Attachment Attachment 1

This document pretains to ITC-STA-20140207-00029 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2014020700029_1034609

                              RUBARD LLC d/b/a CENTMOBILE

                                       ATTACHMENT 1

214STA Question 10 – Justification:

Rubard LLC d/b/a Centmobile (“Rubard”) seeks a renewed STA in order to continue to provide
affordable international calling services during the pendency of Commission review of Rubard’s
Section 214 application filed in May 2012. Rubard 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 Rubard’s existing customers from being
disadvantaged from any discontinuance of service.
Rubard 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)

Rubard has not previously received authority under Section 214 of the Act other than its original
STA granted August 23, 2012 for global resale authority and the renewals of that STA on
February 19, 2013, and August 19, 2013, with the latter extending temporary authority pending
review of its International Section 214 Application until February 15, 2014.

Response to §63.18(e)(3)

Rubard 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, Rubard is applying
to extend the date of its STA for global resale authority. Rubard 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: 2019-04-14 00:04:21
Document Modified: 2019-04-14 00:04:21

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