Attachment 20170817125952-167.p

20170817125952-167.p

SUPPLEMENT

Supplement

2014-08-06

This document pretains to ITC-214-20140806-00234 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142014080600234_1615697

Georcze Li mmummund From: Brown, Tyrone (NSD) <Tyrone.Brown@usdoj.gov> Sent: Friday, August 29, 2014 10:45 AM To: George Li Ce: Dupuy, Siobhan (NSD) Subject: RE: Cover Letter Reference EB 2014—22 (comments by August 27, 2014) Hi George, We will need these to come off streamline. Questions have been sent out to the company. Thanks, : Ty -----Original Message————— From: George Li [mailto:George.Li@fce.gov) Sent: Friday, August 29, 2014 9:12 AM To: Sofield, Richard (NSD) Cc: Brown, Tyrone (NSD) Subject: Fw: Cover Letter Reference EB 2014—22 (comments by August 27, 2014) Help please. Sent from my BlackBerry 10 smartphone on the Verizon Wireless 4G LTE network. From: George Li <George.Li@fec.gov> Sent: Thursday, August 28, 2014 9:06 AM . To: Ongman, Joanne (NSD) (Joanne.Ongman@usdoj.gov); Cassanelli, Jennifer (NSD) (Jennifer.Cassanelli@usdoj.gov); ‘Dupuy, Siobhan (NSD)‘ (Siobhan.Dupuy@usdoj.gov); ‘Taylor, Kristin (NSD)‘ (Kristin.Taylor@usdoj.gov); Caroline.Brown@usdoj.gov Subject: FW: Cover Letter Reference EB 2014—22 (comments by August 27, 2014) Could you HELP please ? From: George Li Sent: Wednesday, August 27, 2014 9:32 AM To: Sofield, Richard (NSD) (Richard.Sofield2 @usdoj.gov) Cc: Brown, Tyrone (NSD) (Tyrone.Brown@usdoj.gov); McConnell, Mark (Mark.McConnell@usdoj.gov); Shaifer, Marilyn (NSD) Subject: FW: Cover Letter Reference EB 2014—22 (comments by August 27, 2014) Hi Rick; May we have your comments today please ? From: Adrienne Downs Sent: Thursday, August 07, 2014 3:09 PM To: ‘edward.hand@usdoj.gov‘; ‘chemmerlein@ntia.doc.gov‘; ‘maydc@state.gov‘; ‘Christopher.Siefken@ic.fbi.gov‘; ‘Marilyn.Shaifer@usdoj.gov‘; ‘Tyrone.Brown@usdoj.gov‘; ‘Brian.williams@associates.dhs.gov‘; ‘Cassanelli, Jennifer (NSD) (Jennifer.Cassanelli@usdoj.gov<mailto:Jennifer.Cassanelli@usdoj.gov>) ‘ (Jennifer.Cassanelli@usdoj.gov<mailto:Jennifer.Cassanelli@usdoj.gov>)‘; ‘Shawn.Cooley@HQ.DHS.Gov‘; ‘TTelecom@usdoj.gov‘; ‘Siobhan.Dupuy@usdoj.gov‘; ‘alex.daman@dhs.gov‘; ‘Joanne.Ongman@usdoj.gov‘; ‘Jennifer.Rockoff@usdoj.gov‘; ‘Jonathan_McHale@ustr.eop.gov‘; ‘Richard.Sofield2@usdoj.gov‘; ‘glenn.kaminsky@hq.dhs.gov‘; ‘dale.barr@hq.dhs.gov‘;‘sdesmond@ostp.eop.gov‘; ‘IP—FCC@dhs.gov‘; 1

Adrienne McNeil From: Paz, Bermel (NSD) <Bermel.Paz@usdoj go‘v> Sent: Thursday, May 28, 2015 10:43 AM To: David Krech; Adrienne McNeil Ce: Slade, Janine; Jacobs, Samuel P CTR OSD DOID) CIO (US) (samuel.p.jacobs.c :r@m iil. mil); Sofield, Richard (NSD) f Subject: ITC—214—20140806—00234 (Mi Fi, LLC) Attachments: MiFi Petition to Adopt May 19 2015.pdf Categories: Actions Taken PN David/Adrienne, I am still having problems submitting/uploading documents in MyIBFS. This time, | got a blank screen after clicking the "submit" button. I submitted the attached petition twice and, in both instances, got blank screens. FYI and thanks. Beérmel T. Paz Attorney U.S. Department of Justice National Security Division Foreign Investment Review Staff (FIRS) Bicentennial Building, 600 E Street NW, Suite 10006 Washington DC 20530 & (202) 233—2022 C (202) 598—9037

