Attachment VTA Telecom Corporat

VTA Telecom Corporat

LETTER submitted by Federal Communications Commission

Letter to Bui Huy

2018-08-10

This document pretains to ITC-214-20130718-00195 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142013071800195_1494252

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                                                                        U.S. Department of Justice

                                                                        National Security Division


    Foreign Investment Review Staff                                    Washington, D.C. 20004



                                                                        August 3, 2018

    By E-File

    Ms. Marlene H. Dortch
    Federal Communications Commission
    445 l2th St. SW, Room TW-B204
    Washington, DC 20554

    Re: ITC-214-20130718-00195, VTA Telecom Corp. f/k/a Viettel American Corporation

    Dear Ms. Dortch:

      The U.S. Department of Justice (“DOJ”), with the concurrence of the U.S. Department
of Homeland Security and the U.S. Department of Defense (collectively, “the Agencies”),
hereby informs the Federal Communications Commission (“Commission”) that for the
reasons stated below, the Agencies are no longer conducting an active review of the pending
application for VTA Telecom Corp. f/k/a Viettel American Corporation (the “Applicant”) 1,
ITC-214-20130718-00195. The Agencies therefore send this application back to the
Commission for further review under the Commission’s rules, regulations, and policy
statements. 2

      On July 25, 2013, the Commission sent Cover Letter Reference EB 2013-21 to the
Agencies and other Executive Branch agencies requesting comments by August 14, 2013. On
August 14, 2013, DOJ, on behalf of the Agencies, requested the removal from streamline of
the above-referenced application so that the Agencies could conduct a review for national
security, law enforcement, and public safety issues. During the review of the application, the
Agencies engaged in several discussions with the Applicant regarding its application for an
international Section 214 authorization. In its response to questions from DOJ, the Applicant
stated that a “Bui Quang Huy” served as its president and was responsible for the overall
operation of the Applicant, including formulating and implementing the Applicant’s strategic
1
  The Applicant is indirectly owned by a Vietnamese state-owned enterprise.
2
  See, e.g., Policy Regarding Character Qualifications in Broadcast Licensing; Amendment of Rules of
Broadcast Practice and Procedure Relating to Written Responses to Commission Inquiries and the Making of
Misrepresentations to the Commission by Permittees and Licensees, Report, Order and Policy Statement, 102
FCC 2d 1179 (1986) (Character Policy Statement); Policy Statement and Order, 5 FCC Rcd 3252 (1990), as
modified, and pertinent precedent; Rules and Policies on Foreign Participation in the U.S. Telecommunications
Market, Report and Order and Order on Reconsideration, 12 FCC Rcd 23891, 23915, para. 53 & n.90 (1997).


Ms. Marlene H. Dortch
Federal Communications Commission
August 3, 2018


and business plans. 3 The Applicant also stated that neither the company nor its officers or
directors had ever been investigated, arraigned, arrested, indicted, or convicted of, among
other things, violations of the International Trade in Arms Regulations (ITAR), the Export
Administration Regulations (EAR), or other U.S. laws. 4 A “Bui Quang Huy” certified the
Applicant’s responses to DOJ’s questions under penalty of perjury on August 22, 2013. 5

       On October 25, 2016, an individual named “Quang Huy Bui” was charged in a two-
count indictment in the District of New Mexico with illegally attempting to export arms from
the United States without first having obtained the required license or written approval in
violation of 22 U.S.C. § 2778 (Arms Export Control Act) and attempting to buy, conceal, and
facilitate the transportation of turbojet engines from the United States without a required
export license or authorization in violation of 18 U.S.C. § 554 (Smuggling Goods from the
United States). 6 On December 20, 2016, counsel for the Applicant informed the Commission
it no longer represented the Applicant, that the Applicant was still interested in pursuing its
application with the Commission, and that any questions or correspondence regarding the
application should be directed to a “Quang Huy.” 7 On June 6, 2017, “Quang Huy Bui”
entered into a plea agreement and pleaded guilty to one count of violating 18 U.S.C. § 554
(Smuggling Goods from the United States) and consented to removal from the United States
to Vietnam. 8 On October 5, 2017, “Quang Huy Bui” was sentenced to an imprisonment of 12
months and a day and three years of unsupervised release that would convert to supervised
release if the defendant were allowed to reenter or remain in the United States. 9

