Attachment Certification

This document pretains to ITC-214-20130711-00187 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142013071100187_1003655

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Black Wire Consulting Group, LP ) ) Application Under Section 214 ) File No. TC - - - ­ Of the Communication Act of 1934. ) As Amended, for Global Authority ) ) For Provision of Resold and ) Facilities-Based International ) Switched ) ) Between the U.S. and Various ) International Points ) APPLICATION BlackWire Consulting, LP ("Black Wire" or "Applicant"), by its attorneys and pursuant to Section 214 of the Communications Act of 1934, as amended ("the Act"). 47 U.S.C. 214, hereby requests global authority to (1) operate as a facilities-based carrier pursuant to the terms and conditions of section 63.18(e)(1) of the Commission's Rules, 47 C.F.R. 63.18(e)(l), to all foreign points as authorized by the Commission and (2) operates as a resale carrier pursuant to the terms and conditions of Section 63.18(e)(2) of the Commission's Rules to all foreign points as authorized by the Commission. 47 C.F.R. 63 .18( e)(2). BlackWire has no affiliation with any foreign carrier in any of the destination countries for which authority si requested nor is BlackWire affiliated with any dominant U.S. carrier whose services BlackWire may resell. Thus, pursuant to Section 63.1 O(a)(l) of the Commission's Rules, 47 C.F.R. 63.1O(a)(1), BlackWire should be classified as a non-dominant carrier in its provision of international service on all routes. Furthermore, as explained herein, this Application is entitled to streamlined processing under Section 63.12 of the Commission's Rules, 47 C.F.R. 63.12. According to the FCC's fee schedule, Fee Code CUT a credit card payment in the amount of$1,050.00 is attached hereto with Form 159. In support of its request for authority, BlackWire submits the following information pursuant to Section 63.18 of the Commission's Rules, 47 C.F.R. 63.18: (a) The name, address and telephone number of the Applicant is: BlackWire Consulting Group, LP 444 Brickell Avenue Suite 51-338 Miami, FL 33131

Tel: (305) 744-5075 (b) Black Wire is a corporation organized under the laws of the state of Florida. (c) Correspondence concerning this Application should be addressed to: Neil S. Ende, Esq & Craig D. Dingwall, Esq. Technology Law Group, LLC 5335 Wisconsin Ave., N.W. Suite 440 Washington, D.C. 20015 Tel: (202) 895-1707 (d) BlackWire has not previously received Section 214 authority from the Commission. (e) BlackWire is applying for authority to operate as a facilities-based carrier pursuant to the terms and conditions of Section 63.18(e)(I) of the Commission's Rules 47 C.F.R. 63 .18( e)( 1) and as a resale carrier pursuant to the terms and conditions of Section 63.18(e)(2) of the Commission's Rules. 47 C.F.R. 63(e)(2). BlackWire requests authority to serve all countries permitted under a grant of global authority. As evidenced by the certification provided in Attachment A, BlackWire will comply with the terms and conditions contained in Section 63.21, 63.22 and 63.23 of the Commission's Rules. 47 C.F.R. 63.21-23. (f) At this time, Applicant does not seek authority to provide services not referenced under paragraph (e) of Section 63.18 of the Commission's Rules. 47 C.F.R. 63.18(e). (g) Black Wire will use previously authorized facilities to provide the services requested by the Application. Consequently, BlackWire is categorically excluded from environmental assessment pursuant to Section 1.1306 of the Commission's Rules. 47 C.F.R. 1.1306. (h) BlackWire is One Hundred percent (100%) owned by XX, a U.S. citizen whose business is U.S. International telecom sales. Mr. X's address is XXX. (i) As evidenced by the certification attached hereto as Attachment A, BlackWire is not affiliated with a foreign carrier. U) As evidenced by the certification attached hereto as Attachment A, BlackWire does not seek to provide international telecommunications service to any destination where: (1) BlackWire is a foreign carrer in that country; (2) BlackWire controls a foreign carrier in that country; (3) any entity that owns more than a 25% interest in BlackWire, or controls BlackWire, controls a foreing carrier in that country; or (4) two ore more parties own, in the aggregate, more than 25% of BlackWire and are parties to, or the beneficiaries of, a contractual relationship that affects the provision of marketing of international basic telecommunications services in the United States.

