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Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by China Mobile International (USA) Inc.

Ex Parte

2013-12-16

This document pretains to ITC-214-20110901-00289 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142011090100289_1030434

2 3 0 0 N S T R E E T, N W SUITE 700 WASHINGTON, DC 20037 TEL 202.783.4141 FA X 202.783.5851 W W W.W B K L AW. C O M JENNIFER L. KOSTYU December 16, 2013 VIA IBFS Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Notice of Ex Parte Presentation China Mobile International (USA) Inc. File No. 1TC-214-20110901-00289 Dear Ms. Dortch: On December 12, 2013, Sean Luo of China Mobile International (USA) Inc. (“China Mobile USA”), Karen Lau of China Mobile International (via telephone), and Jennifer Kostyu and William Maher of Wilkinson Barker Knauer, LLP, counsel to China Mobile USA, met with Troy Tanner, Deputy Chief of the International Bureau; Kate Collins of the International Bureau; Jim Ball, Chief of the International Bureau’s Policy Division; George Li, Deputy Chief of the International Bureau’s Policy Division; David Krech, Associate Division Chief of the International Bureau’s Policy Division; and Rizwan Chowdhry of the International Bureau’s Strategic Analysis and Negotiations Division, regarding the above-referenced application for international Section 214 authorization (“Application”). The China Mobile USA representatives noted that the Application has been pending for more than 26 months. They also explained that the company has been subject to the Team Telecom review process for more than two years, and Team Telecom has acknowledged that it has no further questions for the company. However, other than general assurances that Team Telecom continues to review this matter, it has failed to convey to China Mobile USA any specific concerns or issues with the Application. In fact, China Mobile USA has received no substantive feedback from Team Telecom during the more than two-year review period. The China Mobile USA representatives noted that they had also met with representatives from the Office of the U.S. Trade Representative, who also expressed concern regarding the ongoing lengthy review process in this case.

Marlene H. Dortch December 16, 2013 Page 2 The China Mobile USA representatives further explained that this significant and unreasonable delay has resulted in serious economic and business losses to China Mobile USA. The delay also conflicts with longstanding U.S. policy to encourage foreign investment and participation in the United States. The delay in this case is particularly egregious and discriminatory given that other foreign-owned carriers have received international Section 214 authorizations, including other Chinese-based carriers. The China Mobile USA representatives also described the company’s activities in the United States and discussed with the FCC staff which types of services are subject to international Section 214 authority. Pursuant to Section 1.206(b) of the Commission’s rules, 47 C.F. R. § 1.1206(b), this ex parte notification is being filed for inclusion in the public record of the above-referenced proceeding. Please direct any questions to the undersigned. Sincerely, /s/ Jennifer L. Kostyu Jennifer L. Kostyu Counsel to China Mobile International (USA) Inc. cc: Troy Tanner Kate Collins Jim Ball George Li David Krech Rizwan Chowdhry


Document Created: 2013-12-16 09:47:08
Document Modified: 2013-12-16 09:47:08
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