        As an initial matter, the Agencies believe that the “Bui Quang Huy,” listed by the
Applicant as its President in response to DOJ’s questions, and “Quang Huy Bui,” the
defendant in the criminal case, are one in the same. In a June 3, 2016 Form I-129 application
for an extension of an L-1A Nonimmigrant Worker Visa, the Applicant applied for the
extension of a work visa for a “Huy Quang Bui” and listed the same date of birth, passport
number, and foreign address as it did for a “Bui Quang Huy” in response to DOJ’s August 6,
2013 questions. 10 Furthermore, in the sentencing memorandum submitted on behalf of
“Quang Huy Bui,” the defendant stated, “[b]y March 2013 . . . Viettel directed Mr. Bui to
form the entity now known as VTA Telecom Corporation . . . . At all relevant times from
Oct. 2013, Mr. Bui served as Vice-President of [the Applicant].” 11



3
   Response from Applicant to DOJ’s August 6, 2013 Questions (Aug. 22, 2013).
4
   See id.
5
   See id.
6
   See United States v. Quang Huy Bui, 16 Cr. 4134 (D.N.M.).
7
   Letter from Patricia Paoletta, Harris, Wiltshire & Grannis LLP, to Marlene H. Dortch, Secretary, Federal
Communications Commission (Dec. 20, 2016).
8
   See United States v. Quang Huy Bui, Dkt. No. 53 (June 6, 2017).
9
   See id. at Dkt. No. 69 (Oct. 5, 2017).
10
   Compare United States v. Quang Huy Bui, Dkt. No. 39, Ex. 3 (Mar. 22, 2017) with Response from Applicant
to DOJ’s August 6, 2013 Questions (Aug. 22, 2013).
11
   United States v. Quang Huy Bui, Dkt. No. 62, p. 7 (Sept. 1, 2017).


                                                       2


Ms. Marlene H. Dortch
Federal Communications Commission
August 3, 2018


        According to the defendant, “[he] was working at the direction of his employer.
Viettel requested that he acquire the engine and have it sent to Vietnam.” 12 As such, it
appears that the Applicant’s duties and responsibilities expanded beyond its stated goal of
providing international telecommunications services to and/or from the United States to
“assisting Viettel in procurement efforts for research and development projects in Vietnam.
As to this facet of [the Applicant’s] business, Mr. Bui was responsible for receiving requests
from Vietnam for various products, negotiating the purchase of those products from suppliers
in the United States and elsewhere and arranging for shipment to Vietnam.” 13

        At no time has the Applicant updated its responses to inform DOJ or the Agencies
regarding the facts cited above. Given the felony conviction of the Applicant’s most senior
executive, as well as the allegations that he was acting at the direction of the Applicant and
others, the Agencies believe the Commission should review the Applicant’s pending
application pursuant to its rules, regulations, and policy statements.

        For the foregoing reasons, DOJ, with the concurrence of the Agencies, returns this
application to the Commission for further review under the Commission’s authorities.

                                                        Respectfully submitted,

                                                        SANCHITHA JAYARAM
                                                        Chief, Foreign Investment Review Staff
                                                        National Security Division
                                                        United States Department of Justice

                                                        ___________/s/_________________
                                                        Loyaan A. Egal
                                                        Deputy Chief, Telecommunications
                                                        Three Constitution Square
                                                        175 N Street, NE
                                                        Washington, DC 20002
                                                        (202) 233-0254




       cc: Denise Coca (via email at Denise.Coca@fcc.gov)
           Veronica Garcia-Ulloa (via email at Veronica.Garcia-Ulloa@fcc.gov)
           FCC-TTelecom@fcc.gov



12
     Id. at p. 3; see also pp. 12-13.
13
     Id. at p. 7.


                                                 3


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                                         DOJ Triage Questions