Adrienne McNeil From: Adrienne McNeil Sent: Thursday, June 11, 2015 1:27 PM To: delsmith@jonesday.com; Edward A. Maldonado (eam@maldonado—group.com) Ce: ‘edward.hand@usdoj.gov‘; ‘chemmerlein@ntia.doc.gov‘; ‘maydc@state.gov‘; ‘Christopher.Siefken@ic.fbi.gov‘; ‘Marilyn.Shaifer@usdoj.gov‘; ‘Tyrone.Brown@usdoj.gov‘; ‘Brian.williams@associates.dhs.gov‘; ‘Shawn.Cooley@HQ.DHS.Gov; ‘TTelecom@usdoj.gov‘; ‘Siobhan.Dupuy@usdoj.gov‘; ‘Theme, Nkechi Payton (Nkechi_PIheme@ostp.eop.gov)"; ‘alex.daman@dhs.gov‘; ‘Joanne.Ongman@usdoj.gov‘; ‘matthew.bernstein@ic.fbi.gov‘; ‘Jennifer.Rockoff@usdoj.gov‘; ‘Jonathan_McHale@ustr.eop.gov‘; ‘Richard.Sofield2 @usdoj.gov‘; ‘glenn.kaminsky@hq.dhs.gov‘; ‘dale.barr@hq.dhs.gov‘; IP—FCC@®dhs.gov‘; ‘kristin.taylor@usdoj.gov‘; ‘jJohn.delmore@ic.fbi.gov‘; ‘ttwg@leo.gov‘; ‘mark.meconnell@usdoj.gov‘; ‘robert.s.gorman.civ@mail.mil‘; ‘caroline.brown@usdoj.gov‘; ‘Hagar, Richard (richard.hagar@HQ.DHS.GOV)‘; Denise Coca; David Krech; Susan OConnell; Howard Griboff; Kathleen Collins; Veronica Garcia— Ulloa Subject: Applications Granted Attachments: TELO1737.pdf ITC—214—20130119—00017 — Five9, Inc. ITC—214—20140806—00234 — My Fi, LLC The above listed applications have been granted by Public Notice released June 11, 2015; Report No. TEL— 01737; DA No. 15—690 (attached). Adrienne McNeil International Bureau, FCC (202) 418—0412 Adrienne.McNeil@fcec.gov

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of it Ne ues Nust Mi Fi, LLC Application for authority pursuant ITC—214—20140806—00234 t to Section 214 of the h Ag Communications Act of 1934, ut e as amended, for global authority to 2 operate as an international oA facilities—based and resale carrier Ay, PETITION TO ADOPT CONDITIONS TO AUTHORIZATIONS ANDLICENSES U The U.S. Department of Justice ("USDOJ"), to include its component, the Federal Bureau of Investigation ("FBI"), submits this Petition to Adopt Conditions to Authorizations and Licenses ("Petition"), pursuant to Section 1.41 of the Federal Communications Commission ("Commission") rules.‘ Through this Petition, the USDOJ 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 Mi Fi, LLC ("Mi Fi") to abide by the commitments and undertakings set forth in the May 19, 2015 Letter of Agreement ("LOA"), a copy of which is attached hereto. The Commission has long recognized that law enforcement, national security, and public safety concerns are part ofits 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 ofComsat Corporation d/b/a Comsat Mobile Communications, etc., 16 FCC Red. 21,661, 21707 T 94 (2001). 147 C.F.R. § 1.41.

After discussions with representatives of Mi Fi in ‘connection with the above— referenced proceeding, the USDOJ and FBI have 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 requnsibilities. Accordingly, the USDOJ 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, Is/ 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 May 27, 2015

May 19", 30158 Unit Chief, Science and Technology Policy and Law Unit Fedecral Burcau of Investigation 35 Pennsylvania Ave, NW Room 7350 Washington, DC 20533 Re: Pending application by MyFi, LLC {"MyFi") for authorization under Section 214 of the Communications Act of 1934, as amended {(FCC file number ITC—214— 20140806—00234). Dear Unit Chief: This Letter of Agreement ("LOA"®"or "Agreement") outlines the commitments being made by MyFi to the Federal Bureau of Investigation ("FBI"}, which is part ofthe U.S. Department of Justice ("DOJ"), in order to address national security, lawenforcement, and public safety concerns raised with regard to MyFi‘s application to the Federal Communications Commission ("FCC" or "Commission") requesting authority to provide global or limited global facilitios—based service or global or limited—global resale services between the U.S. and all authorized points (47 C.F.R. §§ 63.18(e)(1) and (e)(2)) under Section 214 ofthe Communications Act of 1934, as amended. MyFi, a Florida corporation headquartered at 7791 NW 46" Street. Suite 105, Doral, Florida 33166, intends to offer international calling for residential and mobile customers, either directly or by resciling Voice over Internet Protocol {(YolP) services through carrier partners. between the US and all suthorized international points. MyFi agrees that its intended future services offerings are covered by and that it will comply with all applicable lawful interception statutes, regulations, and requirements. including the Communications Assistance for LawEnforcement Act (CCALEA®), 47 U.S.C, 1001 et seq., and its implementing regulations, and will comply with all court orders and other legal process for lawfully authorized electronic surveillance. Upon completion of the development of its lawful interception capabilities, MyFi will request that the FBI send its CALEA Implementation Unit to conduct a CALEA compliance test.‘ Once a compliance test is scheduled, MyFi will provide notice of the scheduled date, MyFi will continue to maintain such lawful interception capabilities forthe duration ofthe time it provides services subject to CALEA." MyFi also \ _A request can be made by contecting the general helpdesk for the CALEA Implementation Unit at (8553 LECALEA (532—2532). * MyFi may use a U.S. Trusted Third Party outsourcing partner to implement its lawful intercept capability.

