Sangoma U.S. Inc. Su

SUPPLEMENT submitted by Sangoma U.S., Inc.

Sangoma U.S., Inc. Supplemental Filing

2016-01-19

This document pretains to ITC-214-20150918-00222 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142015091800222_1122954

                                                                    _~ HORSEY'"
                                                                           DORSLY & WIiITN~Y LI._I'

                                                                                KRISTIN K. BERKLAND
                                                                                            Associate
                                                                                       (612)492-6194
                                                                                    FAX(612) 395-5517
                                                                          berkland.kristin@dorsey.com


January 19, 2016

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

Attn:   Competition Policy Division
        Wireline Competition Bureau

        Adrienne McNeil
        International Bureau Policy Division

Re:     WC Docket No. 16-11

        and

        IBFS File No. ITC-214-20150918-00222

        Supplement to Sangoma U.S., Inc.'s Request for Domestic Section 214 Transfers
        of Control Authority and International and Domestic Special Temporary Authority


Dear Mrs. Dortch:

        Pursuant to a January 13, 2013 request from the FCC Wireline Competition Bureau
("WCB"), Sangoma U.S., Inc.("Sangoma U.S.") respectfully submits this supplement to
Attachment 3 of its Request for Domestic Section 214 Transfers of Control Authority and
International and Domestic Special Temporary Authority. The supplement provides further
information, as requested by the FCC WCB, on the corporate structure of the individuals and
entities that have a ten percent or more equity ownership in Sangoma U.S.; overlap between
the customers, services, and territories for SIPStation Inc. ("SIPStation") and Rockbochs Inc.
("Rockbochs") prior to acquisition; and confirmation that neither SIPStation, nor Rockbochs,
were ILECs in their pre-acquisition service territories.

        Sangoma U.S. is simultaneously submitting this supplemental filing with both the FCC
International Bureau and the FCC WCB, in accordance with the Commission's rules. Please do
not hesitate to contact us if you require additional information.




                    DORSEY &WHITNEY LLP WWW.DORSEY.COM • T 612.340.2600 • F 612.340.2868
                    SUITE 1500 50 SOUTH SIXTH STREET •MINNEAPOLIS, MINNESOTA 55402-1498
                                                          USA   CANADA     EUROPE     ASIA -PACIFIC


                                                                        HORSEY'"


Sangoma U.S., Inc.
January 19, 2016
Page 2


                                        Respectfully Submitted,



                                        Kristin K. Berkland, Dorsey &Whitney LLP
                                        Samir M. Islam, Dorsey &Whitney LLP
                                        Erica R. Larson, Dorsey &Whitney LLP


                                        Attorneys for Sangoma U.S., Inc.


cc:   Adrienne McNeil, FCC International Bureau Policy Division
      David Moore, CFO, Sangoma U.S., Inc.
      Philippe Lindheimer, Manager of Software Development, Sangoma U.S., Inc.
      Tony Lewis, General Manager, Sangoma U.S., Inc.
      Samantha Maqueo, Consultant, GSAssociates




                                                                           DORSEY &WHITNEY LLP


                                                                  Supplement to Attachment 3
                                                                          Sangoma U.S., Inc.
                                                                            January 19, 2016
                                                                                  Page 1 of 3

Pursuant to a request from the FCC Wireline Competition Bureau, Sangoma U.S., Inc. hereby
submits this supplement to its Request for Domestic Section 214 Transfers of Control Authority
and International and Domestic Special Temporary Authority.



                                    BEFORE THE
                        FEDERAL COMMUNICATIONS COMMISSION
                               WASHINGTON, DC 20554

In the Matter of

Sangoma U.S., Inc.
                                                            WC Docket No 16-11
Supplement to the Application for Authorization
Pursuant to Section 214 of the
Communications Act of 1934, as Amended,
For Transfer of Control


                                    SUPPLEMENT TO
                   APPLICATIO N FOR DOMESTIC TRANSFER OF CONTROL

        Sangoma U.S., Inc.("Sangoma U.S."), by its undersigned counsel, pursuant to Section
214 of the Communications Act of 1934, as amended, 47 U.S.C. § 214, Section 63.04 of the
rules of the Federal Communications Commission ("FCC" or "Commission"), 47 C.F.R. § 63.04,
and in response to a January 13, 2016 request from the FCC Wireline Competition Bureau
("WCB"), hereby submits this supplement to its Application for Authorization Pursuant to Section
214 of the Communications Act of 1934, as Amended, For Transfers of Control, as filed with the
FCC WCB on December 23, 2015.