                      Questions for FCC Applicants Reviewed by Team Telecom

Company Name: Viettel America Corporation                 FCC Application #: ITC-214-20130718-00195
Company Address: 1201 Hays Street
                 Tallahassee, FL 32301                 Place of Incorporation: Delaware


This list of questions solicits information that Executive Branch Agencies, participating in a working
group informally known as “Team Telecom” (Department of Homeland Security, Department of Justice,
including the Federal Bureau of Investigation, and the Department of Defense), will use to address
homeland security and law enforcement concerns on the above-referenced Federal Communications
Commission licensing application. Your application to the FCC indicates that you are seeking Global or
Limited Global Resale and Facilities-Based Authority. In addition to seeking further details regarding
your company and security-related practices, the following questions are particularly directed at
identifying and assessing the complete scope of the equipment which you will be operating and the
services which you will be offering should the FCC grant those authorities. Accordingly, in answering
questions in Section III (Company Services) and the Services Portfolio Checklist and Reference
Questions in Section IV, please be as complete as possible with particular attention to all equipment (e.g.,
switches, routers, gateways, servers, etc.), facilities, and all services offered to all customers.

For all sections of the triage responses, please inform Team Telecom of any material changes to these
triage responses that occur during Team Telecom’s review of the application including, but not
limited to, changes in ownership, equipment, CALEA compliance, etc.


Instructions for Sections I, II & III: Please complete all Sections. When a “Yes” answer is indicated,
please provide further information as appropriate. Any documents or responses to Team Telecom’s
triage questions that contain trade secrets or commercial or financial information that are privileged
or confidential should be identified as such.


Section I: Applicant Company Details
Please answer all questions in the following sections inclusive of all close affiliates of the applicant
(including subsidiaries, DBAs, operating affiliates, and parent companies) which provide, monitor,
or control telecommunications-related services in the U.S. or its territories.

1) Does the Applicant have existing (or planned) relationships/partnerships with any foreign companies
   and/or any foreign government-controlled companies? Yes         No
   If yes, indicate whether the relationship/partnership includes a management role by any foreign
   companies. Provide the name(s) of the individuals and foreign companies and explain the nature of
   the relationship, including whether the relationship currently exists and/or is intended to continue in
   the future.

    Response:

                                                 REDACTD




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                                                        REDACTED




2) Identify the total number of current employees, and planned number of employees of the company for
   the next 12 months.

    Response:

                                                        REDACTED




3) Will any non-U.S. citizen have access to one or more of the following:

    a) Physical facilities and/or equipment under the company’s control? Yes           No
       If yes, provide identity of person(s) 1 and explain the type of access that will be provided.

    Response:

                                                        REDACTED




    b) Customer records, including Customer Proprietary Network Information (CPNI), billing and Call
       Detail Records (CDRs)? Yes       No
       If yes, provide identity of person(s) and explain the type of access and records that will be
       provided.

    Response:

                                                        REDACTED




1
 For each such individual, provide name (list all the names and aliases used by that person), country of citizenship
(if dual citizen, list both countries), date and place of birth, U.S. alien number (if applicable), passport identifying
information for all passports held (including number and country), all residence addresses, all business addresses
and all phone numbers.


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                                                REDACTED




    c) Electronic interfaces that allow control and/or monitoring of the infrastructure under the
       company’s control including, but not limited to, access to actual communications content and
       data? Yes     No
       If yes, provide identity of person(s) and explain the type of access and control that will be
       provided.

    Response:

                                                REDACTED




4) What access control/security policies are in place on the production network?

    Response:

                                                REDACTED




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                                                  REDACTED




5) What encryption products/technologies have been installed on these production networks?

   Response:

                                              REDACTED




6) Does the company have any screening and/or vetting procedures which will be applied to U.S. or
   non-U.S persons who have access, remote or otherwise, to communications network facilities,
   equipment, or data?
   Yes      No
   If yes, explain all such procedures.

