US Telephone and Tel

COMMENT submitted by U.S. Department of Justice

US Telephone & Telegraph Petition to Adopt

2015-10-08

This document pretains to ITC-214-20140327-00108 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142014032700108_1106939

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

In the Matter of                                 )
US Telephone & Telegraph                         )
Application for authorization under Section      )
214 of the Communications Act of 1934, as        )
amended                                          )          ITC-214-20140327-00108
                                                 )




                            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 US Telephone & Telegraph to abide by the commitments and undertakings set forth

in the September 28, 2015 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 US Telephone & Telegraph in connection with

the above-referenced proceeding, DOJ has concluded that the additional commitments set forth

1
    47 C.F.R. § 1.41.


in the LOA will help ensure that DOJ, an 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 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 8, 2015




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Document Created: 2015-10-08 14:19:17
Document Modified: 2015-10-08 14:19:17

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