(k) Not applicable: BlackWire is not affiliated or otherwise related to any foreign carrier on any of the routes which BlackWire proposed to provide service in this Application. (1) Not applicable: BlackWire is not a foreign carrier and is not affiliated with a foreign carrier on any of the routes it proposes to resell international telecommunications service. (m) Not applicable: BlackWire is not affiliated with any foreign carrier on any of the routes it proposes to provide services. (n) As evidenced by the certification provided in Attachment A, BlackWire has not agreed to accept special concessions directly or indirectly from any foreign carrier with respect to any U.S. international route the foreign carrier possesses sufficient market power on the foreign end of the route to affect competition adversely in the U.S. market and will not enter into such agreements in the future. (0) As evidenced by the certification provided in Attachment A, no party to this application is subject to a denial of Federal benefits pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988. (p) BlackWire respectfully requests streamlined processing of this Application pursuant to Section 63.12 of the Commussion‘s Rules, 47 C.F.R. 63.12. This Application qualifies for streamlined processing for the following reasons: (1) BlackWire is not affiliabted with a foreign carrier on any route for which authority is sought; (2) BlackWire is not affiliated with any dominant U.S. carrier whose international switchd or private line services it seeks to resell; and (3) BlackWire is not requesting atuhrotiy to provide switched service over private lines to countries not previously authorized for service by the Commission. Wherefore, BlackWire respectfully requests that the Commission grant it authority to provide international telecommunications services on a facilities and resale basis pursuant to Section 214 of the Communications Act of 1934, as amended. Respectfully submitted, BlackWire Consulting Group, LP By: \RcAeeZ [. BcomeanL_ Michael Bongart, CKief Operating Officer BlackWire Consulting Group, LP 444 Brickell Avenue Suite 51—338 Miami, FL33131 Tel: (305) 744—5075 Date:@ g; tE plol

ATTACHMENT A In the Matter of BlackWire Consulting Group, LP Application Under Section 214 File No. TC Of the Communication Act of 1934, As Amended, for Global Authority For Provision of Resold and Facilities—Based International Switched Between the U.S. and Various International Points CERTIEFICATE The undersigned hereby certifies, on behalf of BlackWire Consulting Group, LP ("BlackWire") with respect to the foregoing application for authority to provide international services that: 1. BlackWire is not affiliated with any forign carrier in an of the countires to which BlackWire proposes to provide service in the foregoing application. 2. BlackWire will comply with the terms and conditions contained in Section 63.21, 63.22 and 63.23 of the Commission‘s Rules, 47 CFR 63.21—.23. 3. BlackWire does not seek to provide international telecommunications serevice to any destination where: (1) BlackWire is a foreign carrier int hat country; (2) BlackWire controls a foreign carrier in that country; (3) any entity that owns more than a 25% interest in BlackWire, or controls BlackWire, controls a foreign carrier int hat country; or (4) two or more parties own, in the aggregate, more than 25% of BlackWire and are parties to, or the beneficiaries of, a contractual relationship that affects that provision or marketing of international basic telecommunications services in the United States. 4, BlackWire has not agreed to accept special conecessios directly or indirectly from any foreign carrier with respect to any U.S. international route where the foreign carrier possesses sufficient market power on the foreign end of the route to affect competition aversely in the U.S. market and will not enter into such agreements in the future.

No party to this application is subject to a denial for Federal benefits pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988, 21 U.S.C. 853(a) By: ickeL. BW Michael Bongart, Chief Operating Office BlackWire Consulting Group, LP Date: f; g% \\~, 2014


Document Created: 2013-07-11 13:37:54
Document Modified: 2013-07-11 13:37:54
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