Attachment 20170803154014-200.p

20170803154014-200.p

SUPPLEMENT

Supplement

2013-12-19

This document pretains to ITC-STA-20131219-00343 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2013121900343_1615230

George Li

From:                              Adrienne Downs
Sent:                        Friday, December 20, 2013 2:05 PM
To:                      —>» ‘Brown, Tyrone (NSD)‘
Ce:                        ';Z (/.James Ball; David Krech; George Li; Howard Griboff
Subject:                            RE: STA
Attachments:                        Extension_of_STA[2].pdf



We have received Teledirek‘s request for an extension of the current STA (File No. ITC—STA—20131219—00343). They are
requesting a 6 month extension (See attached letter). Jim will act on the request Monday, December 23, 2013. Thanks.

Adrienne Downs


From: Brown, Tyrone (NSD) [mailto:Tyrone.Brown@usdoj.gov]
Sent: Wednesday, December 18, 2013 2:06 PM
To: George Li; "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)‘
Subject: RE: STA

We are looking into extending the STA without a request, if that is a possibility.



From: George Li [mailto:George.Li@fcc.gov]
Sent: Wednesday, December 18, 2013 1:17 PM
To: "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)‘
Cc: Brown, Tyrone (NSD)
Subject: RE: STA

Have you filed the request ?


From: George Li
Sent: Tuesday, December 03, 2013 1:11 PM
To: "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)
CC: ‘Brown, Tyrone (NSD) (Tyrone.Brown@usdoj.gov)‘
Subject: RE: STA




From: George Li
Sent: Wednesday, November 20, 2013 12:01 PM
To: ‘Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)
Cc: Brown, Tyrone (NSD) (Tyrone.Brown@usdoj.gov)
Subject: STA

Hi Edward;
Teledirek‘s ITC—STA—20131101—00282 expires on Dec.19, 2013.
Could you file the request for the extension of STA early next month so we can get TT/DOI‘s consent on time to grant
the extension?    Please send a copy of request to <Tyron.Brown@usdoj.gov>


Geo;ge Li

From:                               Adrienne Downs
Sent:                               Monday, December 23, 2013 12:01 PM
To:                                 Brown, Tyrone (NSD) (Tyrone.Brown@usdoj.gov)
Ce:                                 Sofield, Richard (NSD) (Richard.Sofield2@usdoj.gov); Jam    3all; David Krech; George Li;
                                    Howard Griboff
Subject:                            FW: STA
Attachments:                        Extension_of_STA[2].pdf



Any word of the status of this request? Thanks.

Adrienne


From: Adrienne Downs
Sent: Friday, December 20, 2013 2:05 PM
To: ‘Brown, Tyrone (NSD)‘
Co: James Ball; David Krech; George Li; Howard Griboff
Subject: RE: STA

We have received Teledirek‘s request for an extension of the current STA (File No. ITC—STA—     131219—00343). They are
requesting a 6 month extension (See attached letter). Jim will act on the request Monday,       :ember 23, 2013. Thanks.

Adrienne Downs


From: Brown, Tyrone (NSD) [mailto:Tyrone.Brown@usdoj.gov]
Sent: Wednesday, December 18, 2013 2:06 PM
To: George Li; "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)‘
Subject: RE: STA

We are looking into extending the STA without a request, if that is a possibility.



From: George Li [mailto:George.Li@fcc.gov]
Sent: Wednesday, December 18, 2013 1:17 PM
To: "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)‘
Co: Brown, Tyrone (NSD)
Subject: RE: STA
                                                                                      DEC 10 _20‘13
Have you filed the request ?                                                                   Divigion


From: George Li
Sent: Tuesday, December 03, 2013 1:11 PM
To: "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)‘
CC: ‘Brown, Tyrone (NSD) (Tyrone.Brown@usdoj.gov)‘
Subject: RE: STA




From: George Li
Sent: Wednesday, November 20, 2013 12:01 PM


Geor(_;e Li

From:                               George Li
Sent:                               Monday, December 23, 2013 11:33 AM
To:                                 Brown, Tyrone (NSD) (Tyrone.Brown@usdoj.gov)
Subject:                            FW: STA
Attachments:                        Extension_of_STA[2].pdf



Any lucks ??


