter W. Smith holds a 66.67 percent ownership interest in DigaComm MMG and
                  thus is considered to hold a 10.4 percent interest in Trumpet under the FCC's
                  ownership attribution rules. Mr. Smith is a U.S. citizen whose principal business
                  is investment. The address of Mr. Smith is as follows:
                                                     -4-
DCW/ORIFJ/251 349.1


                      Mr. Peter W. Smith
                      do DigaComm (MMG), L.L.C.
                      400 North Michigan Avenue
                      Suite 520
                      Chicago, IL 60611
                      No other shareholders of DigaComm MMG hold ownership interests in
                      DigiComm MMG sufficient to constitute a 10 percent or greater ownership
                      interest in Trumpet under the Commission's ownership attribution rules.
                      No other shareholder holds a 10 percent or greater ownership interest in Trumpet
                      under the FCC's ownership attribution rules. There are no interlocking
                      directorates with any foreign carriers.
          (i)         As evidenced by the signature of Trumpet's authorized representative to this
                      Application, Trumpet certifies that it is not, and is not affiliated with, a foreign
                      telecommunications carrier.
          (j)         As evidenced by the signature of Trumpet's authorized representative to this
                      Application, Trumpet certifies that it will not provide international
                      telecommunications services to any foreign country where it qualifies as a foreign
                      carrier, controls a foreign carrier, or is more than 25% owned by an entity that is
                      or controls a foreign carrier, or where two or more foreign carriers (or parties that
                      control foreign carriers) own, in the aggregate, more than 25% of Trumpet and are
                      parties to, or the beneficiaries of, a contractual relation affecting the provision or
                      marketing of international basic telecommunications services in the US.
                      No response required.
                      No response required.
         (m)          No response required.
         (n)      As evidenced by the signature of Trumpet's authorized representative to this
                  Application, Trumpet 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.
         (o)      As evidenced by the signature of Trumpet's authorized representative to this
                  Application, Trumpet certifies that 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)      Trumpet requests streamlined processing pursuant to Section 63.12 of the
                  Commission's Rules. This Application is eligible for streamlined processing
                                                       -5
DCOI/GRIFJ/251349.1


                       because (1) Trumpet is not a foreign carrier, andis not affiliated with any foreign
                       carrier in any country to which it will provide service; (2) Trumpet is not
                       affiliated with a dominant U.S. carrier whose international services it seeks
                       authority to resell; (3) Trumpet is not requesting authority to provide switched
                       services over private lines to countries not previously authorized for such
                       services.
                                                       -6-
DCO1/GRIFJ/251 349.1


Conclusion
        For these reasons, Trumpet requests that the Commission grant this Application.
                                             Respectfully submitted,
                                             AFFINITY MOBILE, LLC D/B/A TRUMPET MOmLE
                                             By:
Joan M. Griffin
KELLEY, DRYE & WARREN, LLP                             President
3050 K Street, NW                                      AFFINITY MOBILE, LLC D/B/A TRUMPET
Suite 400                                              MOBILE
Washington, flC. 20007                                 880 Apollo Street
Phone: (202) 342-8573                                  Suite 237
jgriffln@kelleydrye.com                                El Segundo, CA 90245
                                                       Phone: (310) 648-7720
Its Attorney
Date:    December 14, 2006
DCOI/GRIFJ/251349J                                 -


                                                                                                  Attachment I
                        Affinity Mobile, LLC dibla Trumpet Mobile
                               Corporate Organization Chart


 Khalifa All Khalifa Al Sabah   Abdullah All Khalifa Al Sabah   Nasser All Khalifa Al Sabah
          (Kuwa lt)*                      (Kuwait)*                      (Kuwait)*

                                                                                              1




                                (
                                    Al Fawares Construction
                                                                      PeterW. Smith
                                     & Development K.S.C.
                                                                         (US)***
                                           (Kuwait)

                                                  99.16%                     I   66.67%



                                      Affinity Ventures Ltd      DigiComm (MMG), L.L.C.
                                           (Bahamas)                     (DE)**

                                                  100%                           26.57%



DigaComm (MMG), L.L.C.               Affinity Investors Inc.     Mobile Media Group, Inc.
       (DE)**                              (Bahamas)                      (DE)

      2.1%                                        65.26%                         31.24%




                                     Affinity Mobile L.L.C.
                                              (DE)


                   Affinity Mobile, LLC dibla Trumpet Mobile
                          Corporate Organization Chart


Notes

*Khalifa All Khakifa Al Sabah, Abdullah All Khalifa Al Sabah, and Nasser All Khalifa
Al Sabah have do facto control of Al Fawares Construction & Development K.S.C.

** DigaComm (MMG), L.L.C. ("DigaComm MMG") holds a 26.57 percent interest in
MMG and thus an 8.3 percent ownership interest in Trumpet through MMG under
the Commission's ownership attribution rules. Because DigaComm MMG holds a
2.1 interest in Trumpet directly, DigaComm MMG holds a total ownership interest
of 10.4 percent in Trumpet.

***peter W. Smith holds a 66.67 percent ownership interest in DigaComm MMG
and thus is considered to hold a 10.4 percent interest in Trumpet under the FCC's
ownership attribution rules.



Document Created: 0000-00-00 00:00:00
Document Modified: 0000-00-00 00:00:00

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