Attachment Attachment 1

This document pretains to ITC-STA-20111227-00392 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2011122700392_930911

ATTACHMENT 1 Answer to Questions 10: Justification for need for special temporary authority requested. Applicant kajeet/Airlink requests Special Temporary Authority (“STA”) pursuant to Section 214 of the Communications Act of 1934, as amended (“the Act”), 47 U.S.C. § 214. In April 2009 kajeet/Airlink acquired the assets of Airlink Mobile, including Airlink Mobile’s inventory of prepaid calling cards that enabled consumers to make international “dial around” calls. Airlink possessed international Section 214 authority under File No. ITC-214-20030606- 00288. At the time of the transaction, however, kajeet/Airlink was under the belief that it did not need to apply for such authority. The FCC’s recent Notice of Apparent Liability (“NAL”), FCC 11-180, concludes that kajeet/Airlink failed to comply with Section 214 of the Act and Section 63.24 of the rules by consummating the April 2009 transaction without obtaining prior Commission approval for the assignment of the international Section 214 authorization held by Airlink Mobile. NAL at ¶ 19. kajeet/Airlink files this STA request to seek temporary authority to provide international “dial around” calls until December 31, 2011. kajeet/Airlink, however, will not seek permanent Section 214 authority because it stopped selling the pre-paid international calling cards on December 15, 2011. kajeet/Airlink notified the Commission by filing submitted December 14, 2011, that its pre-paid service will be discontinued as of December 31, 2011. The public interest is served by granting the STA and allowing kajeet/Airlink to continue providing international pre-paid telecommunications services until December 31, 2011. Answer to Question 16: 63.18(d): Airlink Mobile, Inc. was authorized by the Commission in File No. ITC-214- 20030606-00288 granted July 3, 2003. kajeet/Airlink does not currently hold Section 214 authority. 63.18(e)(3): N/A 63.18(g): N/A


Document Created: 2011-12-22 09:42:54
Document Modified: 2011-12-22 09:42:54
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