STA Application.pdf

OTHER submitted by Flock FZ-LLC

STA Application - Narrative

2019-03-27

This document pretains to ITC-STA-20190319-00091 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2019031900091_1640290

Date: 25 March 2019

BEFORE THE FEFERAL COMMUNICATIONS COMMISSION
WASHINGTON DC 20554

In the Matter of Flock FZ—LLC previously known as Riva FZC

RE: Application for special temporary authority for Transfer of Control application "ITC—T/C—
INTR2019—00783" dated 19 March 2019



Response to question 10: Provide Justification of Need for Special Temporary Authority

Since Flock FZ—LLC ("Flock" or "Applicant") did not inform the Commission or seek prior approval before
consummating the transaction of Transfer of Control dated 30 January 2018, the application was
submitted as a result of unauthorized transaction.

Flock‘s earlier transfer of control application "ITC—T/C—20160316—00123" dated 16 March 2016 was
pending with Team Telecom for its review, Flock was awaiting updates on this application, so it did not
file the subsequent transfer of control application dated 30 January 2018, this transfer happened
during the intermediate period. The transfer of control has happened between two UBO‘s who are
real brothers and Co—founders of the business.

After discussion and as advised by the Commission, Flock has submitted transfer of control of
international section 214 authorization application as on 19 March 2019.

Flock hereby requests the Commission to grant Special Temporary Authority as it is in the public
interest to avoid a discontinuance of service to customers while the Commission considers underlying
application.

The parties acknowledge that the grant of this STA will not prejudice any action the Commission may
take on the underlying application. The parties further acknowledge that this STA can be modified or
revoked by the Commission upon its own motion without a hearing.

Flock has taken the necessary steps to ensure future compliance with Commission rules and
regulations. Flock will identify regulatory requirements on regular intervals, so Flock can address them
proactively.

Flock hereby request Special Temporary Authority for 180 days.

Response to question 16: Respond to Paragraphs (d), (e)(3) and g of Section 63.18


Section 63.18 (d)

The Flock has previously received international authority under Section 214 of the Act. Its license
number is ITC—20140128—00033.

Section 63.18 (e)(3)
Not Applicable. Applicant is applying for authority to operate as a global resale carrier pursuant to the
terms and conditions of Section 63.18 (e)(2) of the Commission‘s Rules, 47 C.F.R 63.18 (e)(2)

Section 63.18 (g)

Not Applicable. Applicant is applying for authority to operate as a global resale carrier pursuant to the
terms and conditions of Section 63.18 (e)(2) of the Commission‘s Rules, 47 CF.R 63.18 (e)(2)



Thanking you in anticipation.

Your Faithfully,
 or Flock FZ—LLC




Brijesh Jo:
Director



Document Created: 2019-04-19 12:51:50
Document Modified: 2019-04-19 12:51:50

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