First Petition to Ad

PETITION submitted by U.S. Dept. Of Justice

Petition to Adopt

2014-09-05

This document pretains to ITC-214-20130726-00202 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142013072600202_1060261

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

In the Matter of                            )
                                            )
                                            )
First Technology Development, Inc.          )
Application for authorization under Section )                ITC-214-20130726-00202
214 of the Communications Act of 1934, as )
amended                                     )
                                            )
                                            )
                                            )

                            PETITION TO ADOPT CONDITIONS TO
                             AUTHORIZATIONS AND LICENSES


The Department of Justice (“DOJ”) submits 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, DOJ advises the Commission that it has no

objection to the Commission approving the authority sought in the above-referenced proceeding,

provided that the Commission conditions its approval on the assurance of First Technology

Development, Inc. to abide by the commitments and undertakings set forth in the August 25,

2014 Letter of Agreement (“Agreement”), which is attached hereto.

           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 First Technology Development, Inc. in

connection with the above- referenced proceeding, DOJ has concluded that the additional

commitments set forth in the Agreement

1
    47 C.F.R. § 1.41.


will help ensure that DOJ, a U.S Government agency with responsibility for enforcing the law,

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

those responsibilities. Accordingly, DOJ advises the Commission that it has no objection to the

Commission granting the application in the above-referenced proceeding, provided that the

Commission conditions its consent on compliance with the Agreement.



Respectfully submitted,

/S/ Richard C. Sofield
Richard C. Sofield
U.S. Department of Justice
Director - Foreign Investment Review Staff
National Security Division
Bicentennial Building
600 E Street, NW, Suite 10000
Washington, D.C. 20004


August 28, 2014




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Document Created: 2014-08-28 13:39:15
Document Modified: 2014-08-28 13:39:15

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