TWare FCC Pet Adopt

PETITION submitted by U.S. Department of Justice

Petition to Adopt Conditions

2014-06-03

This document pretains to ITC-214-20130827-00232 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142013082700232_1048846

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


In the Matter of                                 )
                                                 )
TWare Connect LLC (formerly Mobile               )   File No. ITC-214-20130827-00232
Financial Services, LLC),                        )
                                                 )
             Applicant.                          )
                                                 )



                            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”), 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, 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 assurances of TWare Connect LLC (formerly

Mobile Financial Services, LLC) (“TWare”) and TeleWare Group Plc (“TeleWare”) (TWare’s

parent entity) to abide by the commitments and undertakings set forth in the attached June 3,

2014, Letter of Agreement from TWare and TeleWare to the DOJ (“the Agreement”).

           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




1
    47 C.F.R. § 1.41.


Corporation d/b/a Comsat Mobile Communications, etc., 16 FCC Rcd. 21,661, 21707 ¶ 94

(2001).

          After discussions and communications with representatives of the Applicants in

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

commitments set forth in the Agreement will help ensure that the agencies 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 to the Commission granting the application in the above-referenced

proceeding provided that the Commission conditions its consent on TWare’s and TeleWare’s

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
                                                    600 E Street, NW, Suite 10000
                                                    Washington, D.C. 20004


June 3, 2014




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Document Created: 2014-06-03 16:53:00
Document Modified: 2014-06-03 16:53:00

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