Next Angel Supplemen

SUPPLEMENT submitted by Next Angel LLC

Next Angel Supplement

2013-02-05

This document pretains to ITC-ASG-20130130-00037 for Assignment on a International Telecommunications filing.

IBFS_ITCASG2013013000037_984723

Jennif er Hin din 1776 K STREET NW February 5, 2013 202.719.4975 WASHINGTON, DC 20006 jhindin@wile yre in.c om PHONE 202.719.7000 FAX 202.719.7049 7925 JONES BRANCH DRIVE VIA IBFS McLEAN, VA 22102 PHONE 703.905.2800 Ms. Marlene H. Dortch, Secretary FAX 703.905.2820 Federal Communications Commission 445 12th Street, S.W. www.wileyr ein .com Washington, D.C. 20554 Re: Applications for Assignment of Domestic and International Section 214 Authorizations and Requests for Special Temporary Authority, File Nos. ITC-ASG-20130130-00035, ITC-ASG-20130130-00037, ITC-STA- 20130130-00036, and ITC-STA-20130130-00038 Dear Ms. Dortch: Next Angel LLC (“Next Angel”), by counsel, files this letter pursuant to Section 1.65 of the Federal Communications Commission’s (“FCC” or “Commission”) rules1 to provide updated information for the above-referenced pending applications for assignment of domestic and international Section 214 authority from STi Prepaid, LLC (“STi Prepaid”) and STi Telecom Inc. (“STi Telecom”) to Next Angel and for Special Temporary Authority (“STA”) to continue providing service to the customers of STi Prepaid and STi Telecom pending approval of the assignment application. In the pending assignment applications, Next Angel acknowledges that STi Prepaid and STi Telecom are delinquent in certain debts owed to the Commission and seeks waiver of Section 1.1910 of the Commission’s rules2 to allow the FCC to process the applications. Next Angel supplements this waiver request to seek immediate grant of its applications for special temporary authority pursuant to Section 1.1910(c) of the Commission’s rules, which states that “[a]pplications for emergency or special temporary authority . . . involving a brief transition period facilitating continuity of service to a substantial number of customers or end users, will not be subject to the provisions of . . . this section.”3 Currently, approximately 20 million calling cards sold by STi Prepaid and STi Telecom remain in the hands of customers who expect the continued ability to place domestic and international 1 47 C.F.R. § 1.65. 2 47 C.F.R. § 1.1910. 3 47 C.F.R. § 1.1910(c).

Ms. Marlene H. Dortch, Secretary February 5, 2013 Page 2 calls using these cards. Although, Next Angel anticipates that the number of cards outstanding is declining as existing card are depleted, there can be no doubt that millions of customers—a “substantial” number—risk disruption of service if the special temporary authorizations are not processed and granted quickly. Because these cards are sold nationwide and, in fact, continue to be sold by STi Prepaid and STi Telecom, there is no means of contacting customers or providing refunds if these cards become non-operational. STi Prepaid and STi Telecom have informed Next Angel that due to financial realities, service to customers may be discontinued by the end of this week and no later than Friday February 15, 2013. Grant of Next Angel’s request for waiver of the redlight rule and for special temporary authority will facilitate continuity of service to these customers. Next Angel is committed to providing quality service to these existing customers. As part of the Asset Purchase Agreement, Next Angel agreed to assume all of the liabilities of providing continued service to existing customers. As explained in the pending applications, Next Angel was recently formed by three experienced telecommunications companies that have the technical and financial expertise necessary to provide quality and even improved service to customers. Next Angel is aware of the 20 million calling cards outstanding and has all of the operational systems and capabilities necessary to provide uninterrupted service to these customers. Next Angel will provide notification to customers of the change in service provider through a recording that includes a telephone number that can be used to directly contact a Next Angel customer service representative. Next Angel is aware of STi Prepaid and STi Telecom’s issues with regulatory compliance and is committed to ensuring that these issues do not continue under the management of Next Angel. Next Angel will retain 80 percent of the staff of STi Prepaid and STi Telecom to ensure there is a seamless transition for customers, but new management under Next Angel is committed to compliance with all regulatory requirements. Next Angel employs Matthew Shulman as in house regulatory counsel and has also engaged outside counsel to make staff aware of all regulatory requirements, including all regulatory fee obligations.

Ms. Marlene H. Dortch, Secretary February 5, 2013 Page 3 If you have any questions, please do not hesitate to contact the undersigned. Sincerely, /s/ Jennifer Hindin Jennifer Hindin cc: David Krech, Jodie May Tracey Wilson Myrva Charles Sally Stone


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Document Modified: 2019-04-14 00:09:31
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