Attachment FCC Potential Termin

FCC Potential Termin

LETTER submitted by Federal Communications Commission

Potential Termination Letter

2018-09-06

This document pretains to ITC-214-20080718-00329 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142008071800329_1544117

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                                                           Office of Policy
                                                           U.S. Department of Homeland Security
                                                            Washington, DC 20528




                                      March 6, 2018

Ms. Marlene H. Dortch
Federal Communications
Commission 445 l2th St. SW,
Room TW-B204
Washington, DC 20554

Re:       Cablemas International Telecom LLC ITC-214-20080718-00329



Dear Ms. Dortch:

        The Department of Homeland Security (“DHS”) hereby requests that the
Federal Communications Commission (“FCC”) terminate, declare null and void and
no longer in effect file number ITC-214-20080718-00329 granted to Cablemas
International Telecom LLC (“Cablemas”) on November 20, 2008, and the
corresponding Letter of Assurance (“LOA”) because Cablemas is no longer in
business.

       Prior to Cablemas receiving the aforementioned authorization, DHS issued its
non-objection on the condition that Cablemas abide by the commitments and
undertakings contained in its November 19, 2008 LOA to DHS.

        DHS assesses that Cablemas is no longer in business based on attempted
contact with the company and evidence acquired through open-source research. The
company has submitted no deliverables under the agreement, and DHS has been
unable to contact Cablemas since the LOA was signed in 2008. Attempts to
communicate with the point of contact provided at the time of application have been
unsuccessful. The telephone number provided in Cablemas’ Section 214 application
as the company and point of contact number, (202) 551-1798, is no longer registered
to the point of contact provided in the application, J. Steven Rich. Research
conducted by DHS indicates that Mr. Rich is no longer employed by Paul, Hastings,
Janofsky & Walker LLP, and DHS was unable to locate current contact information
for Mr. Rich. An email sent to the address provided in the application was never
answered. On January 31, 2018, a certified letter was delivered to Cablemas’ last
known address—1209 Orange Street, Wilmington, DE 19801—requesting the
company confirm its compliance with the terms of the LOA. DHS has received no


response to this letter. In Grupo Televisa, S.A.B.’s 1 Annual Report, filed with the
Securities Exchange Commission (SEC), Cablemas is listed as a subsidiary of Grupo
Televisa, but without operations. Furthermore, Cablemas has never filed any of the
FCC’s required Traffic and Revenue reports between the years 2006 and 2015, 2 and
the company is not listed in the FCC’s Form 499 database.

        Given the above information, DHS believes that the company is neither
providing services pursuant to authorization file number ITC-214-20080718-00329
nor still in existence. In light of these developments, DHS requests the FCC
terminate, declare null and void and no longer in effect the international Section 214
authorization issued to Cablemas, file number ITC-214-20080718-00329, and the
corresponding LOA.

        Should you have any questions whatsoever, please do not hesitate to contact
me.



                                                      Sincerely,

                                                                /S/
                                                      Phil Ludvigson
                                                      Director, Foreign Investment Risk Management
                                                      Office of Policy
                                                      U.S. Department of Homeland Security


cc:
Denise Coca
Chief, Telecommunications and
Analysis Division
International Bureau, FCC
Denise.coca@fcc.gov

David Krech
Associate Chief, Telecommunications and
Analysis Division
International Bureau, FCC
David.krech@fcc.gov




1
  Grupo Televisa, S.A.B. is the parent company of Cablemas Telecomunicaciones, S.A.de C.V., Cablemas’
parent company, as listed in its Section 214 application.
2
  See International Telecommunications Data, Carriers Filing International Traffic Data for 2007-2012 (Cablemas
not listed).



Document Created: 2018-10-02 13:47:15
Document Modified: 2018-10-02 13:47:15

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