   Response:

                                              REDACTED




7) Does the company currently operate or plan to operate a website? Yes No
   If yes, provide all URL addresses for any current or known future company sites and describe
   whether the information therein is up to date.




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    Response:

                                                 REDACTED




8) Provide all addresses of the present and anticipated physical locations of company network equipment
   and infrastructure, whether owned or leased.

    Response:

                                                 REDACTED




9) Identify each individual or entity, whether direct or indirect, holding or controlling greater than a 5%
   equity stake in the Applicant company (whether voting or non-voting), highlighting any foreign
   government entities. Please be sure to include the ultimate parent owner of the Applicant and any
   other companies/individuals owning more than a 5% equity stake in the chain of ownership.

    a) For each such individual or entity, include a clear explanation of involvement in the company,
       including whether they will have a management role.

    Response:

                                                 REDACTED




    b) For each such individual or entity, provide all identifying information, as follows:

        i)  For individuals, provide name, citizenship(s), date and place of birth, U.S. alien number (if
            applicable), passport(s) identifying information (including number and country), all residence
            addresses, all business addresses, and all phone numbers.
        ii) For entities, provide country of incorporation/main place of business, general business type
            (e.g. holding company, investment firm, etc.), all business addresses, and related phone
            numbers.

    Response:

                                                 REDACTED




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10) Has the company, any company officers/directors or any individual/company with 10% or greater
    ownership interest in the company, ever been investigated, arraigned, arrested, indicted or convicted
    of any of the following:

    a) Espionage-related acts, or criminal acts including violations of the International Trade in Arms
       Regulations (ITAR), the Export Administration Regulations (EAR), or other US law? Yes
       No

    b) Deceptive sales practices, violations of the Consumer Fraud Act and regulations, and/or other
       fraud or abuse practices whether pursuant to local, state or federal law?
       Yes      No

    c) Violations of local, state or federal law in connection with the provision of telecommunications
       services, equipment and/or products and/or any other practices regulated by the
       Telecommunications Act of 1996 and/or by state public utility commissions? Yes        No

    If yes to any of the above, please describe in detail, including name(s) of individual(s) and/or
    companies involved, date(s), and current status or final disposition of matter, including any terms of
    settlement.


Section II: Company Operations
Please answer all questions in the following sections inclusive of all close affiliates of the applicant
(including subsidiaries, DBAs, operating affiliates, and parent companies) which provide, monitor,
or control telecommunications-related services in the U.S. or its territories.

1) Has the company been operational over the course of the current and previous year?
   Yes     No     If yes, answer the following:

    a) Provide separately for each year the Cost of Goods Sold (COGS).

    b) What was the total amount of COGS allocated for telecommunications equipment and service
       types?

    c) Describe, for all services provided to each category of customer (e.g. enterprise, residential, carrier,
        etc.):

        i.   Total number of subscribers;

        ii. Total annual gross revenue for preceding fiscal year;

        iii. Percentage of total gross revenue per category of customer for preceding fiscal year.

2) List all expected and actual Federal, State, and local government customers including any classified
   contracts, and include a description of all services to be provided, or services that are currently being
   provided, to such customers.




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   Response:

                                               REDACTED


3) For each member of the Applicant’s senior management team, list the names (where applicable) of
   the CEO (Chief Executive Officer), President, CFO (Chief Financial Officer), CIO (Chief
   Information Officer), CTO (Chief Technical Officer), COO (Chief Operating Officer), Senior VPs,
   and any other positions involved in exercising day-to-day management responsibilities:

   a) Explain the nature and extent of each senior manager’s involvement in the company; and

   b) For each individual, provide name (list all the names and aliases used by that person), country of
      citizenship (if dual citizen, list both countries), date and place of birth, U.S. alien number (if
      applicable), passport identifying information for all passports held (including number and
      country), all residence addresses, all business addresses and all phone numbers.

