Attachment Roam Mobility #1

This document pretains to ITC-214-20130620-00176 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142013062000176_1001553

ATTACHMENT 1 Roam Mobility USA Inc. Response to Question 9 Question: Does the applicant request streamlined processing pursuant to 47 C.F.R. § 63.12? Answer: Yes, Roam Mobility USA Inc. requests streamlined processing. Roam Mobility USA Inc. is eligible for streamlined processing pursuant to 47 C.F.R. § 63.12 because it meets the required conditions. It is a foreign-owned company incorporated in the United States. See information in Attachment 2 for ownership details. To receive streamlined processing, Roam Mobility USA Inc. must demonstrate that it meets at least one condition of 47 C.F.R. § 63.12(c)(1). Roam Mobility USA Inc. is affiliated through common ownership with Roam Mobility, Inc., located in Vancouver, British Columbia, Canada. In compliance with 47 C.F.R. § 63.12(c)(1)(iii) the affiliated company owns no facilities in the destination market. It previously operated as a reseller of telecommunications services. Although only one condition must be met, Roam Mobility USA Inc. also qualifies for streamlined processing pursuant to 47 C.F.R. § 63.12(c)(1)(iv). Canada is a WTO partner of the United States and Roam Mobility USA Inc. qualifies for a presumption of non-dominance under 47 C.F.R. § 63.10(a)(4). It will resell international interexchange service of an unaffiliated US carrier. Response to Question 11 Question: If applicant is affiliated with a foreign carrier, provide the information and certifications required by Section 63.18(i) through (m). Answer: Answers and certifications are provided below. (i): Roam Mobility USA Inc. certifies that it is not affiliated with a foreign carrier. (j): Roam Mobility USA Inc. certifies that it (1) is not a foreign carrier in Canada; (2) does not control a foreign carrier in Canada; (3) the entity that owns Roam Mobility USA Inc. does not control a foreign carrier in Canada; (4) it is not owned by two or more foreign carriers. (l): Roam Mobility USA Inc. will resell the international switched services of an unaffiliated U.S. carrier. It complies with § 63.10(a)(3), as Roam Mobility USA Inc. lacks 50 percent market share in the market it serves. It is a small reseller of international interexchange service. (m) Roam Mobility USA Inc. certifies that it meets the requirements of § 63.10(a)(3) to be classified as a non-dominant carrier. Roam Mobility USA Inc.’s business generated the

equivalent of $462,076 in 2012. The low volume of business done by Roam Mobility Inc. qualifies the U.S. affiliate for non-dominant status. Response to Question 12 Question: Does the applicant seek authority to provide service to any destination described in paragraphs (1) through (4) of Section 63.18(j)? List them. Answer: Answers and certifications are provided below. No. -2-


Document Created: 2013-06-20 12:30:26
Document Modified: 2013-06-20 12:30:26
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