Petition To Adopt Co

PETITION submitted by U.S. Dept. of Justice

Petition to Adopt Condition on License

2016-10-28

This document pretains to ITC-214-20131017-00275 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142013101700275_1157300

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

                                                 )
                                                 )
In the Matter of                                 )
                                                 )
                                                 )
Telecom Services Network LLC                     )        FCC ITC-214-20131017-00275
                                                 )
                                                 )
                                                 )
                                                 )

                            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 proceedings, provided that the Commission conditions its approval on the

assurance of Telecom Services Network LLC (“TSN”) to abide by the commitments and

undertakings set forth in the October 26, 2016 Letter of Assurances (“LOA”), which is attached

hereto. The above-referenced proceedings involves the referenced application filed with the

Commission by TSN for authority under section 214 of the Communications Act of 1934, as

amended, to provide global or limited-global facilities-based and resale services to all

international points.

           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 with representatives of TSN, in connection with the above-referenced

proceedings, DOJ has concluded that the additional commitments set forth in the LOA 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 its

responsibilities of enforcing the law, protecting the national security, and preserving public

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

granting the applications in the above-referenced proceedings, provided that the Commission

conditions its consent on compliance with the LOA.



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, Rm 10000
Washington, D.C. 20004


October 27, 2016




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Document Created: 2016-10-27 10:38:56
Document Modified: 2016-10-27 10:38:56

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