Attachment Attachment 1

This document pretains to ITC-STA-20141216-00323 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2014121600323_1071334

                                                                        Reliance Jio Infocomm USA, Inc.
                                                                                         Request for STA


                                           ATTACHMENT 1


         Reliance Jio Infocomm USA, Inc. (“Applicant”) requests special temporary authority

(“STA”) to provide international facilities-based and resold services to all international points

pending action on the Applicant’s application for permanent authority to provide international

services pursuant to Section 214 of the Communications Act, as amended, filed December 15, 2014

(Submission ID IB2014002408) (the “Application”).

         Response to Question 10

         The Department of Justice and Department of Homeland Security (“Team Telecom”) have

not yet begun their review of the Application. The Applicant does not at this time know how long

Team Telecom review will take, but anticipates that such review will conclude well after the time

when the Commission could be expected to have concluded its streamlined review of the

Application in the ordinary course. The Applicant requests that STA begin no later than thirty (30)

days after the date of this filing, i.e., January 16, 2015, and last for a period of no less than 180 days,

or until the Application is granted. During the period of the STA, the Applicant anticipates that it

will begin providing international resold services, and may initiate the provision of international

facilities-based services.

         The Applicant acknowledges that a grant of STA will not prejudice any future Commission

action on the Application, and that grant of the STA may be revoked or modified by the

Commission on its own motion, upon notice and without a hearing.

         Response to Question 12

         The following information is submitted pursuant to Sections 63.18(i) through (m) of the

rules:




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                                                                     Reliance Jio Infocomm USA, Inc.
                                                                                      Request for STA


       (i)      The Applicant is affiliated with a foreign carrier in the following countries: India;

Singapore; United Kingdom. The Applicant is not a foreign carrier in any foreign country.

       (j)      The Applicant seeks to provide international telecommunications services to all

international points, including the countries of India, Singapore, and the United Kingdom. The

Applicant is not a foreign carrier in these or any other countries, nor does the Applicant control a

foreign carrier in any country. Entities that control and own more than 25 percent of the Applicant

(specifically, Reliance Jio Infocomm Limited (“RJIL”), Reliance Industries Limited (“RIL”), and Sh.

Mukeesh Ambani) also control a foreign carrier each of these countries. Those foreign carriers are:

                Name:                           Reliance Jio Infocomm Limited
                Country:                        India
                Relationship to Applicant:      Holder of 100% of the equity of the Applicant; RJIL
                                                and the Applicant are commonly owed by RIL and
                                                Sh. Mukeesh Ambani, and commonly controlled by
                                                Sh. Ambani, who is the Chairman, Managing Director
                                                and largest shareholder of RIL.

                Name:                           Reliance Jio Infocomm Pte Limited
                Address:                        250 North Bridge Road
                                                # 16-01 Raffles City Tower
                                                Singapore 179101
                Country:                        Singapore
                Relationship to Applicant:      RJIL, which owns 100% of the Applicant, also owns
                                                100% of Reliance Jio Infocomm Pte Limited.

                Name:                           Reliance Jio Infocomm UK Limited
                Address:                        105 Wigmore Street, 8th Floor
                                                London, United Kingdom, W1U 1QY
                Country:                        United Kingdom
                Relationship to Applicant:      RJIL, which owns 100% of the Applicant, also owns
                                                100% of Reliance Jio Infocomm UK Limited

       (k)      With respect to each destination foreign country identified in (j) above, such country

is a Member of the World Trade Organization, and the Applicant’s affiliated foreign carrier lacks

market power. Both Reliance Jio Infocomm Pte Limited and Reliance Jio Infocomm UK Limited

have been authorized to provide service, but are not providing services at this time.


{00071189;v1}


                                                                     Reliance Jio Infocomm USA, Inc.
                                                                                      Request for STA


        (l)     The Applicant proposes to resell the international switched services of an unaffiliated

U.S. carrier to provide service to India, Singapore, and/or the United Kingdom. In each of those

countries, the Applicant’s affiliated foreign carrier has not yet begun providing services, and thus

lacks 50 percent market share.

        (m)     Because none of the foreign carriers with which the Applicant is affiliated has 50

percent or more market share in the international transport and local access markets on its

respective foreign end of the route, the Applicant presumptively should be classified as non-

dominant pursuant to Section 63.10(a)(3) of the rules. RJIL has been authorized to provide services

in India, but has not yet begun to provide services and has no market share. As noted, both

Reliance Jio Infocomm Pte Limited and Reliance Jio Infocomm UK Limited have been authorized

to provide service, but are not providing services at this time.

        Response to Question 13

        As noted in response to Question 12, the Applicant seeks authority to provide services to

India, Singapore, and the United Kingdom.

        Response to Question 16

        The following information is submitted pursuant to Sections 63.18(d), (e) and (g) of the

Commission’s rules:

        (d)     The Applicant has not previously received authority under Section 214 of the

Communications Act of 1934, as amended.

        (e)     Not applicable.

        (g)     Not applicable.




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Document Created: 2014-12-16 16:30:28
Document Modified: 2014-12-16 16:30:28

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