Attachment 20170720092434-410.p

20170720092434-410.p

SUPPLEMENT

Supplement

2009-01-30

This document pretains to ITC-ASG-20090130-00047 for Assignment on a International Telecommunications filing.

IBFS_ITCASG2009013000047_1589350

                                                    Pro Forma

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From:              JohnAdams
To:                DavidKrech;
CC:                Sumita Mukhoty; JoAnn Sutton;
                   JaneeseParker;_
Subject:           RE: Consolidated Communications 214
Date:              Friday, March 13, 2009 12:58:29 PM
Attachments:       Consol rule 63—21h Ltr.pdf


Based upon discussions with Sumita Mukhoty, I am providing some additional
information.

Consolidated understands that the Commission considers this transaction to be a
pro forma assignment rather than a pro forma transfer of control. Consolidated
therefore clarifies that this transaction involves three elements: (1) the
assignment of the 214 authority held by CCOS from CCOS to CCI by virtue of the
merger of CCOS with and into CCI, its parent, with CCI being the surviving company
and CCOS ceasing to exist; (2) transfer of the assets of CCOSfrom CCI to CCES (f/k/
a CCNS), a wholly—owned subsidiary of CCI; and (3) assignment of the 214 authority
from CCI to CCHI, its parent and the ultimate holding company controlling all
parties to these transactions. The 214 operating authority that is being assigned
is ITC—214—20030808—00393; global or limited global facilities—based service, global
or limited global resale; granted September 5, 2003.

Also, please find attached a scanned copy of a letter regarding the provision of
services by CCES pursuant to 47 CFR 63.21(h). Theletter is being mailed for filing
today.

Thanks,


John B. Adams
The Adams Legal Firm, LLC
626C Admiral Drive #312
Annapolis, MD 21401
tel 202—448—9033
fax 202—448—9040
From: David Krech [mailto:David.Krech@fce.gov]
Sent: Thursday, March 12, 2009 9:22 AM
To: John Adams
Co: Sumita Mukhoty
Subject: RE: Consolidated Communications 214

This email will be fine.


The notification will be on the next Actions Taken Public Notice, March 26.



From: John Adams [mailto:jbadams@adamslegalfirm.com]
Sent: Thursday, March 12, 2009 9:16 AM
To: David Krech
Ce: Sumita Mukhoty
Subject: RE: Consolidated Communications 214

David,

(a) is correct. It looks likethe filing contains a typo. Do you want an amendment,
or is this correction by email sufficient?

Thanks,


John B. Adams
The Adams Legal Firm, LLC
626C Admiral Drive #312
Annapolis, MD 21401
tel 202—448—9033
fax 202—448—9040
From: David Krech [mailto: David.Krech@fcc.gov]
Sent: Wednesday, March 11, 2009 3:34 PM
To: John Adams
Ce: Sumita Mukhoty
Subject: RE: Consolidated Communications 214

John,


Please clarify.

Was (a) CCOS merged into CCI, as stated in the email below, or (b) was CCHI
merged into CCI, as stated in the application. (The application identifies CCHI as
the transferee and states that the transferee was merged into CCI.)

Thanks.


David




From: John Adams <jbadams@adamslegalfirm.com>


To: Sumita Mukhoty
Sent: Mon Mar 09 16:13:30 2009
Subject: Consolidated Communications 214
Sumita,


Following up on our telephone conversation today, I am providing additional
information regarding the relationship between the transferee and transferor.

As we discussed, this pro forma transactionis part of a larger internal
reorganization that affected several subsidiary companies. A number of
companies were merged and/or assets were transferred in order to rationalize the
internal corporate structure and to reduce the overall number of subsidiaries.

Per your request, | am providing the attached organizational chart to show the
relationship between the transferor and transferee. For the sake of clarity, It
includes only those companies that are affected by the 214 transfer at issue.

As shown on the chart,ConsolidatedCommunicationsHoldingCompany,Inc._
("CCHI") is the parent companyat the very top of the organizational chart. It has a
number of wholly—owned subsidiaries, including Consolidated Communications,
Inc. ("CCI"). CCl, in turn, has a number of wholly—owned subsidiaries, including
Consolidated Commmunications Operator Services ("CCOS") and Consolidated
Communications Network Services ("CCNS").

As was described in response to question 13 of the 214 filing, the following events
occurred effective January 1, 2009: CCOS was merged with and into CCI, with CCI
being the surviving entity. CCl then transferred the assets of CCOSto CCNS. CCNS
immediately changed its name to Consolidated Communications Enterprise
Services ("CCES"). CCES f/k/a CCNS began providing the services that previously
were provided by CCOS. For your convenience, an electronic copy of the 214 filing
also is attached.

