Fusion - Telecom Hol

SUPPLEMENT submitted by Fusion Connect, Inc., Debtor-In-Possession

Second Supplement

2019-09-05

This document pretains to ITC-ASG-20190724-00136 for Assignment on a International Telecommunications filing.

IBFS_ITCASG2019072400136_1888422

                                       September 5, 2019



Marlene Dortch                                                        via ECFS, IBFS
Secretary
Federal Communications Commission
445-12th Street SW
Washington, DC 20554

        Re:    In the Matter of Application of Fusion Connect, Inc., Debtor-in-Possession
               and Telecom Holdings LLC For Consent to a Transaction That Will Result
               in a Change of Control of Companies Holding Domestic and International
               Authority Pursuant to Section 214 of the Communications Act of 1934, as
               Amended: Second Supplement to Application
               WC Ref: INBOX-63.04
               ITC- ITC-ASG-20190724-00136

Dear Ms. Dortch:

        On July 24, 2019, Fusion Connect, Inc., debtor-in-possession (“Fusion Connect”) and

Telecom Holdings LLC (together with Fusion Connect, the “Applicants”) filed the above-

referenced application (the “Application”) with the Federal Communications Commission (the

“Commission”) for approval of a transfer of control of Fusion Connect and each of its

subsidiaries that holds a Section 214 telecommunications license1 (the “Transaction”). The

Fusion Companies’ Chapter 11 Plan of Reorganization (the “Plan”) and Disclosure Statement,

submitted in pre-final form as Exhibit B to the Application, proposed the reorganization

transaction for which approval is sought in the Application.




1   Fusion Connect and these subsidiaries (collectively, the “Fusion Companies”) each
    commenced with the United States Bankruptcy Court for the Southern District of New York
    (the “Bankruptcy Court”) a voluntary case under chapter 11 of title 11 of the United States
    Code. In re Fusion Connect, Inc., et al., Debtors, Case No. 19-11811 (Bankr. S.D.N.Y. Jun.
    3, 2019).


                                                1


       Earlier this week, Fusion Connect filed an Amended Chapter 11 Plan of Reorganization

and Disclosure Statement with the Bankruptcy Court. The Applicants submit this filing to

provide the Commission with a copy of these updated materials.

                                          Respectfully submitted,


       FUSION CONNECT, INC.                          TELECOM HOLDINGS LLC

        /s/ Winafred R. Brantl                          /s/ Wayne D. Johnsen
       Edward A. Yorkgitis, Jr.                       Wayne D. Johnsen
       Winafred R Brantl                              Wiley Rein LLP
       Kelley Drye & Warren LLP                       1776 K Street NW
       3050 K Street, NW, Suite 400                   Washington, DC 20006
       Washington, DC 20007                           wjohnsen@wileyrein.com
       cyorkgitis@kelleydrye.com                       Its Attorneys
       wbrantl@kelleydrye.com
       Its Attorneys




                                           2


                             Attachment 1

                 AMENDED JOINT CHAPTER 11 PLAN
       OF FUSION CONNECT, INC., AND ITS SUBSIDIARY DEBTORS

      AMENDED DISCLOSURE STATEMENT FOR AMENDED JOINT
CHAPTER 11 PLAN OF FUSION CONNECT, INC. AND ITS SUBSIDIARY DEBTORS

                       (as filed on Sept. 4, 2019)



Document Created: 2010-01-01 00:00:00
Document Modified: 2010-01-01 00:00:00

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