Honotua 214 Partial

NOTICE submitted by ONATI SAS

Pro Forma Notice

2019-04-03

This document pretains to ITC-ASG-20190328-00098 for Assignment on a International Telecommunications filing.

IBFS_ITCASG2019032800098_1643626

March 28, 2019


BY ELECTRONIC FILING

Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

       Re:     Partial Pro Forma Assignment of International Section 214 Authorization for the
               Honotua Submarine Cable System, FCC File Nos. ITC-214-20081008-00453 and
               ITC-MOD-20180410-00068

Dear Ms. Dortch:

        Pursuant to 47 U.S.C. § 214 and 47 C.F.R. § 63.24, ONATI SAS (“ONATI”) (FRN
0028355444), hereby notifies the Commission of the partial pro forma assignment of the
international Section 214 authorization for the Honotua submarine cable system connecting
French Polynesia and Hawaii, from Office des postes et télécommunications de Polynésie
française (“OPT”) (FRN 0015464282) to ONATI. This partial pro forma assignment results
from a corporate reorganization of OPT. OPT and ONATI will therefore be authorization
holders for the Honotua submarine cable system (and for the associated cable landing license, the
subject of a partial pro forma assignment notification filed in parallel with this notification).

1.     Background

        As authorized by recent changes in French Polynesia law, OPT has undertaken a
restructuring of its operations to create new French Polynesia operating subsidiaries for its
telecommunications, postal, and financial services businesses that will leave OPT itself operating
as a holding company. By deed dated December 31, 2018, OPT agreed to delegate to ONATI
the provision of telecommunications services in French Polynesia through the operation and use
of network infrastructure owned by OPT (including the physical assets of the Honotua submarine
cable system, to which OPT will retain legal title). Under the delegation, OPT will also transfer
to ONATI the personnel of OPT’s telecommunications business. The delegation has been
implemented on a phased basis, with delegation of authority with respect to the Honotua
submarine cable system effective as of March 1, 2019.

2.     Information Required by 47 C.F.R. §§ 63.18(a)-(d) and (h) and 63.24(f)(2)

       As required by 47 C.F.R. §§ 63.18(a)-(d) and (h) and 63.24(f)(2)(i), ONATI provides the
following information:


Ms. Marlene H. Dortch
Federal Communications Commission
March 28, 2019
Page 2 of 3


       a.      Name, Address, and Telephone Number

               ONATI SAS
               Rond-point de la base marine, Fare Ute
               BP 440
               98713 Papeete, Tahiti
               French Polynesia
               +689 41 74 65

       b.      Place of Organization:

       ONATI is organized under French Polynesia law.

       c.      Contact Information

       ONATI’s contact information is as follows:

               Tehina Thuret
               Executive Manager
               Telecoms & Multimedia Business Unit
               ONATI SAS
               Rond-point de la base marine, Fare Ute
               BP 440
               98713 Papeete, Tahiti
               French Polynesia
               +689 41 74 65

Correspondence concerning this filing should be sent to Mr. Thuret at the address listed above,
with a copy to:

               Kent Bressie
               Harris, Wiltshire & Grannis LLP
               1919 M Street, N.W., Suite 800
               Washington, D.C. 20036
               +1 202 730 1337
               kbressie@hwglaw.com

       d.      Prior International Section 214 Authority

     ONATI has not previously held international Section 214 authority from the
Commission.


Ms. Marlene H. Dortch
Federal Communications Commission
March 28, 2019
Page 3 of 3


       e.      Direct and Indirect Ownership; Interlocking Directorates with Foreign
               Carriers

       ONATI has two 10-percent-or-greater direct and indirect interest holders, as follows:

               Office des postes et télécommunications de Polynésie française
               Address: Fare Ute, P.O. Box 605, 98713 Papeete, Tahiti
               Place of Organization: French Polynesia
               Principal Business: holding company
               Interest Held: OPT holds 100 percent of ONATI’s economic and voting interests.

               Presidency of the Government of French Polynesia
               Address: Quartier Broche, Avenue Pouvanaa a Oopa, BP 2551, Papeete, Tahiti,
                       French Polynesia
               Place of Organization: French Polynesia
               Principal Business: government
               Interest Held: The Government of French Polynesia holds 100 percent of OPT’s
                       economic and voting interests.

       f.      Certification Regarding Prior Pro Forma Transactions

        As required by 47 C.F.R. § 63.24(f)(2)(ii), ONATI certifies in the attached certification
that this partial assignment is pro forma in nature and would not, when considered together with
all previous pro forma transactions, result in a change in control of the Honotua submarine cable
system.

                                       *    *   *   *    *

       ONATI has notified the Team Telecom agencies of this partial pro forma assignment.


                                             Yours sincerely,



                                             Kent Bressie
                                             Susannah Larson

                                             Counsel to ONATI SAS

Attachment


                                       CERTIFICATION



       1, Tehina Thuret, as Telecoms & Multimedia Business Unit Executive Manager of
ONATI SAS, hereby certify as follows:


   1. 1 have reviewed the attached partial pro forma assignmentnotification and believe that it
      states fully and accurately the circumstances of the partial pro forma assignment of the
      international Section 214 authorization for the Honotua submarine cable system.

   2. This partial assignment described therein is proforma in nature under the Commission‘s
      rules and, together withall previous pro formatransactions, would notresult in a change
      in the ultimate control of the international Section 214 authorization for the Honotua
      submarine cable system.

   3. No party to this notification is subjectto a denial of federal benefits, including FCC
       benefits, under Section 5301 of the Anti—Drug Abuse Act of 1988.

I certify under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.




                                                i
                                             Tehina Thufet        2 /.


Executed March 27®, 2019
                                                             s#



Document Created: 2019-04-28 16:41:30
Document Modified: 2019-04-28 16:41:30

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