agrees that it will comply with all other statutes, regulations, and requirements regarding clectronic surveillance. MyFi agrees to maintain a point of contact in the US, preferably a US citizen or Lawful Permanent Resident, to receive service of process for US records and to support US law enforcement agencies‘ lawhul requests for assistance and survelllance needs. This point of contact and his/her contact information will be provided to the FBI at least 30 days prior to the date that MyFi begins to provide services, and will be subject to FRBI approval. MyFi also agrees to provide FBH at least 30 days prior notice of any change to this POC, with all such changes also subject to FBI approval. MyFi also agrees that its designated law enforeement point ofcontact will have access to, and will make all customer billing records, subscriber information, and any other related information used, processed, or maintained in the ordinary course ofbusiness relating to telecommunications servicesoffered in the U.S. (U.S. Records) available promptly and in any event no later than five business days, in the U.S. in response to lawful U.S. process." For these purposes, U.S. Records shall include information subject to disclosure to a U.S. Federal or state governmental entity under the procedures specified in Sections 2703(c) and {d) and Section 2709 of Title 18 of the .S. Code. MyFi also agrees to ensure that U.S. Records are not made subject to mandatory destruction under any foreign laws. MyFi agrees that it will not, directly or indirectly, disclose or permit disclosure ofor access to U.S. Records, domestic communications. or any information (including the content of communications) pertaining to a wiretap or electronic surveillance order., pen‘trap order, subpoena, or other lawful demand by a U.S. lawenforcement agency for U.S. Records or lawfully authorized electrontc surveillance in response to legal process or a request on behalf of a non—U.S. government, without first satisfying all pertinent requirements of U.S. law and obtaining the express written consent of DOJ or the authorization ofa court ofcompetent jurisdiction in the U.S. The term"non—U.S. government" means any government, including an identified representative, agent, component, or subdivision thereof, that is not a local, state, or federal government in the U.S. Any such requests or legal process submitted by a non—U.S. government to MyFi shall be referred to DOJ as soon as possible, and in no event later than five business days after such request or legal process is received by or known to MyFi, unless the disclosure of the request or legal process would be in violation of U.S. law or anorder ofa court of the U.S. MyFi agrees thal in the event the commitments set forth in this letter are breached, FRBI may request, in addition to any other remedy available at law or equity, that the FCC modify, condition, revoke, cancel, terminate, or reader null and void any relevant license, permit, or other authorization granted by the FCC to MyFi or any successor—in—interest. Nothing herein shall be construed to be a waiver by MyFi of, or limitation on, its right to oppose or comment on any such request. *\ This statement does not supersede or repliace MyFI‘s other duties to comply with any applicable FCC requirements and regulations regarding the storage and protection ofcustomer records. including hut not Himited to requirements related to the storage and protection of Customer Proprictary Network Information.

Nothing in this letter is intended to excuse MyFi from its obligations to comply with any and all applicable legal requirements and MyFi, including any and all applicable statutes. regulations, requirements, or orders. MyFi understands that, upon execution ofthis letter by an authorized representative or attorney for MyFi, DOJ shall notify the FCC that it has no objection to the FCC‘s grant ofits appliecation. The Company can send all notices pursuant to this letter to: Unit Chief, Science and Technology Policy and LawUnit Federal Bureau of Investigation 935 Pennsylvania Ave, NW Room 7350 Washington,. DC 20535 Courtesy electronic copies ofall notices and communications should also be sent to Tonathan Frenke!l ofthe FBI (at jJonathanfreakel@ictbiLgov) / ff@g{z}e: "etee HMEZIADRES Tit}e: mw "\‘ {""’:i w % %2‘"{‘}} {Z& J’x}\?«é‘ Cfis For MyFi, LLC


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Document Modified: 2019-05-22 13:58:29
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