Petition to adopt LO

PETITION submitted by U.S. Department of Justice

Petition to Adopt Conditions

2011-02-28

This document pretains to ITC-214-20100719-00298 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142010071900298_871836

                                      Before the
                        FEDERAL COMMUNICATIONS COMMISSION
                                 Washington, D.C. 20554

                                                 )
                                                 )
                                                 )
In the Matter of                                 )   File No. ITC-214-20100719-00298
                                                 )
Rules Telecomm, LLC                              )
                                                 )
Application for authorization under Section      )
214 of the Communications Act of 1934, as        )
amended                                          )

                            PETITION TO ADOPT CONDITIONS TO
                             AUTHORIZATIONS AND LICENSES


           The Department of Justice (DOJ)(the Agency) submits this Petition to Adopt Conditions

to Authorizations and Licenses (Petition), pursuant to Section 1.41 of the Federal

Communications Commission (“Commission”) rules.1 Through this Petition, the Agency advises

the Commission that it has no objection to the Commission approving the authority sought in the

above-referenced proceeding, provided that the Commission conditions its approval on the

assurance of Rules Telecomm, LLC to abide by the commitments and undertakings set forth in

the February 7, 2011 Letter of Assurances (LOA), which is attached hereto. In the above-

referenced proceeding, the Applicant petitioned the Commission for authority under Section 214

of the Communications Act of 1934, as amended, to provide facilities-based and resale services

in the United States.

            The Commission has long recognized that law enforcement, national security, and public

safety concerns are part of its public interest analysis, and has accorded deference to the views of

other U.S. government agencies with expertise in those areas. See In the Matter of Comsat

Corporation d/b/a Comsat Mobile Communications, etc., 16 FCC Rcd. 21,661, 21707 ¶ 94

1
    47 C.F.R. § 1.41.


(2001).

          After discussions with representatives of the Applicant in connection with the above-

referenced proceedings, the Agency has concluded that the additional commitments set forth in

the LOA will help ensure that the Agency with responsibility for enforcing the law, protecting

the national security, and preserving public safety, can proceed appropriately to satisfy those

responsibilities. Accordingly, the Agency advises the Commission that it has no objection to the

Commission granting the application in the above-referenced proceeding, provided that the

Commission conditions its consent on compliance by Rules Telecomm, LLC with the LOA.



Respectfully submitted,

/S/ Richard C. Sofield
Richard C. Sofield
U.S. Department of Justice
Director - Foreign Investment Review Staff
National Security Division
600 E Street, NW Rm 10000
Washington, D.C. 20004


February 28, 2011




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Document Created: 2011-02-28 14:14:27
Document Modified: 2011-02-28 14:14:27

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