Attachment Attachment 1

This document pretains to ITC-ASG-20190129-00045 for Assignment on a International Telecommunications filing.

IBFS_ITCASG2019012900045_1613910

       Attachment 1 to Notice of Pro Forma Assignment of International Section 214
            Authorization from BT LatAm Inc. to BT Americas Holdings Inc.


Answer to Question 10

Response to 47 C.F.R. § 63.18(c):

(c) The name, title, post office address, and telephone number of the officer and any other
contact point, such as legal counsel, to whom correspondence concerning the application is to be
addressed:

For Assignor and Assignee:

       A. Sheba Chacko
       Chief Regulatory Counsel
       BT Americas Holdings Inc.
       11440 Commerce Park Drive, Suite 100
       Reston, VA 20191
       Telephone: 703-755-6730
       Email: sheba.chacko@bt.com

With a copy to:

       Ruth E. Holder
       Regulatory Affairs & Compliance Manager
       BT Americas Holdings Inc.
       11440 Commerce Park Drive, Suite 100
       Reston, VA 20191
       Telephone: 703-755-6730
       Email: ruth.holder@bt.com

Response to 47 C.F.R. § 63.18(d):

(d) A statement as to whether the applicant has previously received authority under Section 214
of the Act and, if so, a general description of the categories of facilities and services authorized
(i.e., authorized to provide international switched services on a facilities basis):

       Assignee: BT Americas Holdings Inc. (“Assignee”) has not previously received Section
       214 authority from the Federal Communications Commission, although several of its
       subsidiaries have held such authority. BT Americas Holdings Inc. is a Delaware
       corporation and the ultimate U.S. holding company for all BT entities in the United
       States. Assignor is indirectly and wholly owned by Assignee.




                                                  1


        Assignor: BT LatAm Inc., formerly named Comsat International, Inc.1 (“Assignor”), has
        previously received authority under 47 U.S.C. § 214 for Global or Limited Global
        Facilities-based and Resale Service authority. That authorization is the subject of this
        notice of pro forma assignment to BT Americas Holdings Inc., and is identified by the
        FCC IBFS File No. ITC-214-20020306-00105.

Answer to Question 11

The following entities directly or indirectly own ten percent or more of the equity of Assignee
BT Americas Holdings Inc.:

        BT Fifty-One, a company organized under the laws of England and Wales, with a
        registered office address at 81 Newgate Street, London, EC1A 7AJ, whose principal
        business is Finance, directly holds 100 percent of BT Americas Holdings Inc.

        BT (International) Holdings Limited, a company organized under the laws of England
        and Wales, with a registered office address at 81 Newgate Street, London, EC1A 7AJ,
        whose principal business is Holding Company, directly holds 76 percent of BT Fifty-
        One, and therefore indirectly holds 76 percent of BT Americas Holdings Inc.

        BT Holdings Limited, a company organized under the laws of England and Wales, with a
        registered office address at 81 Newgate Street, London, EC1A 7AJ, whose principal
        business is Holding Company, directly holds 24 percent of BT Fifty-One, and directly
        holds 100 percent of BT (International) Holdings Limited, and therefore indirectly holds
        100 percent of BT Americas Holdings Inc.

        British Telecommunications plc, a company organized under the laws of England and
        Wales, with a registered office address at 81 Newgate Street, London, EC1A 7AJ, whose
        principal business is Communications, directly holds 100 percent of BT Holdings
        Limited, and therefore indirectly holds 100 percent of BT Americas Holdings Inc.

        BT Group Investments Limited, a company organized under the laws of England and
        Wales, with a registered office address at 81 Newgate Street, London, EC1A 7AJ, whose
        principal business is Holding Company, directly holds 100 percent of British
        Telecommunications plc, and therefore indirectly holds 100 percent of BT Americas
        Holdings Inc.

1
  See FCC IBFS File No. ITC-T/C-20070425-00162 and Public Notice DA 07-2263 for approval of the
transfer of control of Comsat International, Inc. to BT. Following the consummation of that transaction in
2008, Comsat International, Inc. changed its name to BT LatAm Inc. Although notice of the name
change was made in other contexts (such as the FCC’s CORES and Form 499 Filer Databases) and is
presumed to have been timely filed with the International Bureau, given intervening staff changes, a date-
stamped copy has not been located. If necessary, Applicants respectfully request a waiver of 47 C.F.R.
§ 63.21(i) to provide for late notice of the name change. See 47 C.F.R. § 1.3; see also Numbering
Resource Optimization, Order, 18 FCC Rcd 16860, ¶ 9 (2003) (“The Commission may exercise its
discretion to waive a rule where the particular facts make strict compliance inconsistent with the public
interest.”).
                                                    2


       BT Group plc, a company organized under the laws of England and Wales, with a
       registered office address at 81 Newgate Street, London, EC1A 7AJ, whose principal
       business is Communications, directly holds 100 percent of BT Group Investments
       Limited, and therefore indirectly holds 100 percent of BT Americas Holdings Inc.

       Deutsche Telekom AG, a company organized under the laws of Germany, with an
       address at Friedrich-Ebert-Allee 140, 53113 Bonn, whose principal business is
       Communications, directly holds 12.05 percent of BT Group plc, and therefore indirectly
       holds 12.05 percent of BT Americas Holdings Inc.

There are no other individuals or entities that hold ten percent or more of the equity in BT
Americas Holdings Inc.

Answer to Question 12

Assignee has interlocking directorates with foreign carriers as listed on Exhibit A hereto.