From: Adrienne Downs
Sent: Friday, December 20, 2013 2:05 PM
To: ‘Brown, Tyrone (NSD)‘
Co: James Ball; David Krech; George Li; Howard Griboff
Subject: RE: STA

We have received Teledirek‘s request for an extension of the current STA (File No. ITC—STA—20131219—00343). They are
requesting a 6 month extension (See attached letter). Jim will act on the request Monday, December 23, 2013. Thanks.

Adrienne Downs


From: Brown, Tyrone (NSD) [mailto:Tyrone.Brown@usdoj.gov]
Sent: Wednesday, December 18, 2013 2:06 PM
To: George Li; "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)‘
Subject: RE: STA

We are looking into extending the STA without a request, if that is a possibility.



From: George Li [mailto:George.Li@fcc.gov]
Sent: Wednesday, December 18, 2013 1:17 PM
To: "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)‘
Cc: Brown, Tyrone (NSD)                          ‘
Subject: RE: STA

Have you filed the request ?


From: George Li
Sent: Tuesday, December 03, 2013 1:11 PM
To: "Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)‘
Cc: ‘Brown, Tyrone (NSD) (Tyrone.Brown@usdoj.gov)‘
Subject: RE: STA




From: George Li
Sent: Wednesday, November 20, 2013 12:01 PM
To: ‘Edward A. Maldonado, Esq.‘ (eam@maldonado—group.com)
Cc: Brown, Tyrone (NSD) (Tyrone.Brown@usdoj.gov)
Subject: STA


Hi Edward;
Teledirek‘s ITC—STA—20131101—00282 expires on Dec.19, 2013.
Could you file the request for the extension of STA early next month so we can get TT/DOJ‘s consent on time to grant
the extension?    Please send a copy of request to <Tyron.Brown@usdoj.gov>


 Geor@e Li                    f                                                           ©

 From:                               David Krech
 Sent:                              Tuesday February 25, 2014 4:07 PM
— To:                             /”James Ball; GeorgeLi
  Subject:                           FW: Teledirek LOA
 Attachments:                       Teledirek Global Corp LOA Draft 20140203 — redline.docx; Teledirek Global Corp LOA      Q;
                                    Draft 20140203 — clean.docx .




From: Hagar, Richard [mailto:richard.hagar@HQ.DHS.GOV]
Sent: Tuesday, February 25, 2014 4:04 PM
To: David Krech
Co: IP—FCC; Brown, Tyrone (NSD); George Li
Subject: FW:wfii-’

 David,
                                                                                        x _
 As seen below, we sent an updated Letter of Assurances to Teledirek’s counsel on             'fifilmmnfirmed with
 counsel that they dldinfact receive theupdated
                                        piess
                                                 LOA onthe
                                                       L/—\
                                                            3.   We  have   not yet received a re/pfimse..J\beheve the STA
 that was granted isdueto\fxp}e   shortly Assuming that Teledirek fails to respond Eeforet iéTA     explresDHS  does not
 recommend that theFCCg:anmk an additional STA.
       smy .            /\"“‘/\’_\“—:‘:;7
               aic*m*Six.,                                                                                    Y

 Richard                                      mm                                                   /b '                     ,Lf

 Richard Hagar
 Deputy Director — Foreign Investment Risk Management
 Office of Policy
 U.S. Department of Homeland Security
 Office: 202—447—4165
 Mobile: 202—527—3322



FromHagar Richard
Sent: Monday, Febr/PM
To: eam@maldonado    —group.com                                       /
Co: IP—FCC; ‘Brown, Tyrone (NSD)‘; rlevy@maldonado—group.com
Subject{ Teledirek LOA

 Ed,

 See attached for an updated Letter of Assurances reflecting Teledirek‘s use of GAAP and adding DOJ as an
 addressee. Assuming Teledirek has no objections to these revisions, please incorporate the requested information
 highlighted in the Letter and return an executed copy to DOJ and DHS. Please confirm receipt of this email. Thanks.

