Attachment SORACOM 214 Attch 1

This document pretains to ITC-214-20190130-00067 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142019013000067_1614527

                                         Soracom Global, Inc.
                                 Application for Section 214 Authority
                                             Attachment 1



Question 9

The Applicant qualifies for streamlined processing under 47 CFR § 63.12. Rule 63.12(c)(1) provides
that the streamlining procedures shall apply where the applicant is affiliated with a foreign carrier in
a destination market that is a WTO member country and the applicant agrees to be classified as a
dominant carrier to the affiliated destination country under Section 63.10 of the Commission’s rules.

As detailed in Attachment 1, Soracom Global, Inc., is a direct wholly owned subsidiary of Soracom,
Inc. Soracom International, PTE, Ltd., a Singapore private limited company, is a wholly owned
subsidiary of Soracom, Inc.

KDDI Corporation owns more than 50% of the stock of the Applicant’s direct parent. KDDI
Corporation owns and operates a portfolio of telecommunications companies throughout the world.
By virtue of KDDI Corporation’s indirect ownership of the Applicant and KDDI Corporation’s greater
than 25% ownership in the following foreign carriers, the Applicant is affiliated with foreign carriers
as follows:

        KDDI Korea Corporation, Korea
        KDDI Europe Ltd., United Kingdom
        KDDI Deutschland GmbH, Germany
        KDDI France SAS, France
        KDDI Singapore Pte Ltd, Singapore
        KDDI Summit Global Myanmar Co., Ltd., Myanmar
        KDDI Hong Kong, Ltd., Hong Kong
        KDDI Australia Pty Ltd, Australia
        Mobicom Corporation, Mongolia
        KDDI Thailand, Thailand
        KDDI Malaysia, Malaysia
        KDDI Indonesia, Indonesia
        KDD Philippines, Philippines
        KDD Vietnam, Vietnam
        KDDI India, India
        KDDI Corporation, Japan
        UBIK do Brasil Solucoes em Tecnologia Ltda
        KDDI Rus limited liability company
        KDDI TAIWAN Corporation

Question 11

For purposes of this application, Applicants submit that, with the exception of KDDI Corporation,
Japan (a WTO member country), the Applicant qualifies for a presumption of non-dominance for
each of the routes where it holds foreign carrier affiliations under Section 63.10(a)(3) of the
Commission Rules, 47 C.F.R. § 63.10(a)(3), as each of these carriers lacks a 50% market share in
the international transport and local access markets on the foreign end of that route. Applicant
agrees to be classified as a dominant carrier on the U.S.-Japan route under Sections 63.10(c)-(e) of


the Commission’s Rules, 47 C.F.R. §§ 63.10(c)-(e) without prejudice to its right to petition for
reclassification at a later date.

Question 12

The applicant seeks authority to provide service to the countries identified in response to Questions
9 and 11, above.



Document Created: 2019-01-30 14:05:14
Document Modified: 2019-01-30 14:05:14

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