Petition to adopt LO

PETITION submitted by DOJ NSD FIRS

Petition to adopt

2014-09-10

This document pretains to ITC-214-20140310-00092 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142014031000092_1060712

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

In the Matter of                                 )
                                                 )
                                                 )
KOL TELECOM SERVICES                             )
                                                 )          ITC-214-20140310-00092
Application for authorization under Section      )
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

KOL TELECOM SERVICES (“KOL”) to abide by the commitments and undertakings set forth

in the August 25, 2014 Letter of Assurances (“LOA”), which is attached hereto. The above-

referenced proceeding involves an application filed with the Commission by KOL for authority

under section 214 of the Communications Act of 1934, as amended, to provide facilities based

and resale services between the United States and permissible 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 KOL in connection with the 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 10, 2014




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Document Created: 2014-09-10 14:40:47
Document Modified: 2014-09-10 14:40:47

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