 Richard

 Richard Hagar
 Deputy Director — Foreign Investment Risk Management
 Office of Policy


ol
George
   OrO Li                                                           es

From:                              David Krech            .
Sent:                              Friday, March 14, 2014 8:49 AM
To:                                Adrienne Downs
Coe:                               George Li; James Ball
Subject:                           FW: Teledirek Global Corporation (ITC—214—20120801—00193)
Attachments:                       TELEDIREK — LOA.pdf; Teledirek Petition to adopt 3 13 14.pdf




From HO]atI, Shahram (NSD) [mallto Shahram Ho1at|@usd01 gov]
Sent: Friday, March 14, 2014 7:10 AM
To: George Li; David Krech
Co: Brown, Tyrone (NSD)
Subject: RE: Teledirek Global Corporation (ITC-214—20120801—00193)

Good Morning:

TT has filed petition to adopt conditions to authorization of above Applicant.
If you have any questions please call me.

Thanks
Shahram Hojati
DOJ, SME
202—233—0748


              DRAFT Letter of Agreement with Teledirek Global Corp., 04—Dec—13



                                                                   February XX, 2013

David Heyman         .
Assistant Secretary for Policy
Office of Policy
U.S. Department of Homeland Security
3801 Nebraska Avenue NW
Washington, DC 20016
IP—FCC@hq.dhs.gov

Mr. JohnCarlin
Acting Assistant Attorney General
National Security Division
US Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530
ttelecom@usdoj.gov

       Re: Teledirek Global Corporation‘s application for Section 214 authority in accordance
       with section 63.24 of the Federal Communication Commission‘s rules (ITC—214—
       20120801—00193).

Dear Mr. Heyman:

        Teledirek Global Corporation (Teledirek) is a Florida—based telecommunications
company applying for new Federal Communications Commission (FCC) authority to provide
facilities—based and resale services to all international points. Charles Eveillard, Teledirek‘s
Chief Technology Officer, and Paul Mentor, Teledirek‘s Chief Executive Officer and Chief
Financial Officer, each own 50 percent of Teledirek.

        This Letter outlines the commitments made by Teledirek to the U.S. Department of
Homeland Security (DHS) and the U.S. Department of Justice (DOJ) (collectively, the USG
Parties), in order to address national security, law enforcement, and public safety concerns raised
with regard to Teledirek‘s application with the FCC. Through this Letter of Assurances, the
USG Parties seek to ensure that the public interest continues to be served by the grant of this
Section 214 authority to Teledirek. Teledirek hereby agrees to the following terms:

Mutually Agreed Upon Accounting Standard:
Teledirek will maintain its financial books and records in a manner that complies with Generally
Accepted Accounting Principles (GAAP).

Changes in Ownership or Control:
(a) Teledirek certifies that Charles Eveillard and Paul Mentor are the sole owners of Teledirek,
and that no other party holds an ownership interest in Teledirek.


               DRAFT Letter of Agreement with Teledirek Global Corp., 04—Dec—13


 (b) Teledirek will inform the USG Parties within thirty (30) days of any change in the ownership
 of Teledirek, including the names of the businesses or personally identifiable information of the
 individuals associated with the changein ownership and the change in the percentage amount of
 ownership. Teledirek will also informthe USG Partiesof any change in ownership or control of
 Teledirek resulting in a change of a passive investor to an active one. Teledirek further agrees to
 negotiate in good faith with the USG Parties to resolve any national security, law enforcement,
 or public safety concerns the USG Parties may raise with respect to changes in Teledirek‘s
 ownership structure.