   Response:

       Viettel America’s senior management team is as follows:

        Name:                        Mr. Bui Quang Huy
        Title:                       President
        Country of citizenship:      Vietnam
        Date and place of birth:     [REDACTED], 1981
                                     Namdinh, Vietnam
        Passport Information:        Vietnam
                                     Number B363[REDACTED]
                                     Issued October 12, 2009 Expires
                                     October 12, 2019
        Residence address and        [REDACTED]
        phone number:                Tay Son Street Dong Da District, Ha Noi
                                     10000, Vietnam
                                     [REDACTED]
        Business address and         Viettel Group
        phone number:                01 Giang Van Minh Street
                                     Ba Dinh District, Hanoi
                                     10000, Vietnam
                                     + 84 462556789
        Responsibilities:            Oversees the overall operation of Viettel
                                     America, including formulating and
                                     implementing the company’s strategic and
                                     business plans


        Name:                        REDACTED
        Title:                       REDACTED
        Country of citizenship:      REDACTED



                                                 -7-


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         Date and place of birth:       REDACTED

         Passport Information:          REDACTED



         Residence address and
         phone number:


         Business address and
         phone number:


         Responsibilities:



         Name:                          REDACTED
         Title:                         REDACTED
         Country of citizenship:        REDACTED
         Date and place of birth:       REDACTED

         Passport Information:          REDACTED



         Residence address and
         phone number:


         Business address and          Viettel Group
         phone number:                 01 Giang Van Minh Street
                                       Ba Dinh District, Hanoi
                                       10000, Vietnam
         Company role:                 REDACTED




4) Identify a senior officer or employee (U.S. citizen or legal alien residing in the U.S. with an active
   security clearance or able to obtain one) who will be the Applicant’s authorized law enforcement
   point of contact responsible for accepting and overseeing compliance with subpoenas/court
   orders/search warrants including responding to official requests and/or compulsory processes from
   U.S. law enforcement or other U.S. government agencies.

    a) For this individual, explain the relationship to the Applicant and provide name (list all the names
       and aliases used by that person), country of citizenship (if dual citizen, list both countries), date
       and place of birth, U.S. alien number (if applicable), passport identifying information for all


                                                   -8-


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       passports held (including number and country), all residence addresses, all business addresses and
       all phone numbers.

   Response:

                                               REDACTED




   b) Confirm that the Applicant will report to the appropriate law enforcement agencies, immediately
      upon discovery:

       i)   Any act of compromise of a lawful interception of communications or access to call-
            identifying information to unauthorized persons or entities? Yes

       ii) Any act of unlawful electronic surveillance that occurred on its premises or via electronic
           systems under its control? Yes


5) Will the Applicant store and/or maintain any U.S. communications content, transactional data, call-
   associated data, billing records or other subscriber information? Yes No
   If yes, please answer the following:

   a) Describe what types of records will be stored.

   Response:

                                               REDACTED




   b) Provide all addresses of locations where such records will be stored and/or remotely
      accessed/managed via electronic systems.

   Response:

                                               REDACTED


   c) If any storage location differs from the Applicant’s address, explain the general purpose of the
      location and its function within the Applicant’s business.




                                                 -9-


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    Response:

                                                 REDACTED




    d) Describe all physical/electronic security measures utilized for all locations/systems to protect the
       confidentiality of records.

    Response:

                                                 REDACTED




    e) Confirm that the Applicant will inform the National Security Division (NSD) of the U.S.
       Department of Justice if, in the future, any record storage/access location is transferred and/or
       newly established outside of the U.S. Yes

    f) Can the Applicant agree to make any and all records not stored in the U.S. electronically available
       in the U.S. within five business days of law enforcement serving legal process through the
       Applicant’s U.S. based point of contact (identified in question 4 above)?
       Yes     No     Not Applicable

    Response:

                                                 REDACTED



6) Describe the Applicant’s lawful intercept solution(s). Include all lawful intercept capabilities of the
   Applicant company to include whether the Applicant uses (or intends to use) a Trusted Third Party
   (TTP) provider. If so, please provide the name of that TPP and whether the Applicant has a signed
   agreement with that TPP. If the Applicant will use its own equipment, please specify the equipment
   and describe the functions supported.

