Attachment Attachment 1

This document pretains to ITC-214-20160115-00024 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142016011500024_1120550

Sully Telephone Association Inc.                                                  ATTACHMENT 1
International 214 Application                                                          Page 1 of 1



RESPONSE TO QUESTION 9

Section 63.18(p)     Applicant requests and qualifies for streamlined processing pursuant to
                     Sections 63.12(a) & (b) because the Applicant is not affiliated with a
                     foreign carrier or a dominant U.S. carrier.

RESPONSE TO QUESTIONS 11 AND 12

Section 63.18(i)     Applicant certifies that it is not affiliated with a foreign carrier.

Section 63.18(j)     Applicant certifies that it does not seek to provide international
                     telecommunications services to any destination country for which any of
                     the following is true: (1) Applicant is a foreign carrier in that country; (2)
                     Applicant controls a foreign carrier in that country; (3) any entity that
                     owns more than 25 percent of the Applicant, or that controls the
                     Applicant, controls a foreign carrier in that country; or (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.



Document Created: 2016-01-05 10:52:34
Document Modified: 2016-01-05 10:52:34

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