    I. Supplemental Information Reaardinq Corporate Structure and Individuals and
       Entities that Have a Ten Percent or More Equity Ownership in Sangoma U.S.

       Sangoma Technologies Corp.("STC.V"), is a public holding company with a single 100%
owned subsidiary Sangoma Technologies Inc. ("STI"), through which all of STC.V's business is
conducted. STC.V has one 10% or more individual shareholder, Mr. David Mandelstam, a
Canadian citizen, who holds an estimated 16.3% interest in STC.V. STI holds 100% of
Sangoma U.S. Since the ownership between STC.V, STI, and Sangoma U.S. is 100% in each
case, there are certain parts of the prior filing where we noted that STC.V is the ultimate parent
of Sangoma U.S.


                                                                          Supplement to Attachment 3
                                                                                 Sangoma U.S., Inc.
                                                                                   January 19, 2016
                                                                                          Page 2 of 3

       The above explanation is depicted in the following organizational chart:'



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    II. Supplemental Information Regardinq Overlap Between the Customers, Services,
        and Territories For SIPStation, Inc.("SIPStation") and Rockbochs, Inc.
        ("Rockbochs") Prior to Acquisition.

        In Item 7 of the December 23, 2015 Application for Domestic Transfer of Control,
Sangoma U.S. described the geographic areas in which SIPStation and Rockbochs operated,
and the services they provided, prior to acquisition by Sangoma U.S. In pertinent part, that
description stated that:

        Rockbochs: Rockbochs provided nationwide fax-over-IP monthly service, and
        telecommunications equipment and software to support that service.

        SIPStation: SIPStation was established to provide nationwide integrated SIP
        trunking service.

  Note that STC.V is a Canadian publicly held company of which Mr. Mandelstam holds an estimated
16.3% equity interest, with an estimated 83.7% equity interest being publicly held. Mr. Mandelstam is the
only equity holder of STC.V with a more than 10% equity interest.


                                                    2


                                                                     Supplement to Attachment 3
                                                                            Sangoma U.S., Inc.
                                                                              January 19, 2016
                                                                                     Page 3 of 3

        Sangoma U.S. clarifies that there was no product or customer overlap between
SIPStation and Rockbochs prior to (or after) the acquisition. SIPStation provides only a SIP
trunking service, while Rockbochs provides a fax store and forward service that requires a
physical device to be sent to and activated at the customer site. Both companies had the ability
to provide their services throughout the United States, and there were some states in which
both companies had customers. However, being small, each company only had actual
customers in a limited number of states and even in the states where both companies had
customers, they provided completely different services. This situation did not change after the
acquisition of the companies by Sangoma U.S. and both companies have retained the same
pre-acquisition sales teams.

   III. Supplemental Information Reqardinq ILEC Status of Sangoma U.S., SIPStation,
        and Rockbochs.

        On January 13, 2016, the FCC WCB inquired as to whether SIPStation or Rockbochs
were ILECs in their service territories prior to their acquisition. Sangoma U.S. confirms that
neither Rockbochs, nor SIPStation, were ILECs prior to their acquisition. Moreover, none of
Rockbochs, SIPStation, nor Sangoma U.S., are ILECs post-acquisition.

       In light of the supplemental information provided in this filing, Sangoma U.S. respectfully
requests that the Commission promptly grant its Application for Domestic Transfer of Control
and corresponding Request for Special Temporary Authority.



Respectfully submitted,

                          .-___------            ~r~
l~—~
Kristin K. Berkland, Dorsey &Whitney LLP
Samir M. Islam, Dorsey &Whitney LLP
Erica. R. Larson, Dorsey &Whitney LLP

Suite 1500, 50 South Sixth Street
Minneapolis, MN 55402-1498
612-492-6194

Attorneys for Sangoma U.S., Inc.



Dated: January 19, 2016



Document Created: 2016-01-19 10:19:51
Document Modified: 2016-01-19 10:19:51

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