    Response:

                                                 REDACTED




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7)    Describe the customer base of the Applicant (business, residential, carrier, enterprise, etc.). Please
     identify the top 10 business customers, and provide their billing address and contact person.

     Response:

                                                  REDACTED




8) What, if any, outside capabilities via remote access will exist within the Applicant company to control
   operations over the network (e.g., audit mechanisms, record access monitoring)?

     Response:

                                                  REDACTED




                                                   - 11 -


FOR OFFICIAL USE ONLY                                                     HIGHLY CONFIDENTIAL
                                                                     NOT FOR PUBLIC INSPECTION


Section III: Company Services

Please answer all questions in the following sections inclusive of all close affiliates of the applicant
(including subsidiaries, DBAs, operating affiliates, and parent companies) which provide, monitor,
or control telecommunications-related services in the U.S. or its territories.

1) Provide a general summary of the nature of the company’s current and planned services and
   operations, to include an explanation of the intended overall business model and its relationship with
   any sister and/or partner companies.

    Response:

                                REDACTED




2) Describe company’s carrier transport facilities (T1, DS3, Optical Carrier) that will enable customer
   data flow into and out of owned and/or leased equipment.

    Response:

                                                REDACTED




3) Will the company be operating any physical telecommunications switching platforms (TDM and/or
   VoIP switches)? Yes    No

    a) If yes, provide a network architecture diagram that shows all switches and connection points.




                                                 - 12 -


FOR OFFICIAL USE ONLY                                                    HIGHLY CONFIDENTIAL
                                                                    NOT FOR PUBLIC INSPECTION


   Response:



                                      REDACTED




4) Provide a description of any other intended network equipment and/or proposed infrastructure (e.g.,
   routers, media gateways, multiplexing/cross-connect facilities, signaling devices, other equipment).

   Response:

                                               REDACTED




                                                - 13 -


FOR OFFICIAL USE ONLY                                                     HIGHLY CONFIDENTIAL
                                                                     NOT FOR PUBLIC INSPECTION


5) Provide network architecture diagram(s) and/or topology map(s) that shows the company’s Points of
   Presence (POPs), Network Operations Centers (NOCs), datacenters, colocation facilities (if any), and
   geographic footprint.

                                                    REDACTED




6) Will the company use interconnecting carriers and/or peering relationships?
   Yes      No

       a) If yes, provide details, including the name of the carrier, the carrier’s address, and a contact
          person at the carrier.

   Response:

                                                REDACTED




7) Will the company rely on underlying carrier(s) to furnish services to its customers and/or resell any
   services?
   Yes     No



                                                 - 14 -


FOR OFFICIAL USE ONLY                                                        HIGHLY CONFIDENTIAL
                                                                        NOT FOR PUBLIC INSPECTION



        a) If yes, provide details and list whose services will be resold, including the name of the carrier,
           the carrier’s address, and a contact person at the carrier.

    Response:

                                                  REDACTED




8) Will the applicant or its affiliates be able to control operations at any POP and/or Network Operations
   Center (NOC) from any overseas locations? Yes             No

        a) If yes, what is the nature of the foreign-based control?

9) What services will be delivered to customers, and how will the services be delivered?

    Response:

                                 REDACTED


10) Does the company serve any sectors of U.S. infrastructure? Yes        No
    If yes, check all that apply:

            a.      Defense Industrial Base
            b.      U.S. Intelligence Community
            c.      Emergency Services
            d.      Government Facilities
            e.      Banking and Finance
            f.      Nuclear Reactors, Materials, or Waste
            g.      Drinking Water and Water Supply
            h.      Energy
            i.      Information Technology
            j.      Chemical
            k.      Commercial Facilities
            l.      Agriculture and Food Supply
            m.      Health Care
            n.      National Monuments
            o.      Transportation
            p.      Postal Shipping
            q.      Dams
            r.      Other (Please explain)




                                                   - 15 -


FOR OFFICIAL USE ONLY                                                     HIGHLY CONFIDENTIAL
                                                                     NOT FOR PUBLIC INSPECTION


Section IV: Services Portfolio Checklist

Instructions: Please check all applicable boxes that reflect the types of telecommunication services the
Applicant intends to provide in the U.S. only. Do not select any services that will be provided outside
the U.S. For each checked box, please provide a separate and full explanation at the end of this
questionnaire, as well as answer the Reference Questions below the table as they pertain to the services
you have indicated in the checklist.

