Attachment Attachment 2

This document pretains to ITC-214-20160630-00180 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142016063000180_1141566

                                                                                 Primus of Puerto Rico LLC

                                                           Application for Authority to Provide International
                                             Facilities-Based and Resold Services to All International Points

                                       ATTACHMENT 2

Response to Question 14

       Primus of Puerto Rico LLC (the “Applicant”) provides the name, address, citizenship,
and principal business of the entities holding a ten percent (10%) or greater direct or indirect
ownership interest in Applicant:

        The Applicant is a wholly owned subsidiary of Primus Holdings, Inc. (“Primus
Holdings”). Primus Holdings is a Georgia corporation whose principal business is as a holding
company, with offices located at 320 Interstate North Parkway SE, Atlanta, GA 30339. Primus
Holdings is a wholly owned subsidiary of Birch Communications, Inc. (“Birch”). Birch is a
Georgia corporation whose principal business is telecommunications, with offices located at 320
Interstate North Parkway SE, Atlanta, GA 30339. Birch is a wholly owned subsidiary of Birch
Communications Holdings, Inc. (“Birch Holdings”). Birch Holdings is a Georgia corporation
whose principal business is as a holding company, with offices located at 320 Interstate North
Parkway SE, Atlanta, GA 30339.

       Ownership of Birch Holdings is as follows:

                 Holcombe Green, a U.S. citizen, owns approximately 62% voting and equity
interest in Birch Holdings. The business address for Holcombe Green is 320 Interstate North
Parkway SE, Atlanta, GA 30339.

                 R. Kirby Godsey, a U.S. citizen, owns approximately 23% voting and equity
interest in Birch Holdings. The business address for R. Kirby Godsey 320 Interstate North
Parkway SE, Atlanta, GA 30339.

       Other than as set forth in this Application, no other entity or individual owns a ten
percent (10%) or greater direct or indirect equity or voting interest in the Applicant, Primus
Holdings, Birch, or Birch Holdings.

Response to Question 15

     Applicant has not previously received international Section 214 authority from the
Commission.

        Applicant is not seeking authority to provide any service not referenced under paragraphs
(e)(1) and (e)(2) of 47 C.F.R. § 63.18.

       Applicant does not seek to acquire facilities under Section 63.18(g); therefore, Section
1.306 of the Commission’s rules regarding environmental assessments is inapplicable.


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Document Created: 2016-06-30 16:11:09
Document Modified: 2016-06-30 16:11:09

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