  Access to Information and Facilities: Teledirek, and any owner of Teledirek, shall permit the
  USG Parties and such other U.S. Government agency representatives as the USG Parties may
  designate, to inspect books and records, equipment, servers, andfacilities and premises ownedor
  leased by Teledirek Communications or any owner of Teledirek, to the extent business relating
  to Teledirek‘s FCC—licensed activity takes place at suchlocation/s. Ordinarily, the USG Parties
_ will provide Teledirek with fourteen (14) days advance notice, but in extraordinary
  circumstances Teledirek shall afford the USG Parties such access during normal business hours
  with or without advance notice.

 Access to Personnel: Teledirek, and any owner of Teledirek, shall permit the USG Parties, and
 suchother U.S. Government agency representative as the USG Parties may designate, to conduct
 confidential interviews of owners, ownership groups, employees, or contractors of Teledirek
 concerning compliance with this letter of agreement and any other law enforcement concerns.

 Initial Audit Requirement: No later than one year after the execution of this Letter, Teledirek
 will retain and payfor a neutral third party GAAP audit of Teledirek‘s financial books and
 records, including its corporate bank accounts. Within sixty (60) days from the execution of this
 Letter, Teledirek shall provide notice of the proposed auditor, and the USG Parties shall have an
 opportunity to object to the selection of the auditor within sixty (60) days of receipt of such
 notification. Oncea third party auditor has been mutually—agreed, the USG Parties shall be
 consulted on the audit terms and Teledirek will reasonably address any concerns raised by the
 USG Parties. Teledirek shall ensure that all reports generated by the third party auditor are
 promptly providedto the USG Parties. Teledirek agrees to negotiate in good faith with the USG
 Parties to resolve any national security, law enforcement, or public safety concerns the USG
 Parties may raise with respectto the results of the initial third party audit. The USG Parties shall
 be granted the right to exclusively meet with the auditor at any time, upon request of the USG
 Parties.

 Subsequent Audit Requirement: Following the initial audit, at the USG Parties‘ request, but
 not more often than once per year, Teledirek shall retain and pay for subsequent neutral third
 party GAAP audits of Teledirek‘s financial books and records, including its corporate bank
 accounts. Within sixty (60) days from the date of any such request from the USG Parties,
 Teledirek shall provide notice of the initial proposed auditor, and the USG Parties shall have an
 opportunity to object to the selection of the auditor within sixty (60) days of receipt of such
 notification. Once a third party auditor has been mutually—agreed, the USG Parties shall be
 consulted on the audit terms and Teledirek will reasonably address any concerns raised by the
 USG Parties. In the event an auditor not previously approved by the USG Parties is proposed for
 a subsequent annual audit, Teledirek agrees to follow the same procedures set forth above.


              DRAFT Letter of Agreement with Teledirek Global Corp., 04—Dec—13


Teledirek shall ensure that all reports generated by a third party auditor are promptly prc    ledto
the USG Parties. Teledirek agrees to negotiate in good faith with the USG Parties to res:      e any
national security, law enforcement, or public safety concerns the USG Parties may raise        th
respect to the results ofa third party audit. The USG Parties shall be grantedthe right tc
exclusively meet with the auditors at any time, upon request of the USG Parties.

Notice of Termination of Accounts: Teledirek agrees to notify the USG Parties withir           irty
(30) days of any termination of accounts in the name of Teledirekor any of its owners b
financial institution and the reasongiven by the financial institution for such terminatior
Teledirek also agrees to inform the USG Parties if it terminates or initiates any relations.   s with
a financial institution and provide additional information regarding such relationships as
requested by the USG Parties.

