Attachment Attachment 1

This document pretains to ITC-STA-20130128-00025 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2013012800025_983055

                              RUBARD LLC d/b/a CENTMOBILE

                                        ATTACHMENT 1

214STA Question 10 – Justification:

Rubard LLC d/b/a Centmobile (“Centmobile”) seeks a renewed STA in order to continue to
provide affordable international calling services during the pendency of Commission review of
Centmobile’s Section 214 application filed in May 2012. Centmobile requires a renewed STA to
ensure that its existing customers do not lose international service under their prepaid
Centmobile plans. It is in the public interest to grant a renewed STA and prevent Centmobile’s
existing customers from being disadvantaged from any discontinuance of service.

Centmobile acknowledges that a grant of the STA will not prejudice any future Commission
action on the underlying application for global facilities-based and resold international
telecommunications authority, and that grant of the STA can be revoked or modified by the
Commission upon its own motion without a hearing.

214STA Question 16:

Response to §63.18(d)

Centmobile has not previously received authority under Section 214 of the Act other than its
original STA granted August 23, 2012 for global resale authority.

Response to §63.18(e)(3)

Centmobile applied for authority to provide facilities-based services pursuant to § 63.18(e)(1)
and resell the services of authorized carriers pursuant to §63.18(e)(2) to all international points
authorized by the Commission on May 18, 2012. In the instant application, Centmobile is
applying to extend the date of its STA for global resale authority. Centmobile will comply with
the terms and conditions contained in 47 C.F.R. §§ 63.21 and 63.23.

Response to §63.18(g)

Not applicable.



Document Created: 2019-04-28 20:06:24
Document Modified: 2019-04-28 20:06:24

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