Attachment Attachment 1

This document pretains to ITC-STA-20151111-00262 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2015111100262_1115109

                                                                   Reliance Jio Infocomm USA, Inc.
                                                                                    Request for STA


                                        ATTACHMENT 1


Reliance Jio Infocomm USA, Inc. (“Applicant”), pursuant to 47 C.F.R. § 63.25, hereby requests
special temporary authority (“STA”) for a period of ninety (90) days to provide international service
to customers pending consideration of the Applicant’s separately filed application for permanent
authority to provide international services pursuant to Section 214 of the Communications Act, as
amended, filed July 24, 2015 (File No. ITC-214-20150724-00185) (the “Application”).

Response to Question 10

India, the world’s second-largest mobile wireless market by number of customers, will see the
introduction of multiple 4G wireless networks in 2015. The Applicant’s affiliate, Reliance Jio
Infocomm Ltd., is in the process of launching its own new 4G, all-IP network in India this year.
The services that the Applicant proposes to provide in the United States will commercially support
that network, giving network users in both the U.S. and India a new competitive alternative for
personal and business data and voice communications between the U.S. and India. Grant of
temporary authority will allow the Applicant to initiate service promptly.

The introduction of a new entrant in the U.S. market will result in economic benefits throughout the
broadband ecosystem. In addition to making broadband service offerings more accessible to
individuals, the Applicant also intends to offer wholesale services to U.S. providers. The Applicant
also has partnered with U.S. vendors who will benefit from substantially increased business when
the Applicant initiates service. U.S. consumers and carriers will benefit from the increased
competition that will come with the introduction of a new provider of wholesale voice and data
services. Such increased competition serves to foster technological advancement and lower prices
for consumers.

Grant of temporary authority also will assist the Applicant in obtaining interconnection agreements
with U.S. carriers, which will enable enhanced service offerings. To date, lack of Commission
authority has hindered the Applicant’s efforts to complete such agreements.

The Applicant notes that but for review by Executive Branch agencies, its Application would have
been processed under streamlined review procedures, resulting in a grant in August 2015. The
Application was accepted for streamlined processing by Public Notice released August 14, 2015
(Report No. TEL-01748S). Thereafter, the Commission was “requested by the Executive Branch
agencies of the United States that we remove the [Application] from streamlined processing.”
Public Notice, Report No. TEL-01751S (Aug. 28, 2015). The Application was removed from
streamlined processing, see id. (notwithstanding that no procedures exist governing such requests).
The Executive Branch agencies sent a request for information to the Applicant on August 25, 2015,
and the Applicant submitted responses on September 25, 2015. The Applicant has received no
further correspondence from the Executive Branch agencies regarding its Application.

The Applicant requests that STA begin no later than November 30, and last until the earlier of 90
days or the Application is granted. During the period of the STA, the Applicant will begin providing



{00087335;v1}


                                                                     Reliance Jio Infocomm USA, Inc.
                                                                                      Request for STA


international resold services concurrent with or shortly following the launch of its affiliate’s network
in India.

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:

(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 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.
        Mukesh 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. Mukesh
                                        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




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                                                                   Reliance Jio Infocomm USA, Inc.
                                                                                    Request for STA


(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.

(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: 2015-11-11 14:19:15
Document Modified: 2015-11-11 14:19:15

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