Attachment Responses

This document pretains to ITC-214-20141022-00280 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142014102200280_1065391

Talk America Services, LLC
Application for New Authorization
FRN: 0023997349

                                           Attachment 1

       Talk America Services, LLC (“Applicant”) submits this application for new authority to
provide international facilities-based and resold services to all international points pursuant to
Sections 63.18(e)(1) and 63.18(e)(2). The Applicant is a U.S. competitive local exchange carrier
(“CLEC”).

Response to Question 9

       The Applicant requests streamlined processing of this application pursuant to Section
63.12 of the Commission’s rules. The Applicant is not affiliated with either a foreign carrier or a
U.S. carrier that is dominant on the foreign end of a U.S. international route. Therefore, the
Applicant is entitled to non-dominant treatment, and this application qualifies for streamlined
processing.

Response to Question 11

        The Applicant is not a foreign carrier and is not affiliated with any foreign carrier.




DC\3598501.1


Talk America Services, LLC
Application for New Authorization
FRN: 0023997349

                                            Attachment 2

Response to Question 14

         The following information is submitted pursuant to Section 63.18(h) of the Commission’s
rules:

    1. The name, principal business, address and citizenship of the Applicant, are as follows:

               Name:                              Talk America Services, LLC
               Principal Business:                Communications Services
               Address:                           4001 Rodney Parham Rd.
                                                  Little Rock, AR 72212
               Citizenship:                       U.S. (Delaware)

    2. The name, principal business, address, citizenship, and ownership interest of CSL
       Services, LLC, the sole owner of Talk America Services, LLC, are as follows:

               Name:                              CSL Services, LLC
               Principal Business:                Communications Services
               Address:                           4001 Rodney Parham Rd.
                                                  Little Rock, AR 72212
               Citizenship:                       U.S. (Delaware)
               Ownership Interest in Applicant:   100% Direct Interest

    3. The name, principal business, address, citizenship, and ownership interest of
       Communications Sales & Leasing, Inc., the sole owner of CSL Services, LLC, are as
       follows:

               Name:                              Communications Sales & Leasing,
                                                  Inc.
               Principal Business:                Communications Services
               Address:                           4001 Rodney Parham Rd.
                                                  Little Rock, AR 72212
               Citizenship:                       U.S. (Delaware)
               Ownership Interest in Applicant:   100% Indirect Interest

    4. The name, principal business, address, citizenship, and ownership interest of Windstream
       Corporation, the sole owner of Communications Sales & Leasing, Inc., are as follows:

               Name:                              Windstream Corporation
               Principal Business:                Communications Services
               Address:                           4001 Rodney Parham Rd.
                                                  Little Rock, AR 72212
               Citizenship:                       U.S. (Delaware)


DC\3598501.1


               Ownership Interest in Applicant:    100% Indirect Interest

      5. The name, principal business, address, citizenship, and ownership interest of Windstream
         Holdings, Inc., the sole owner of Windstream Corporation, are as follows:

               Name:                               Windstream Holdings, Inc.
               Principal Business:                 Holding Company
               Address:                            4001 Rodney Parham Rd.
                                                   Little Rock, AR 72212
               Citizenship:                        U.S. (Delaware)
               Ownership Interest in Applicant:    100% Indirect Interest


       As a publicly traded company, the stock of Windstream Holdings, Inc. is widely held.
No entity or individual owns 10 percent or more of the equity of Windstream Holdings, Inc.

      6. The Applicant has no interlocking directorates with any foreign carriers.


Response to Question 15

     The following information is submitted pursuant to Section 63.18(d), (e) and (g) of the
Commission’s rules:

(d)      The Applicant has not previously received authority under Section 214 of the
         Communications Act, as amended. However, its indirect parent company, Windstream
         Corporation, holds domestic Section 214 authority under Section 63.01 of the
         Commission’s rules, and International Section 214 authority to provide global facilities-
         based and resale authority under Sections 63.18(e)(1) and 63.18(e)(2) of the
         Commission’s rules (FCC File No. ITC-214-19980925-00658).

(e)      The Applicant is requesting authority to provide global facilities-based and resold
         services to all international points pursuant to Sections 63.18(e)(1) and 63.18(e)(2) of the
         Commission’s rules. The Applicant certifies that it will comply with the terms and
         conditions specified in Sections 63.21, 63.22 and 63.23 of the Commission’s rules.

(g)      The Applicant is not seeking facilities-based authority pursuant to Section 63.18(e)(3).




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DC\3598501.1



Document Created: 2014-10-22 13:21:30
Document Modified: 2014-10-22 13:21:30

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