Attachment A1 Stream

This document pretains to ITC-STA-20130412-00109 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2013041200109_993189

                                                 Document: Attachment A1 Stream
                                                      Ocean Technology Limited

Question 9:

Ocean Technology Limited (“Ocean”) desires streamlined processing pursuant to
Section 63.12 of the Commission's rules. Ocean qualifies for streamlined
processing under Section 63.12(c)(1)(ii) because although Ocean is a foreign
carrier in a destination market, Ocean qualifies for a presumption of non-
dominance under Section 63.10(a)(3). As more fully described in response to
Question 11 below, Ocean qualifies for a presumption of non-dominance under
Section 63.10(a)(3) Ocean is not a monopoly provider and does not have more
than 50% of the market share for international transport or local access on the
foreign end of the relevant routes.

The other restrictions set forth in Section 63.12(c) of the Commission's rules do
not apply. Ocean does not have an affiliation with a dominant U.S. carrier whose
international switched or private line services the applicant seeks authority to
resell. And Ocean does not seek authority to provide switched basic services
over private lines to a country for which the Commission has not previously
authorized the provision of switched services over private lines.

Question 11:

63.18(i) – Ocean hereby certifies that it is licensed as a foreign carrier in Japan.

63.18(j) – Ocean hereby certifies that it seeks to provide international
telecommunications services to Japan, where it is licensed as a foreign carrier.

63.18(k) – Japan is a member of the WTO. In addition, Ocean lacks market
power in Japan. Japan has less than 1% of the market for telecommunications
services and access lines in Japan.

63.18(l) – Ocean desires the authority to resell the international switched
services of an unaffiliated U.S. carrier on the routes to Japan. Accordingly,
pursuant to Section 63.10(a)(3), Ocean hereby certifies that Ocean is not a
monopoly provider in Japan. Ocean further submits the following information to
demonstrate that Japan does not have sufficient market power on the foreign end
of the routes to the countries specified above to adversely affect competition in
the U.S. market: Ocean has less than 1% of the market for telecommunications
services and access lines in Japan.

63.18(m) – Ocean desires to be classified as non-dominant. Ocean submits that
the information set forth above for Section 63.18(l) demonstrates that it is
presumptively non-dominant under Section 63.10(a)(3) of the Commission’s
Rules.


Question 12:

As described above, Ocean desires to be authorized to provide international
telecommunications services to, among other countries, Japan, where it is a non-
dominant foreign carrier, as described above.

Question 15:

(d)   Ocean has not received authority previously under Section 214 of the
      Communications Act.

(e)   Ocean certifies that it will comply with the terms and conditions contained
      in sections 63.21, 63.22 and 63.23 of the Commission's rules.

(f)   At this time, Ocean seeks no other authorization available under Section
      63.18(e).

(g)   Not applicable.



Document Created: 2012-12-10 11:42:11
Document Modified: 2012-12-10 11:42:11

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