Notice of Enforcement Actions: Teledirek and its owners certify that they are not curr         ly the
subject of enforcement action or inquiry by any State, local, or Federal law enforcement
regulatory agency, and that neither is a party to any lawsuit alleging fraud or misreprese;    tion in
any jurisdiction. Teledirek and its owners agree to notify the USG Parties within thirty |     ) days
of being served notice of civil, criminal, or regulatory/administrative enforcement actior
inquiry, or receipt of such a lawsuit.

Communication: All notices to be provided to the USG Parties shall be directed to:

       Shawn Cooley
       Director, Foreign Investment Risk Management
       Office of Policy
       U.S. Department of Homeland Security
       3801 Nebraska Avenue NW
       Washington, D.C. 20016
       Email: IP—FCC@hq.dhs.gov
       Phone: 202—282—8489

       Richard Sofield
       Director
       Foreign Investment Review Staff
       National Security Division
       U.S. Department of Justice
        600 E. Street, NW
        Washington, DC 20530
        Email: ttelecom@usdoj.gov
        Phone: 202—233—0702

All notices to be provided to Teledirek shall be directed to:

        [INSERT NAME &TITLE, ADDRESS, EMAIL AND PHONE NUMBER]


              DRAFT Letter of Agreement with Teledirek Global Corp., 04—Dec—13



         Teledirek agrees that, in the event of a breach by Teledirek of the commitments set forth
in this letter, in addition to any other remedy available at law or equity, the USG Parties may
request that the FCC modify, condition, revoke, cancel, or render null and void any relevant
license, permit, or other authorization granted by the FCC to Teledirek or any successors—in—
interest. Nothing herein shall be construed to be a waiver by Teledirek of, or limitation on, its
right to oppose or comment on any such request.

        Nothing in this letter is intended to excuse Teledirek from its obligations to comply with
any and all applicable legal requirements and obligations, including any and all applicable
statutes, regulations, requirements, or orders.          ’

        Teledirek understands that, upon execution of this letter by an authorized representative
or attorney for Teledirek, the USG Parties shall notify the FCC that it has no objection to the
FCC‘s grant of Teledirek‘s application.



                                              Sincerely,



                                              [INSERT NAME OF SIGNER AND TITLE]
                                              Teledirek Global Corp.


              DRAFT Letter of Agreement with Teledirek Global Co.r'p., 04—Dec—13



                                                               Jarmary—FebruaryXX, 2013

David Heyman
Assistant Secretary for Policy
Office of Policy
U.S. Department of Homeland Security
3801 Nebraska Avenue NW
Washington, DC 20016
IP—CFHIUS@hq—dbhs—govIP—FCC@hq.dhs.gov

Mr. John Carlin
Acting Assistant Attorney General
National Security Division
US Department ofJustice
950 Pennsylvania Avenue. NW
Washington, DC 20530
ttelecom@usdoj.gov
—INSERT—OTHER
       Re: Teledirek Global Corporation‘s application for Section 214 authority in accordance
       with section 63.24 of the Federal Communication Commission‘s rules (ITC—214—
       20120801—00193).

Dear Mr. Heyman:

       Teledirek Global Corporation (Teledirek) is a Florida—based telecommunications
company applying for new Federal Communications Commission (FCC) authority to provide
facilities—based and resale services to all international points. Charles Eveillard, Teledirek‘s
Chief Technology Officer, and Paul Mentor, Teledirek‘s Chief Executive Officer and Chief
Financial Officer, each own 50 percent of Teledirek.

       This Letter outlines the commitments made by Teledirek to the U.S. Department of
Homeland Security (DHS) and the U.S. Department ofJustice (DOJ) (collectively. the USG
Parties), in order to address national security, law enforcement, and public safety concerns raised
with regard to Teledirek‘s application with the FCC. Through this agreementLetter of
Assurances, DBHS—and—DOJ—the USG Parties seeks to ensure that the public interest continues to
be served by the grant of this Section 214 authority to Teledirek. Teledirek hereby agrees to the
following terms:

Mutually Agreed Upon Accounting Standard:
Teledirek will maintain its financial books and records in a manner that complies with ar
toTeledirekGenerally Accepted Accounting
Principles (GAAP).