The reorganization resulted in no change of ultimate control: both before and
after the reorganization, the subject 214 authorization was and is under the
ultimate control of CCHI. Further, the 214 authorization is to be vested in CCHI.

Please let me know if you have any further questions or need additional
information.


Thanks,


John B. Adams
The Adams Legal Firm, LLC
626C Admiral Drive #312
Annapolis, MD 21401
tel 202—448—9033
fax 202—448—9040


                                                                           Pryo Forma           ITC—ASC—20090130—00047

                                                                           Consefidated Communications Holdings, Inc.
   JoAnn Sutton

   From:           John Adams [jJbadams @adamslegalfirm.com]
   Sent:           Thursday, March 26, 2009 2:11 PM
   To:             JoAnn Sutton
   Subject:        FW: Consolidated Cormmunications 214
   Attachments: Consol rule 63—21h Ltr.pdf; Consol rule 63—21h Ltr confirm.pdf

 JoAnn:

 Following up on our conversation, I have uploaded the March 13, 2009 letter to MyIBFS. A copy of the letter
 and the filing confirmation are attached.

 Also, per your request for clarification, the name of the ultimate parent company involved in this transaction is
_.ConsolidatedCommunicationsHoldings,There have been some name changes associated with acquisitions
 and prior restructurings, but this is the correct current name. | have verified that this name is reflected in
 CORES.

 Please let me know if you need anything further.

 Thanks,

 John B. Adams
 The Adams Legal Firm, LLC
 626C Admiral Drive #312
 Annapolis, MD 21401
 tel 202—448—9033
 fax202—448—9040
 From: David Krech [mailto:David.Krech@fcc.gov]
 Sent: Wednesday, March 25, 2009 3:35 PM
 To: John Adams; JoAnn Sutton
 Co: Janeese Parker
 Subject: RE: Consolidated Communications 214

 Thank you.

 Unfortunately, we have already processedthe PN. We will be able to grant the notification tomorrow when JoAnn
 is back, and it will appear on the next PN.

 David


 From: John Adams [mailto:jJbadams@adamslegalfirm.com]
 Sent: Wednesday, March 25, 2009 3:23 PM
 To: JoAnn Sutton
 Ce: Janeese Parker; David Krech
 Subject: RE: Consolidated Communications 214

 The FRN for Consolidated Communications, Inc. is 0018633321.

 Thanks,




  3/26/2009


                                                                                                        Page 2 of 5


John B. Adams
The Adams Legal Firm, LLC
626C Admiral Drive #312
Annapolis, MD 21401
tel 202—448—9033
fax 202—448—9040
From: John Adams [mailto:Jjbadams@adamslegalfirm.com]
Sent: Wednesday, March 25, 2009 12:05 PM
To: ‘JoAnn Sutton‘
Co: ‘Janeese Parker‘; ‘David Krech‘
Subject: RE: Consolidated Communications 214

JoAnn,

l am working on it. Unfortunately, some folks were let go as part of the restructuring that necessitated this 214
filing, inlcuidng the regulatory person who was the keeper of FRNs. It therefore is taking a little while to confirm
the FRN. I‘ll get it to you as soon as possible.

Thanks,

John B. Adams
The Adams Legal Firm, LLC
626C Admiral Drive #312
Annapolis, MD 21401
tel 202—448—9033
fax 202—448—9040
From: JoAnn Sutton [mailto:JoAnn.Sutton@fce.gov]
Sent: Tuesday, March 24, 2009 6:11 PM
To: John Adams
Co: Janeese Parker; David Krech
Subject: RE: Consolidated Communications 214

John,

To follow—up my phone message I left you earlier this afternoon, we‘d like to include Consolidated
Communications‘ pro forma ASG application on Thursday‘s PN, but we need an FRN for Consolidated
Communications, Inc. in order to do so. If you can provide Janeese Parker with the FRN before noon tomorrow
(Wednesday, 3/25), we will include it on the PN.

Also, if you have a copy of the attached letter with the Secretary‘s stamp, could you forward it to us so we can act
on it. We will upload it into IBFS so it‘ll be available to the public.

I‘ll be out of the office tomorrow, so please contact David Krech at (202) 418—7443 if you have any questions.

Thanks!

JoAnn




From: John Adams [mailto:jbadams@adamslegalfirm.com]
Sent: Friday, March 13, 2009 12:58 PM
To: David Krech
Ce: Sumita Mukhoty; JoAnn Sutton; Janeese Parker
Subject: RE: Consolidated Communications 214




3/26/2009


                                                                                                        Page 3 of 5


Based upon discussions with Sumita Mukhoty, I am providing some additional information.

