Attachment Attachment 1

This document pretains to ITC-214-20150121-00011 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142015012100011_1073779

Attachment 1 ­ Callmonitor LLC ­ 214 application

Question 9

Does the applicant request streamlined processing pursuant to 47 C.F.R. Section 63.12? If yes, include in Attachment 1 a statement of how
the application qualifies for streamlined processing.


Pursuant to 63.10(e) Callmonitor LLC of Nevada is affiliated to foreign company Callmonitor
Limited of England & Wales (registration number 03844878) as Richard Offenbach owns and
controls 100% of both entities.

Pursuant to 63.12(b) iii, the foreign company Callmonitor Limited of England & Wales owns no
facilities, or only mobile wireless facilities, in any market.




Question 11

If the applicant is a foreign carrier, or is affiliated (as defined in 47 C.F.R. Section 63.09(e)) with a foreign carrier, provide in Attachment 1
the information and certifications required by Section 63.18(i) through (m).



63.18 (i) A certification as to whether or not the applicant is, or is affiliated with, a foreign carrier. The certification shall state with
specificity each foreign country in which the applicant is, or is affiliated with, a foreign carrier.


The applicant is affiliated with one company in the United Kingdom, Callmonitor Limited
(registered in England & Wales, registration number 03844878)

The applicant has no other affiliation in any other country


63.18 (j) A certification as to whether or not the applicant seeks to provide international telecommunications services to any destination
country for which any of the following is true.
The certification shall state with specificity the foreign carriers and destination
countries:
(1) The applicant is a foreign carrier in that country; or
(2) The applicant controls a foreign carrier in that country; or
(3) Any entity that owns more than 25 percent of the applicant, or that controls the applicant, controls a foreign carrier in that country.
(4) Two or more foreign carriers (or parties that control foreign carriers)
own, in the aggregate, more than 25 percent of the applicant and are parties to, or the beneficiaries of, a contractual relation (e.g., a joint
venture or market alliance) affecting the provision or marketing of international basic telecommunications services in the United States.


The applicant is not a carrier in any other country. The applicant does not control a foreign
carrier. The applicant is 100% owned by Richard Offenbach who also owns 100% of United
Kingdom carrier Callmonitor Limited (registered in England & Wales, registration number
03844878)


63.18 (k) For any country that the applicant has listed in response to paragraph
(j) of this section that is not a member of the World Trade Organization, the applicant shall make a demonstration as to whether the foreign
carrier has market power, or lacks market power, with reference to the criteria in §63.10(a) of this chapter.
(1) The named foreign country (i.e., the destination foreign country) is a Member of the World Trade Organization; or
(2) The applicant’s affiliated foreign carrier lacks market power in the
named foreign country; or
(3) The named foreign country provides effective competitive opportunities to U.S. carriers to compete in that country’s market for the
service that the applicant seeks to provide (facilities­based, resold switched, or resold non­interconnected private line services).
An effective competitive opportunities demonstration




United Kingdom is a member of the World Trade Organisation.




63.18 (l) [Reserved]



63.18 (m) With respect to regulatory classification under §63.10 of this part, any
applicant that is or is affiliated with a foreign carrier in a country listed in response to paragraph (i) of this section and that desires to be
regulated as non­dominant for the provision of particular international telecommunications services to that country should provide
information in its application to demonstrate that it qualifies for non­dominant classification pursuant to §63.10 of this part.


Pursuant to 63.10(a)3, the applicant’s affiliated company, Callmonitor Limited (registered in
England & Wales, registration number 03844878) does not operate or do business in the
international transport or local access markets in the United Kingdom or any other country or
market and therefore should be classified as non­dominant.




Question 12

Does the applicant seek authority to provide service to any destination described in paragraphs (1) through (4) of Section 63.18(j)? If yes,
list those destinations in Attachment 1 as a response to question 12.


The applicant seeks authority to offer service to all destinations including the United Kingdom
where it has an affiliate Callmonitor Limited (registered in England & Wales, registration
number 03844878). The applicant’s is however only seeking authority to resell a service, not
to use it’s own facilities.



Document Created: 2019-04-18 11:43:40
Document Modified: 2019-04-18 11:43:40

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