Changes in Ownership or Control:


              DRAFT Leiter of Agreemefit with Teledirek Global Corp., 04—Dec—13


(a) Teledirek certifies that Charles Eveillard and Paul Mentor are the sole owners of Teledirek,
and that no other party holds an ownership interest in Teledirek.
(b) Teledirek will inform DHS—andDOJthe USGPartieswithin thirty (30) days of any change in
the ownership of Teledirek, including the namesofthe businesses or personally identifiable
information of the individuals associated with the change in ownership and the change in the
percentage amount of ownership. Teledirek will also inform DBHS—andBOJtheUSG Partiesof
any change in ownership or control of Teledirekresulting in a change of a passive investor to an
active one. Teledirek further agrees to negotiate in good faith with DHS—and—DOJthe USG
Parties to resolve any national security, law enforcement, or public safety concerns the USG
PartiesDHS may raise with respect to changes in Teledirek‘s ownership structure.

Access to Information and Facilities: Teledirek, and any owner of Teledirek, shall permit DHS
and—DOJ—the USG Partiesand such other U.S. Government agency representatives as DHS—and
DBOJthe USG Parties may designate, to inspect books and records, equipment, servers, and
facilities and premises owned or leased by Teledirek Communications or any owner of
Teledirek, to the extent business relating to Teledirek‘s FCC—licensed activity takes place at such
location/s. Ordinarily, DBHS—and—BOJthe USG Partieswill provide Teledirek with fourteen (14)
days advance notice, but in extraordinary circumstances Teledirek shall afford DBHS—and—BOJthe
USG Parties such access during normal business hours with or without advancenotice.

Access to Personnel: Teledirek, and any owner of Teledirek, shall permit BHS—and—BOJthe
USG Parties, and such other U.S. Government agencyrepresentative as DHS—and—DOJthe USG
Parties may designate, to conduct confidential interviews of owners, ownership groups,
employees, or contractors of Teledirek concerning compliance with this letter of agreement and
any other law enforcement concerns.

Initial Audit Requirement: No later than one year after the execution of this Letter, Teledirek
will retain and pay for a neutral third party GAAP audit of its—Teledirek‘s financial books and
records, including its corporate bank accounts. Within sixty (60) days from the execution of
this Letter, Teledirek shall provide notice of the proposed guditor, and BHS—and—BOL—the USG
Parties shall have an opportunity to object to the selection of the auditor within sixty (60) days of
receipt of such notification. Once a third party auditor has been mutually—agreed, DHS—and
DBOJthe USG Parties shall be consulted on the audit terms and Teledirek will reasonably address
any concerns raised by DHS—and—DOJthe USG Parties. Teledirek shall ensure that all reports
generated by the third party auditor are promptly provided to DHS—andDBDOJthe USG Parties.
Teledirek agrees to negotiate in good faith with DBHS—and—DOJthe USG Parties to resolve any
national security, law enforcement, or public safety concerns DHS—and—BOJthe USG Parties may
raise with respect to the results of the initial third party audit. DHS—and—DOJThe USG Parties
shall be granted the right to exclusively meet with the auditor at any time, upon request of BHS
and—DOJthe USG Parties.                       '

Subsequent Audit Requirement: Following the initial audit, at DHS—and—BPOJ‘sthe USG
Parties‘ request, but not more often than once per year, Teledirek shall retain and pay for
subsequent neutral third party GAAP audits of Teledirek‘s financial books and records, including
its corporate bank accounts. Within sixty (60) days from the date of any such request from BHS
and—DOJ;—the USG Parties, Teledirek shall provide notice of the initial proposed auditor, and
DHS—and—DOJthe USG Parties shall have an opportunity to object to the selection of the auditor


