Attachment Attachment 3

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

IBFS_ITCSTA2014020700029_1034612

                                              ATTACHMENT 3
  Mr. Jim Ball                                                                               February 6, 2014
  Chief, Policy Division
  International Bureau
  Federal Communications Bureau
  445 12th St SW
  Washington, D.C. 20554

  Re: FCC Form 214STA; ITC-214-20120518-00134

  Dear Mr. Ball:

         This letter serves as Attachment 3 to the Special Temporary Authority (“STA”)
  application of Rubard LLC d/b/a Centmobile filed today. On August 19, 2013, your office
  renewed its previous STA to Rubard to provide global resold international telecommunications
  services for an additional 180 days. This grant expires on February 15, 2014.

          Rubard applied to the Bureau for international Section 214 authority in May 2012. To
  ensure that Rubard’s customers can continue to use their Centmobile prepaid service while
  Rubard awaits that decision, Rubard seeks an extension of its STA to provide resold international
  services. Renewing Rubard’s STA will ensure that its existing customers do not lose service
  under their prepaid Centmobile plans. This grant will therefore serve the public interest by
  shielding those customers from a discontinuance of service.

         Since its current STA was granted, Rubard has entered into a Consent Decree with the
  Enforcement Bureau to end its investigation of preauthorized service. The Consent Decree
  includes a Compliance Plan with reporting requirements.
         Rubard acknowledges that grant of its instant STA request does not prejudice any future
  Commission action and can be revoked or modified by the Commission upon its own motion
  without a hearing.
                                                      Respectfully submitted,




                                                      Patricia Paoletta
                                                      Counsel to Rubard LLC d/b/a Centmobile


  cc: David Krech
      Adrienne Downs


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Document Created: 2019-04-15 05:42:41
Document Modified: 2019-04-15 05:42:41

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