Centmobile 07242012

LETTER submitted by Rubard LLC d/b/a Centmobile

Letter to International Bureau

2012-07-25

This document pretains to ITC-STA-20120703-00168 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2012070300168_960954

WG WILTSHIRE & GRANNIS us Mr. Jim Ball July 24, 2012 Chief, Policy Division International Bureau Federal Communications Bureau 445 12" St SW Washington, D.C. 20554 Re: FCC Form 2148TA ITC—STA—20120703—00168 Dear Mr. Ball: Rubard LLC, dba Centmobile ("Centmobile") provides international calling at among the lowest ratesin the market, and its customers would be economically harmed by having such service discontinued. In such an event, for most routes, Centmobile customers would have to pay higher prices for the same product. The representative chart below showsthe economic value that Centmobile‘s customers enljoy and may highlight a reason a competitor would have for driving Centmobile from the market: Rates (/min) Route Centmobile Stanacard Cameroon 1.60 1.89¢ Pakistan 1.95C 320 Nigeria 6.60 790 Kenya 7.99€ 8490 Poland 0.99€ 228C China 1.99€ 2160 Sri Lanka 799€ $.050 Syria 7.99¢ £.930 El Salvador 12998 13.17¢ Ghana 14.90 19.90 Additional route rates comparisons may be found on therespective websites of www.centmobile.com and www.keku.com, Stanacard‘s trade name. ‘The table reflects prices advertised as of July 20, 2012, independentof any additional promotions the companies may offer. 1200 187 STREET, NW| SuifE 1200 | wasHinGToN, DC 20036 | TE 202—730—1300 | Fax 202—730—1301 | witrSHiRsraNNiS coMt

WG WILTSHIRE & GRANNIS LLP In response to your letter of July 19, 2012, Centmobile provides the following answers to your questions: 1. What service is Centmobile providing to its customers? Please clarify whether Centmobile is providing just international service or both domestic and international service? Centmobile provides both domestic and international service, with a small amount being domestic. Centmobile designed its innovative system to reduce overhead costs, compared to its competitors, and therefore can offer some of the lowest prices in the market. In addition, Centmobile saves its customers money by not printing cards and by offering services only through the Internet. Centmobile also runs various programs to reward its loyal customers. All of Centmobile's customers- I 00%- receive some amount of credit towards the free use of service after their purchased minutes are depleted. For example, most of Centmobile's customers have been rewarded a $20 bonus of free minutes after their first deposit. Were Centmobile to discontinue service, a substantial value in free minutes would be lost to customers. Based on a report run after receipt of your letter, the current value of unused bonus minutes is $91,403.00. Centmobile plans to provide this $91,403.00 of free service to its customers. For Centmobile's price-sensitive customer base, the loss of such economic value is contrary to the public interest, particularly in the current economic environment. 2. Please describe how the service is provided to the customers. Centmobile offers global voice calling services through prepaid plans, the accounts for which are established by customers directly through Centmobile's website, www.centmobile.com. Centmobile provides service through its access numbers, as well as utilizing a call forwarding feature whereby the customer can simply dial a local phone number and have the call forwarded to the international destination. Centmobile's innovative technology allows it to significantly reduce the cost of operating such a business and as a result pass these savings to the consumer. To maximize convenience for a range of customers, with a range of incomes, Centmobile offers a variety of plans, from $5.00 up to $200.00- all prepaid using credit or debit cards. Centmobile customers can replenish their accounts by adding monetary value to their on-line accounts at any time. If Centmobile were to terminate service, it would re.fund the dollar balance of unused paid minutes, but many customers would lose the value of their remaining free minutes- totaling in the aggregate $91,403.00. 3. How many customers does Centmobile currently have, both international and domestic? 1200 18TH STREET. NW I SUITE 1200 I WASHINGTON. OC 20036 I TEL202-730-1300 I FAX 202-730-1301 I WILTSHIREGRANNIS COM

WG WILTSHIRE & GRANNIS LLP The attached certification by Alexander Dzerneyko certifies to the accuracy of the information provided. Because it is in the public interest to ensure that Centmobile's existing customers are not disadvantaged by any discontinue of service, and because any action on the STA is without prejudice to Commission action on the underlying Section 214 application, Centmobile reiterates its request for Special Temporary Authority, originally filed July 3, 2012. Grant of the STA to 2 avoid a disruption of service for Centmobile's customers is well within Commission precedent. Respectfully subm itted, Patricia Paoletta Counsel to Rubard LLC, dba Centmobile cc: George Li David Krech Adrienne Downs 22 See, e.g., Domestic Section 214 Application Filed for the Transfer of Control ofSTi Prepaid, LLC to Vivaro Corporation, 25 FCC Red. at 14309 (20 11 ); Domestic Section 214 Application Filed for the Transfer of Control ofAries Network, Inc. to Nobe/Tel, LLC, 25 FCC Red. at 3648 (20 I 0). The precedent Stanacard, LLC cites in its Reply to Response to Opposition to Application for STA ofRubard LLC d/b/a Centmobile are Title III radio cases. Centmobile is not using radio spectrum nor seeking a radio license. Section 214's temporary authorization references do not require a demonstration of extraordinary circumstances nor a showing that delay would seriously prejudice the public interest. To the contrary, Section 214(a), after referencing the public convenience and necessity criteria, provides that "the Commission may, upon appropriate request being made, authorize temporary or emergency service, or the supplementing of existing facilities, without regard to the provisions of this section." 47 U.S.C. § 214(a). Section 63.25 of the Commission's Rules sites as its origin Section 303, in Title III. See 47 C.F.R. § 63.25 (Parts 40-69, revised as of October 2011, at 251). In any event, Section 63 .25 has no extraordinary circumstances requirement, unlike Section 1.931, governing STAs for wireless facilities. See Section 1.93l(b)(4), 47 C.F.R. § 1.931(b)(4). 1200 18TH STREET. NW I SUITE 1200 I WASHINGTON. DC 20036 I TEL 202·730·1300 I FAX 202·730·1301 I WllTSHIREGRANNIS COM

DECLARATlON OF ALEXAJ\DER DZERNEYKO I. Alexander Dzerneyko. Manager ofRubard LLC dbaCentrnobile.do hereb) certif)· to lhe accuracy of the i.nformarion provided in counsel' skttcr of today's date, including the m1Sv..ers to the questionsin lntema(ionul Bureau's letter of Jul) 19, ]012. Alexander Dzemeyko ExecUled on July 24. 2012 1


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