                   DRAFT Letter of Agreement with Teledirek Global Corp., 04—Dec—13


within sixty (60) days of receipt of such notification. Once a third party auditor has been

Teledirek will reasonably address any concerns raised by DHS—and—DOJthe USG Parties. In the
event an auditor not previously approved by DBHS—andDBOJtheUSG Parties is proposed for a
subsequent annual audit, Teledirek agrees to follow the same procedures set forth above.
Teledirek shall ensure that all reports generated by a third party auditor are promptly provided to
DHS—and—DOJthe USG Parties. Teledirek agrees to negotiate in good faith with BHS—and—DOJthe
USG Parties to resolve any national security, law enforcement, or public safety concerns the
USG PartiesDHS may raise with respect to the results of a third party audit. DHS—and—DOJThe
USG Parties shall be granted the right to exclusively meet with the auditors at any time, upon
request of DHS—and—DOJthe USG Parties.

Notice of Termination of Accounts: Teledirek agrees to notify the DHS—and—BOJUSGParties
within thirty (30) days of any termination of accounts in the name of Teledirek or any of its
owners by a financial institution and the reason given by the financial institution for such
termination. Teledirek also agrees to inform PHS—and—DOJthe USG Parties if it terminates or
initiates any relationships with a financial institution and provide additional information
regarding such relationships as requested by DHS—and—DOJthe USG Parties.

Notice of Enforcement Actions: Teledirek and its owners certify that they are not currently the
subject of enforcement action or inquiry by any State, local, or Federal law enforcement or
regulatory agency, and that neither is a party to any lawsuit alleging fraud or misrepresentation in
any jurisdiction. Teledirek and its owners agree to notify DBHS—and—DOJthe USG Parties within
thirty (30) days of being served notice of civil, criminal, or regulatory/administrative
enforcement action or inquiry, or receipt of such a lawsuit.

Communication: All notices to be provided to DBHS—and—DOJthe USG Parties shall be directed
to:

          Shawn Cooley
          Director, Foreign Investment Risk Management
          Office of Policy
          U.S. Department of Homeland Security
          3801 Nebraska Avenue NW
          Washington, D.C. 20016
          Email: JP—FCCEFIYS@hq.dhs.gov_                                                               .__....~| Field Code Changed
          Phone: 202—282—8489

          Richard Sofield
______________Director
          Foreign Investment Review Staff
          National Security Division
          U.S. Department ofJustice
          600 E. Street. NW
          Washington. DC 20530
          Email: ttelecom@usdoi.gov


                  DRAFT Letter of Agreement with Teledirek Global Corp., 04—Dec—13


|          Phone: 202—233—0702

    All notices to be provided to Teledirek shall be directed to:

           [INSERT NAME &TITLE, ADDRESS, EMAIL AND PHONE NUMBER]



             Teledirek agrees that, in the event of a breach by Teledirek of the commitments set forth
    in this letter, in addition to any other remedy available at law or equity, DPHS—and—BOJthe USG
    Parties may request that the FCC modify, condition, revoke, cancel, or render null and void any
    relevant license, permit, or other authorization granted by the FCC to Teledirek or any
    successors—in—interest. Nothing herein shall be construed to be a waiver by Teledirek of, or
    limitation on, its right to oppose or comment on any such request.

           Nothing in this letter is intended to excuse Teledirek from its obligations to comply with
    any and all applicable legal requirements and obligations, including any and all applicable
    statutes, regulations, requirements, or orders.

            Teledirek understands that, upon execution of this letter by an authorized representative
    or attorney for Teledirek, DHS—and—DOJthe USG Parties shall notify the FCC that it has no
    objection to the FCC‘s grant of Teledirek‘s application.



                                                      Sincerely,



                                                      [INSERT NAME OF SIGNER AND TITLE]
                                                      Teledirek Global Corp.



Document Created: 2019-10-18 18:31:16
Document Modified: 2019-10-18 18:31:16

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