Attachment Attachment 1

This document pretains to ITC-214-20141219-00324 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142014121900324_1071752

                                        ATTACHMENT 1

The Application qualifies for streamlined treatment pursuant to Sections 63.12(c)(1)(ii), (iii) and
(iv).

        Pursuant to Section 63.12(c)(1)(ii), an application may qualify for streamlined treatment
if the Applicant qualifies for a presumption of non-dominance under Section 63.10(a)(3). The
Applicant, The People’s Operator USA, LLC (“TPO USA”) qualifies for a presumption of non-
dominance under 63.10(a)(3) because the Applicant’s sole foreign affiliated carrier, The People’s
Operator LLP, (“TPO UK”) lacks 50% market share in the United Kingdom, the only country
where TPO UK is based and currently provides services. The United Kingdom is the only
destination market in which the Applicant is affiliated with a foreign carrier, which is TPO UK.

       The application also qualifies for streamlined treatment pursuant to Section
63.12(c)(1)(iii) because TPO UK owns no facilities, or only mobile wireless facilities, in the
United Kingdom.

       The application also qualifies for a presumption of non-dominance under Section
63.12(c)(1)(iv) because the United Kingdom is a member of the WTO and because the
Applicant qualifies for non-dominance pursuant to Section 63.10(a)(4). The Applicant will
provide international switched service solely through the resale of an unaffiliated U.S. facilities-
based carrier’s international switched services.

Responses to Sections 63.18 (i)-(m)

(i)    The Applicant is affiliated with TPO UK, a non-dominant, mobile wireless reseller
       in the United Kingdom. TPO UK and the Applicant are each indirectly owned and
       controlled by The People’s Operator plc (“TPO PLC”), a UK-registered holding
       company.

(j)    The Applicant seeks to provide international telecommunications services to a destination
       country, the United Kingdom, in which an entity, TPO PLC, indirectly, through its
       wholly-owned subsidiary, The People’s Operator Holdings Limited (“TPO
       Holdings”) owns more than 25 percent of the Applicant and also controls TPO UK, in
       that destination country.

(k)    TPO UK lacks market power in United Kingdom, which is a member of the World Trade
       Organization (“WTO”).

(l)    Reserved. – No response required.

(m)    The Applicant qualifies for non-dominant classification pursuant to sections 63.10(a)(3)
       and (a)(4). The Applicant’s affiliated foreign carrier, TPO UK, a United Kingdom based
       non-dominant, mobile wireless reseller, lacks 50 percent market share in the international
       transport and local access markets in the United Kingdom. Moreover, the Applicant will


      provide international switched service solely through the resale of an unaffiliated U.S.
      facilities-based carrier’s international switched services.

(n)   As evidenced by the certificate, attached hereto as Attachment A, the Applicant has not
      accepted any special concessions from any carrier possessing market power in a
      destination market and will not enter into such concessions in the future.

(o)   As evidenced by the certificate, attached hereto as Attachment A, no party to this
      application is subject to a denial of Federal benefits pursuant to Section 5301 of the Anti-
      Drug Abuse Act of 1988.





Document Created: 2014-12-19 17:26:40
Document Modified: 2014-12-19 17:26:40

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