Attachment Attachment 1 ITC-STA-20110131-00020

Attachment Attachment 1

This document pretains to ITC-STA-20110131-00020 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2011013100020_865332

Application
for

Special
Temporary
Authority

Under
Section
214
of
the
Act

Attachment
1,
Page
1
of
2

PUBLIC
INTEREST
NETWORK
SERVICES,
INC.

Response
to
Question
10

Public
Interest
Network
Services,
Inc.
(“PINS”)
respectfully
seeks
Special
Temporary

Authorization
(“STA”)
for
the
provision
of
resold
international
services
pending

grant
of
its
application
for
permanent
Section
63.18(e)(2)
authorization,
filed

simultaneously
herewith.

PINS
has
only
recently
come
to
understand
that,
unlike

the
“blanket”
authority
to
provide
domestic
interstate
services
that
arises
under

Section
63.01(a)
of
the
Commission’s
Rules,
specific
application
for
and
grant
of

international
authorization
is
required.

Prompt
grant
of
the
STA
request
would

serve
the
public
interest
by
allowing
PINS
to
continue
uninterrupted
international

service
to
its
customers,
primarily
small
and
medium
businesses,
many
of
whom
are

non-‐profit
public
interest
organizations.

PINS
only
recently
became
aware
that
it
was
operating
without
international

authorization.

In
the
course
of
a
due
diligence
review
in
contemplation
of
a

proposed
transfer
of
PINS
corporate
control,
no
Section
214
International

Authorization
could
be
located.

Based
on
retained
corporate
records,
current

management
believes
that
in
the
good
faith
but
unfortunately
mistaken
belief
that

the
filing
of
a
tariff
was
the
only
federal
regulatory
requirement
regarding
the

initiation
of
international
telecommunications
service,
the
company
began
offering

international
service
in
1998.

International
service
is
provided
as
a
convenience
to

its
customers,
and
constitutes,
on
average,
less
than
five
percent
of
PINS’s

telecommunications
services
revenues.

Until
the
proposed
transaction
initiated
an
independent
regulatory
review,
PINS
had

believed
that
it
was
operating
in
compliance
with
all
regulatory
obligations.

Promptly
upon
confirming
the
fact
of
non-‐compliance,
PINS
initiated
the

preparation
of
this
application
and
its
companion
application
for
permanent

authorization.
PINS acknowledges that the grant of this STA will not prejudice any
action the Commission may take on the underlying application for permanent
authorization, or the contemplated subsequent application seeking Commission consent
to transfer of the authorization. PINS further acknowledges that this STA can be revoked
by the Commission on its own motion without a hearing.

Good
cause
exists
for
grant
of
the
instant
request.

Grant
would
ensure
that
PINS’s

customers
would
not
suffer
inconvenience
or
loss
of
service,
or
otherwise
be

affected
adversely.

Having
become
aware
of
its
oversight,
PINS
is
voluntarily

attempting
to
take
all
steps
necessary
to
rectify
the
situation
as
promptly
as

Application
for

Special
Temporary
Authority

Under
Section
214
of
the
Act

Attachment
1,
Page
2
of
2

PUBLIC
INTEREST
NETWORK
SERVICES,
INC.

Response
to
Question
10
(continued)

possible.

Accordingly,
PINS
submits
that
the
public
interest
would
be
served
by

prompt
grant
of
this
request
for
STA.

Response
to
Question
16

Applicant
PINS
has
not
previously
been
granted
international
Section
214
authority.

Applicant
seeks
authorization
to
operate
as
a
resale
carrier
pursuant
to
the
terms

and
conditions
of
Section
63.18(e)(2)
to
resell
the
international
services
of

authorized
US
common
carriers
for
the
provision
of
international
switched,
private

line,
data,
television
and
business
services
to
all
international
points,
and
to
resell

private
lines
for
the
purpose
of
providing
international
basic
switched
services
to

countries
found
to
offer
equivalent
resale
opportunities.

Accordingly,
Sections

63.18(e)(3)
and
63.18(g)
are
not
applicable.

Document Created: 0410-04-23 00:00:00
Document Modified: 0410-04-23 00:00:00

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