Shuf Petition to Ado

PETITION submitted by U.S. Department of Justice

Petition to Adopt

2015-03-09

This document pretains to ITC-214-20140421-00130 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142014042100130_1078408

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

In the Matter of                                 )
                                                 )
                                                 )
Shuf Incorporated                                )
Application for authorization under Section      )          ITC-214-20140421-00130
214 of the Communications Act of 1934, as        )
amended                                          )
                                                 )
                                                 )
                                                 )

                            PETITION TO ADOPT CONDITIONS TO
                             AUTHORIZATIONS AND LICENSES


The Federal Bureau of Investigation (“FBI”), which is part of the U.S. Department of Justice,

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 FBI 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 Shuf Incorporated (“Shuf”) to abide by

the commitments and undertakings set forth in the March 5, 2015 Letter of Agreement (“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 Shuf in connection with the above-referenced

1
    47 C.F.R. § 1.41.


proceeding, the FBI has concluded that the additional commitments set forth in the LOA will

help ensure that the FBI, which has the responsibility of enforcing the law, protecting the

national security, and preserving public safety, can proceed appropriately to satisfy those

responsibilities. Accordingly, the FBI 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


March 9, 2015




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Document Created: 2015-03-09 10:59:54
Document Modified: 2015-03-09 10:59:54

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