Attachment Attachment 3

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

IBFS_ITCSTA2013012800025_983057

WG WILTSHIRE & GRANNIS LLP Mr. James Ball January 28, 2013 Chief, Policy Division International Bureau Federal Communications Bureau 445 1ih St SW Washington, D.C. 20554 Attachment 3 Re: FCC Form 214STA ITC-STA-20120703-00168 and ITC-214-20120518-00134 Dear Mr. Ball: This letter serves as Attachment 3 to the renewed Special Temporary Authority ("STA") application ofRubard LLC d/b/a Centmobile ("Centmobile") filed January 28, 2013 to extend the date ofCentmobile's existing STA. On August 23,2012, your office granted an STA to Centmobile to provide resale authority for 180 days. This grant expires on February 19, 2013. As of the writing of this letter, Centmobile still waits for a determination on the above- referenced 214 application for global facilities-based and resale authority, which was removed from streamlined processing June 22, 2012. To ensure that Centmobile can continue to provide service to its prepaid customers while it awaits this determination, Centmobile seeks an extension of its STA to provide resold international telecommunications services. Centmobile recognizes that providing international services prior to express authorization by the Commission is not permitted by its rules. Centmobile seeks expeditious treatment of its STA in order to continue to provide affordable international calling services during the pendency of Commission review of the above referenced 214 application. Centmobile acknowledges that grant of renewed STA for an additional six months is without prejudice to Commission action on the underlying 214 application and that the Commission may revoke or modify a renewed STA upon its own motion without a hearing. Respectfully submitted, Patricia Paoletta Counsel to Rubard LLC 1 dba Centmobile cc: George Li David Krech Adrienne Downs 1200 18TH STREET. NW I SUITE 1200 I WASHINGTON, DC 20036 I TEL 202-730·1300 I FAX 202·730·1301 I WILTSHIREGRANNIS.COM


Document Created: 2019-04-20 06:16:00
Document Modified: 2019-04-20 06:16:00
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