Consolidated understandsthat the Commission considers this transaction to be a pro forma assignment rather
than a pro forma transfer of control. Consolidated therefore clarifies that this transaction involves three
elements: (1) the assignment of the 214 authority held by CCOS from CCOS to CCI by virtue of the merger of
CCOS with and into CCI, its parent, with CCI being the surviving company and CCOS ceasing to exist; (2) transfer
of the assets of CCOS from CCI to CCES (f/k/a CCNS), a wholly—owned subsidiary of CCI; and (3) assignment of the
214 a uthority from CCI to CCHI, its parent and the ultimate holding cormpany controlling all parties to these
transactions.   The 214 operating authority that is being assignedis ITC—214—20030808—00393; global or limited
global facilities—based service, global or limited global resale; granted Septermber 5, 2003.

Also, please find attached a scanned copy of a letter regarding the provision of services by CCES pursuant to 47
CFR 63.21(h). The letter is being mailed for filing today.

Thanks,

John B. Adams
The Adams Legal Firm, LLC
626C Admiral Drive #312
Annapolis, MD 21401
tel 202—448—9033
fax 202—448—9040
From: David Krech [mailto: David.Krech@fcc.gov]
Sent: Thursday, March 12, 2009 9:22 AM
To: John Adams
Ce: Sumita Mukhoty
Subject: RE: Consolidated Communications 214

This email will be fine.

The notification will be on the next Actions Taken Public Notice, March 26.



From: John Adams [mailto:jbadams@adamslegalfirm.com]
Sent: Thursday, March 12, 2009 9:16 AM
To: David Krech
Ce: Sumita Mukhoty
Subject: RE: Consolidated Communications 214

David,

(a) is correct. It looks like the filing contains a typo. Do you want an amendment, or is this correction by email
sufficient?

Thanks,

John B. Adams
The Adams Legal Firm, LLC
626C Admiral Drive #312
Annapolis, MD 21401
tel 202—448—9033
fax 202—448—9040
From: David Krech [mailto: David.Krech@fcc.gov]
Sent: Wednesday, March 11, 2009 3:34 PM



3/26/2009


                                                                                                        Page 4 of 5


To: John Adams
Ce: Surnita Mukhoty
Subject: RE: Consolidated Cormmunications 214

John,

Please clarify.

Was (a) CCOS merged into CCI, as stated in the email below, or(b) was CCHI merged into CCI, as stated in the
application. (The application identifies CCHI as the transferee and states that the transferee was merged into
CCI.)

Thanks.

David




From: John Adams <jbadams@adamslegalfirm.com>
To: Sumita Mukhoty
Sent: Mon Mar 09 16:13:30 2009
Subject: Consolidated Communications 214
Sumita,

Following up on our telephone conversation today, | am providing additional information regarding the
relationship between the transferee and transferor.

As we discussed, this pro forma transaction is part of a larger internal reorganization that affected several
subsidiary companies. A number of companies were merged and/or assets were transferred in order to
rationalize the internal corporate structure and to reduce the overall number of subsidiaries.

Per your request, | am providing the attached organizational chart to show the relationship between the
transferor and transferee. For the sake of clarity, It includes only those companies that are affected by the 214
transfer at issue.

As shown on the chart, Consolidated Communications Holding Company, Inc. ("CCHI") is the parent company at
the very top of the organizational chart. It has a number of wholly—owned subsidiaries, including Consolidated
Communications, Inc. ("CCI"). CCl, in turn, has a number of wholly—owned subsidiaries, including Consolidated
Communications Operator Services ("CCOS") and Consolidated Communications Network Services ("CCNS").

As was described in response to question 13 of the 214 filing, the following events occurred effective January 1,
2009: CCOS was merged with and into CCl, with CCI being the surviving entity. CCl then transferred the assets
of CCOS to CCNS. CCNS immediately changed its name to Consolidated Communications Enterprise Services
("CCES"). CCES f/k/a CCNS began providing the services that previously were provided by CCOS. For your
convenience, an electronic copy of the 214 filing also is attached.

The reorganization resulted in no change of ultimate control: both before and after the reorganization, the
subject 214 authorization was and is under the ultimate control of CCHI. Further, the 214 authorization is to be
vested in CCHI.

Please let me know if you have any further questions or need additional information.




3/26/2009



Document Created: 2019-06-03 13:47:48
Document Modified: 2019-06-03 13:47:48

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