Services Proposed
VOICE SERVICES
VoIP (Voice over Internet Protocol)
POTS (Plain Old Telephone Service)
TDM (Time Division Multiplexing)
Voicemail
PBX (Private Branch Exchange)
Centrex (Hosted/Managed PBX)
Callback Service
Calling Card
Dial Tone Service
Issue DID (Direct Inward Dial) Local Telephone Numbers
Local Exchange Service
Local Toll Service
Domestic/International Long Distance (Interexchange Service)
Tollfree Service
IVR (Interactive Voice Response)
Conference Calling
Operator Service
Directory Assistance
Dial Around Service (1010XXX Casual Calling)
Switched Access
Special Access (Dedicated Line)
Other

                       INTERNET AND DATA SERVICES
ISP (Internet Service Provider)
Data/Private Line
VPN (Virtual Private Network)
Web Hosting
LAN (Local Area Network)
WAN (Wide Area Network)
ISDN (Integrated Services Digital Network) BRI (Basic Rate Interface)
ISDN PRI (Primary Rate Interface)
DSL (Digital Subscriber Line)
Frame Relay
Email
International Voice/Data Service
Wireless/Mobile Voice/Data Services
Satellite Services


                                                 - 16 -


FOR OFFICIAL USE ONLY                                                      HIGHLY CONFIDENTIAL
                                                                      NOT FOR PUBLIC INSPECTION


RF (Radio Frequency), Microwave
Video
Other

                     CARRIER / ENTERPRISE WHOLESALE
Routing, Signaling Services
Transport Facilities
Leased Lines
Collocation Services
Other

Reference Questions

For each service checked in Section IV, answer the following questions.

   1) In what manner will the service(s) be delivered to your customers?
      (Please describe typical customer transactions. For example: How do you acquire customers?
      How do customers contract services? What are your terms of sale? What are the products and
      services you provide? How do you deliver them?)

   2) What kind of network infrastructure will be utilized to deliver the service(s)?

   3) Describe the Applicant’s network, operation, and services in detail.              Provide a detailed
      explanation of current and planned services.

   4) What equipment (make and model) will be utilized to provide the service(s)?

   5) Will the service(s) be facilities based, resold or both?
      Describe.

If more than one service was checked above, then answer Questions 1-4 above again for each of
those services.

   Response:

                                                 REDACTED




                                                  - 17 -


FOR OFFICIAL USE ONLY                   HIGHLY CONFIDENTIAL
                                   NOT FOR PUBLIC INSPECTION




                        REDACTED




                          - 18 -


FOR OFFICIAL USE ONLY                                                    HIGHLY CONFIDENTIAL
                                                                    NOT FOR PUBLIC INSPECTION


      The following diagram also describes the equipment for the calling card services:




                                               REDACTED




                                              REDACTED




                                               - 19 -


FOR OFFICIAL USE ONLY                       HIGHLY CONFIDENTIAL
                                       NOT FOR PUBLIC INSPECTION




                        REDACTED




                              - 20 -


FOR OFFICIAL USE ONLY                                                       HIGHLY CONFIDENTIAL
                                                                       NOT FOR PUBLIC INSPECTION



Making false, fictitious, or fraudulent certification may render the Applicant subject to criminal
prosecution under Title 18, United State Code, Section 1001, civil penalties.

Pursuant to Title 28 U.S.C. Section 1746, I declare under penalty of perjury that the foregoing is true and
correct to the best of my knowledge.

Executed this ___22____ day of __August_______ , year of __2013______.




X __________________________________
Bui Quang Huy




                                                  - 21 -



Document Created: 2018-08-15 09:40:45
Document Modified: 2018-08-15 09:40:45

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