VUSI Petition to Ado

PETITION submitted by U.S. Department of Justice

Petition to Adopt

2014-09-22

This document pretains to ITC-214-20131028-00298 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142013102800298_1061829

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

In the Matter of                                 )
                                                 )
                                                 )
Vodafone US Inc.                                 )
Application for authorization under Section      )          ITC-214-20131028-00298
214 of the Communications Act of 1934, as        )
amended                                          )
                                                 )
                                                 )
                                                 )

                            PETITION TO ADOPT CONDITIONS TO
                             AUTHORIZATIONS AND LICENSES


The Department of Justice (“DOJ”) and the Department of Homeland Security (“DHS”)(“the

Agencies”) submit 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 assurance of Vodafone US Inc. to abide by the

commitments and undertakings set forth in the September 16, 2014 Letter of Assurances

(“LOA”), 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 Vodafone US Inc. in connection with the

1
    47 C.F.R. § 1.41.


above-referenced proceeding, the Agencies have concluded that the additional commitments set

forth in the LOA 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 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


September 22, 2014




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Document Created: 2014-09-22 11:29:46
Document Modified: 2014-09-22 11:29:46

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