Attachment CPC, LLC STA Grant.p

CPC, LLC STA Grant.p

DECISION submitted by FCC

STA Grant

2018-11-29

This document pretains to ITC-STA-20181010-00187 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2018101000187_1584673

Streamlined ITC-STA-20f 81010-00187 Granted lB2Ol 80071 51 ce J.M. Steinhart, P.C. Combined Public Communications, LLC Attorneys At Law date: ]oveEnbex- 2 , 2cI 5 Windward Concourse authorized by Te kor’v ic Suite 150 an A 5iq’Lso Irna-rcI we’j Aipharefta, Georgia 30005 signature IZt Also Admitted in New York Ieplioue. 770) 232-9200 - Email: info@teiecomcounsel.com Facsmn . (770) 232-9208 Mcy a a MflV 29Z078 October 10, 2018 Intemationaj Bureau VIA IBFS Marlene H. Dortch, Secretary federal Communications Commission Office of the Secretary 445 12th Street, S.W. Washington, DC 20554 Aftn: International Bureau Re: Protocall, LLC and Combined Public Communications, LLC, Request for Special Temporary Authorization Dear Secretary Dortch, Pursuant to 47 U.S.C. § 214, and Section 63.24 of the Commission’s Rules, 47 C.F.R. § 63.24, Protocall, LLC (“Protocall”) along with Combined Public Communications, LLC (“Combined Public”) (collectively, the “Applicants”), hereby respectfully request Special Temporary Authority (“STA”) so that Combined Public may continue to service newly acquired business pending Commission approval of their joint section 214 applications, filed concurrently herewith, for assignment of domestic and international authorizations and transfer of customers and assets from Protocall to Combined Public (the “Joint Application”). Effective October 1, 2017, Protocall sold all the rights, title and interest in all the customers and assets (the “Transaction”) utilized to provide inmate telecommunications services to certain jails and detention centers in Iowa, Kansas, Colorado, Nebraska and Missouri pursuant to an asset purchase agreement dated September 27, 2017 by and between Protocall and Combined Public (the “Agreement”). The Transaction resulted in the sale of Protocall’s domestic operations and customers, see 47 C.F.R. § 63.01, 63.03, and 63.04, and the partial assignment of Protocall’s international Section 214 authorization pursuant to 47 C.F.R. § 63.18 and 63.24.

Unfortunately, the Applicants did not seek timely Commission approval of the Transaction. The oversight was inadvertent and unintentional. At the time of the Transaction, Protocall did not have advice from federal communications counsel on the Transaction and it was not aware of the obligation to request Commission approval. As soon as this failure came to the Applicants’ attention, the Applicants took steps to remedy the noncompliance and to seek authority, to the extent necessary, for the continued provision of service to customers. The Applicants regret this oversight and have taken steps to ensure compliance with all applicable Commission requirements going forward. Grant of the STA will serve the public interest by permitting the continued, uninterrupted provision of service to customers while the Commission reviews the Joint Application. Grant of the STA also will promote competition in the inmate telephone services marketplace. Without discounting the regulatory obligation to obtain prior approval, the Applicants note that no harm to customers or to the market occurred as a result of Applicants’ oversight. The Applicants request temporary authority for sixty (60) days while the Joint Application is pending. The Applicants acknowledge that the grant of this STA will not prejudice any action the Commission may take on the Joint Application, and that once granted, the STA may be revoked on the Commission’s own notice, without a hearing. The Applicants further acknowledge that grant of the STA will neither preclude nor dictate the scope of any enforcement action related to the Transaction. This filing with the International Bureau and the applicable credit card payment in the amount of $1,195.00, which satisfies the filing fee required under the Commission’s rules, are being submitted electronically through the MyIBFS. All correspondence and inquiries in connection with this filing should be forwarded to the undersigned. If you have any questions or if I may provide you with any additional information, please do not hesitate to contact me. Respectfully submitted, Is! Lance J.M. Steithart Lance J.M. Steithart Managing Attorney Lance J.M. Steinhart, PC Attorneys for Combined Public Communications, LLC and Protocall, LLC


Document Created: 2018-11-30 19:04:13
Document Modified: 2018-11-30 19:04:13
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