Attachment Attachment 1

This document pretains to ITC-ASG-20110408-00089 for Assignment on a International Telecommunications filing.

IBFS_ITCASG2011040800089_880824

Pro Forma Assignment of International Section 214 Authorization
FCC File No. ITC-214-20051122-00478


                                                ATTACHMENT 1


Answer to Question 10:

       Section 63.18(c). For both the assignor and assignee, the Commission should address
correspondence regarding this application to:

                                     Edwin Janaslani
                                     President
                                     SUPER PREPAID INC.
                                     210 N. Glenoaks Boulevard
                                     Suite B
                                     Burbank, CA 91502
                                     +1 818-618-3763 tel
                                     +1 818-558-1292 fax
                                     edwin@janaslani.com

                                     with a copy to:

                                     John T. Nakahata
                                     WILTSHIRE & GRANNIS LLP
                                     1200 Eighteenth Street NW
                                     Suite 1200
                                     Washington, DC 20036
                                     +1 202-730-1320 tel
                                     +1 202-730-1301 fax
                                     jnakahata@wiltshiregrannis.com

                                     Counsel for Super Prepaid Inc. and Janaslani Enterprises, LLC

        Section 63.18(d). The Commission previously has authorized Janaslani Enterprises, LLC
(“Janaslani”) to provide global resale telecommunications services in the authorization that is the
subject of this pro forma assignment notification. See FCC File No. ITC-214-20051122-00478.

Answer to Question 13:

       On January 1, 2011, 1 Janaslani consummated a pro forma assignment of its International
Section 214 Authorization to provide global resale services (FCC File No. ITC-214-20051122-
00478), and related common carrier operations, to Super Prepaid Inc. Super Prepaid Inc. intends

1
   As appropriate, Janaslani requests a waiver of the Commission’s requirement that an International 214
authorization holder notify the FCC of a pro forma assignment of authorization within 30 days after the assignment
is completed. 47 C.F.R. § 63.24(f)(2).Janaslani’s failure to file this notification within the specified timeframe was
inadvertent. Janaslani apologizes for any inconvenience resulting from its failure to file this notification in a timely
manner.


Pro Forma Assignment of International Section 214 Authorization
FCC File No. ITC-214-20051122-00478

to continue providing international telecommunications services for the operations transferred
from Janaslani for global or limited global resale service.

        This is a pro forma assignment because, prior to January 1, 2011, Janaslani and Super
Prepaid were independently incorporated entities under 100% common ownership and control.
As of January 1, 2011, Janaslani merged into Super Prepaid. Thus, the assignment of the
international 214 authorization and common carrier operations is “an assignment from a
corporation to a corporation owned or controlled by the assignor stockholders without substantial
change in their interests.” 47 C.F.R. § 63.24(d), Note 2. Therefore, Super Prepaid certifies in
the attachment to this letter that the assignment is pro forma as defined by Section 63.24(a) of the
Commission’s rules and has not resulted in a change of the authorization’s ultimate control.
Janaslani retained ultimate control of the international Section 214 authorization both before and
after the consummation of the assignment.



Document Created: 2011-04-08 00:06:31
Document Modified: 2011-04-08 00:06:31

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