Attachment Attachment 1

This document pretains to ITC-214-20110915-00301 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142011091500301_916922

                                                          EUSA Wholesale Inc.
                                                          International Section 214 Application
                                                          September 15, 2011



                                   ATTACHMENT 1

Response to Question 9.

Section 63.18(p)      Applicant requests and qualifies for streamlined processing
                      pursuant to Section 63.12(c)(1)(ii) because the Applicant qualifies
                      for a presumption of non-dominance under Section 63.10(a)(3).

Section 63.10(a)(3)   Empresa Nacional de Telecomunicaciones de Chile S.A. (“ENTEL
                      S.A”), Applicant’s foreign carrier affiliate, is not a monopoly
                      provider of communications services in any market in Chile.
                      ENTEL S.A. lacks fifty percent (50%) market share in the
                      international transport and the local access markets on the foreign
                      end of the applicable U.S. international route.

                      Americatel Perú S.A., Applicant’s foreign carrier affiliate, is not a
                      monopoly provider of communications services in any market in
                      Peru. Americatel Perú S.A. lacks fifty percent (50%) market share
                      in the international transport and the local access markets on the
                      foreign end of the applicable U.S. international route.

Response to Question 11-12

Section 63.18(i)      Applicant certifies that it is affiliated with a foreign carrier in
                      Chile, ENTEL S.A.

                      Applicant certifies that it is also affiliated with a foreign carrier in
                      Peru, Americatel Perú S.A.

Section 63.18(j)      Applicant seeks to provide telecommunication services to Chile,
                      where an entity that controls more than 25 percent of the Applicant
                      is a foreign carrier. Applicant is also affiliated with a foreign
                      carrier in Peru, where the same entity that controls more than 25
                      percent of the Applicant also controls the foreign carrier in Peru.
                      Applicant seeks to provide services to Peru.

Section 63.18(k)      Chile and Peru are members of the World Trade Organization.

Section 63.18(l)      Applicant satisfies Section 63.10(a)(3). 47 C.F.R. § 63.10(a)(3).
                      See above.

Section 63.18(m)      Applicant qualifies for non-dominant classification pursuant to
                      Section 63.10. 47 C.F.R. § 63.10. See above.



Document Created: 2011-09-15 10:58:50
Document Modified: 2011-09-15 10:58:50

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