Attachment Attachment 1

This document pretains to ITC-STA-20170317-00040 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2017031700040_1201532

                                                                      Section 214 Application for
                                                                    Special Temporary Authority
                                                                       Attachment 1, Page 1 of 2



                                  LigTel Communications, Inc.

Question 10: In Attachment 1, provide justification of need for special temporary
             authority requested.

Response:

       LigTel Communications, Inc. (“LCI”) respectfully submits that the public interest would
be served by a grant of this Special Temporary Authority (“STA”) pending grant of its
application for the transfer of control regarding its Section 63.18(e)(2) (global resale authority),
File No. ITC-214-20000270-00064, filed simultaneously herewith. 1 Thus, prompt action
granting this STA will allow LCI’s customers to continue to utilize the international long
distance service offered by it

       The instant request for STA is a companion filing to correct the inadvertent error of not
seeking the January 15, 2005 transfer of control of LTC and indirectly the transfer of control of
LCI. At the time of the transfer of control, LTC was the parent company of LCI and is now,
along with LCI, a wholly owned subsidiary of Heartland Innovations, Inc. (“Heartland”) arising
from a January 1, 2017 pro forma transfer of control. 2

        Grant of this request for STA will ensure that LCI will be able to continue to provide
uninterrupted international resold service. LCI expressly acknowledges that grant of this request
will not prejudice action by the Commission on the underlying International 214 Application and
that any authority granted pursuant to this request is subject to cancellation or modification upon
notice but without a hearing.

1
        LCI and its affiliate, Ligonier Telephone Company, Inc. (“LTC”), will also be filing ha
STA request to continue their domestic operations. A copy of this STA request will be provided
to the FCC International Bureau once filed.
2
  At the time of the transfer of control, LTC was the parent company of LCI and is now, along
with LCI, a wholly owned subsidiary of Heartland arising from a January 1, 2017 pro forma
transfer of control. As a result of the Companies’ planned corporate reorganization, Heartland
was formed and, on January 1, 20017, Heartland established LTC and LCI as separate wholly-
owned subsidiaries. The ownership of Heartland, an Indiana corporation formed for the purpose
of reorganization, is the same as that previously for LTC. Specifically, the former shareholders
of LCI’s parent company, LTC, exchanged their shares of LTC for shares of Heartland. As a
result of the reorganization, both LCI and LTC are wholly owned subsidiaries of Heartland, and
the shareholders of Heartland, after the reorganization, are identical to the previous shareholders
of LTC.


                                                                      Section 214 Application for
                                                                    Special Temporary Authority
                                                                       Attachment 1, Page 2 of 2



        Good cause exists for grant of the instant request, which would ensure that consumers
would not suffer inconvenience or loss of service, or otherwise be affected adversely. Having
become aware of the inadvertent oversight regarding ownership changes arising from the death
of Dr. Schloss, LCI is voluntarily attempting to take all steps necessary to rectify the situation.
Accordingly, LCI submits that the public interest would be serviced by prompt grant of the
instant request.
     Applicants request that the STA be granted for a period of sixty (60) days to permit the
Commission to complete its processing of the pending domestic 214 application in due course.

Question 16: In Attachment 1, respond to paragraphs (d), (e)(3) and (g) of Section 63.18.

Response:

        In response to 47 C.F.R. §63.18(d), LCI, the Applicant, has been granted international
global resale authority under File No. ITC-214-20000270-00064 (see Public Notice, Report No.
TEL-00997, DA No. 06-360, released February 16, 2006) to resell the international services of
authorized U.S. common carriers for the provision of international switched, private line, data,
television and business services to all international points, and to resell private lines for the
purpose of providing international basic switched services to countries found to offer equivalent
resale opportunities. Accordingly, Sections 63.18(e)(3) and 63.18(g) are not applicable.



Document Created: 2017-03-17 15:06:12
Document Modified: 2017-03-17 15:06:12

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