Petiton to Adopt Con

PETITION submitted by US Depart of Justice, National Security Division, FIRS

Petition to Adopt

2013-07-12

This document pretains to ITC-214-20121222-00325 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142012122200325_1003769

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


In the Matter of                              )
                                              )
Advanced Voice Technologies LLC               )   File No. ITC-214-20121222-00325
                                              )
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”), including the Federal Bureau of Investigation

(“FBI”), with the concurrence of the Department of Homeland Security (“DHS”)(collectively,

the “Agencies”), submit 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 Agencies advise the Commission that they

have no objection to the Commission approving the authority sought in the above-referenced

proceeding, provided that the Commission conditions its approval on the agreement of Advanced

Voice Technologies LLC (AVT) to abide by the commitments and undertakings set forth in the

July 8, 2013 Letter of Assurance (“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


1
       47 C.F.R. § 1.41.


international global or limited global facilities-based services, and global or limited global resale

services (47 C.F.R. §§ 63.18(e)(1) and (2)) to all international points.

          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

(2001).

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

referenced proceeding, the Agencies have concluded that the commitments set forth in the LOA

will help ensure that the Agencies and other entities with responsibility for enforcing the law,

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

those responsibilities. Accordingly, the Agencies advise the Commission that they have no

objection on those grounds to the Commission granting the application in the above-referenced

proceeding, provided that the Commission conditions its consent on compliance by AVT with

the commitments set forth in the LOA.



Respectfully submitted,


/s/ Richard C. Sofield
Richard C. Sofield
Director – Foreign Investment Review Staff
National Security Division
United States Department of Justice
600 E Street, NW, Room 10000
Washington, DC 20004


July 12, 2013




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Document Created: 2013-07-12 14:21:25
Document Modified: 2013-07-12 14:21:25

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