Answer to Question 13

Assignor, a wholly owned subsidiary of Assignee, assigned its international section 214
authorization to Assignee effective December 31, 2018, as part of a corporate reorganization
designed to streamline the holdings of various BT entities in the United States. Assignee, as the
top level United States holding company, serves as an umbrella organization under which
various BT United States companies operate, and certain other BT entities also assigned their
international section 214 authorizations to Assignee as of December 31, 2018.2 Assignor does
not desire to retain its authorization.

This assignment is pro forma in nature as ultimate control and ownership of the authorization at
issue did not change. With this pro forma assignment, the following BT entities, wholly owned
by Assignee, are operating under the international section 214 authorizations held by their
parent, Assignee BT Americas Holdings Inc., pursuant to 47 C.F.R. § 63.21(h), as necessary:

               BT Americas Inc.
               BT Conferencing Video Inc.
               BT Communications Sales LLC
               BT Federal Inc.
               BT LatAm Inc.
               BT Procure LLC
               Infonet Services Corporation
               Radianz Americas Inc.




2
  See Notices of Pro Forma Assignment filed concurrently herewith by BT Fifty-Three Limited and
Infonet Services Corporation.
                                                 3


                                 Exhibit A to Attachment 1
                  Directors and Officers of BT Americas Holdings Inc. and
                      Interlocking Directorates with Foreign Carriers


The following individuals are officers and/or directors of Assignee BT Americas Holdings Inc.:

               Jennifer Artley, Director, President and Chair
               Tammie Briscoe, Director
               Andrew McGroarty, Director and CFO
               Richard E. Nohe, Director and Chief Legal Officer
               Jamie Paul Newell, Secretary
               Stephane Patrice Jean Calvary, Treasurer
               Lynn Morzorati Metz, Vice President of Tax
               Andrew Schmitt, Tax Officer

Richard Nohe is also Chief Legal Officer of BT Canada Inc.

Andrew Schmitt is also Tax Officer of BT Canada Inc.

Andrew McGroarty is also a director and/or officer of the following foreign carriers:

 Name of Company                         Country           Position Held
 BT Canada Inc.                          Canada            Director and Chief Financial Officer
 BT LatAm México, S.A. de C.V.           Mexico            Director

Jamie Paul Newell is also a director and/or officer of the following foreign carriers:

 Name of Company                         Country           Position Held
 BT Argentina S.R.L.                     Argentina         Director
 BT Bulgaria EOOD                        Bulgaria          Director
 BT Canada Inc.                          Canada            Secretary
 BT Colombia Limitada                    Colombia          Alternate Director
 BT de Panama, S.R.L.                    Panama            Director
 BT Dominican Republic, S.A.             Dominican         Director and Chairman
                                         Republic
 BT El Salvador, Limitada de Capital     El Salvador       Director
 Variable
 BT Global Costa Rica SRL                Costa Rica        Director
 BT Guatemala S.A.                       Guatemala         Director and Secretary
 BT LatAm Argentina S.A.                 Argentina         Alternate Director
 BT LatAm Colombia S.A.                  Colombia          Alternate Director
 BT LatAm Costa Rica, S.A.               Costa Rica        Director
 BT LatAm Dominicana, S.A.               Dominican         Director and Secretary
                                         Republic
 BT LatAm El Salvador, S.A. de CV        El Salvador       Director and Assistant Vice President

                                                A-1


 BT LatAm Guatemala, S.A.                Guatemala         Director and Secretary
 BT LatAm Honduras, S.A.                 Honduras          Alternate Director
 BT LatAm Nicaragua, S.A.                Nicaragua         Director and Secretary
 BT LatAm Panama, Inc.                   Panama            Director
 BT LatAm Peru S.A.C.                    Peru              Director and Secretary
 BT Nicaragua S.A.                       Nicaragua         Director and Secretary
 BT Peru S.R.L.                          Peru              Director and Secretary
 BT Sociedad De Responsabilidad          Honduras          Director
 Limitada
 Servicios de Telecomunicaciones         Chile             Director
 BT Global Networks Chile Limitada

Stephane Patrice Jean Calvary is also a director and/or officer of the following foreign carriers:

 Name of Company                         Country           Position Held
 BT Canada Inc.                          Canada            Treasurer
 BT de Panama, S.R.L.                    Panama            Director
 BT Dominican Republic, S.A.             Dominican         Director and Secretary
                                         Republic
 BT El Salvador, Limitada de Capital     El Salvador       Director
 Variable
 BT Global Costa Rica SRL                Costa Rica        Director
 BT Guatemala S.A.                       Guatemala         Director
 BT LatAm Costa Rica, S.A.               Costa Rica        Director
 BT LatAm Dominicana, S.A.               Dominican         Director
                                         Republic
 BT LatAm Guatemala, S.A.                Guatemala         Director
 BT LatAm Honduras, S.A.                 Honduras          Director and Vice President
 BT LatAm México, S.A. de C.V.           Mexico            Director
 BT LatAm Nicaragua, S.A.                Nicaragua         Director and Vice President
 BT LatAm Panama, Inc.                   Panama            Director
 BT Nicaragua S.A.                       Nicaragua         Director and Vice President
 BT Sociedad De Responsabilidad          Honduras          Director
 Limitada

Lynn Morzorati Metz is also a director and/or officer of the following foreign carriers:

 Name of Company                          Country           Position Held
 BT Canada Inc.                           Canada            Vice President of Tax
 BT Colombia Limitada                     Colombia          Alternate Director
 BT LatAm El Salvador, S.A. de C.V.       El Salvador       Director and Assistant Treasurer




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Document Created: 2019-01-29 16:15:38
Document Modified: 2019-01-29 16:15:38

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