Attachment 20170126100107-820.p

20170126100107-820.p

SUPPLEMENT

Supplement

1998-11-12

This document pretains to ITC-T/C-19981112-00818 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC1998111200818_1396641

                                       Streamtined    ITC-T/C-1 9981112-00818
                                       AMERICAN INTERNAT!ONAL TELEPHONE, INC.
       Categories of -Seryices for 214 Applications
                (Streainl me/Non- streainl me)
L]   ASSIGNMENT OF LICENSE
Li   GLOBAL FACILITIES-BASED SERVICE
Li   GLOBAL FACILITIES-BASED/GLOBAL RESALE SERVICE
LI   GLOBAL RESALE SERVICE
Li   INDIVIDUAL FACILITIES-BASED SERVICE
Li   INTERCONNECTED PRIVATE LINE RESALE SERVICE
L]   LIMITED GLOBAL FACILITIES-BASED SERVICE/LIMITED
     GLOBAL RESALE SERVICE
Li   LIMITED GLOBAL FACILITIES-BASED SERVICE
LI   LIMITED GLOBAL RESALE SERVICE
Li   INARSAT AND MOBILE SATELLITE SERVICE
Li   SWITCHED RESALE SERVICE
LI   TRANSFER OF CONTROL
Li   SUBMARINE CABLE LANDING LICENSE
Li   INTERNATIONAL SPECIAL PROJECT
Description of Application:


                    LAW OFFICES OF THOMAS K. CROWE, P.C.
                                       2300 M STREET, N.W.
                                            SUITE 800
                                      WASHINGTON, D.C. 20037
                                      TELEPHONE (202) 973-2890
                                         FAX (202) 973-2891
                                     E-MAIL tkcrowe@mci2000.com
                                          www.tkcrowe.com
                                                                  November 12, 1998
BY COURIER
Federal Communications Commission
International Bureau-Telecommunications
P.O. Box 358115
Pittsburgh, PA 15251-5 115
       Re:    Interoute Telecommunications, Inc - and
              American International Teleyhone, Inc.
Dear Sir/Madam:
      Please find enclosed an original and six copies of Interoute Telecommunications, Inc. and
American International Telephone, Inc.'s Application for Consent to Transfer of Control.
       Also enclosed is an FCC Form 159 and a check in the amount $780.00 payable to the
"Federal Communications Commission" to cover the requisite filing fee. Please file-stamp and
return the extra copy of this filing in the self-addressed, stamped envelope enclosed for this
purpose.
       Questions regarding this filing should be directed to the undersigned.
                                                                  Thomas K. Crowe
                                                                  Elizabeth Holowinski,
                                                                  Counsel for Interoute
                                                                  Telecommunications, Inc.
                                                                  and American International
                                                                  Telephone, Inc.
Enclosures


INTEROUTE TELECOMMUNICATIONS, LLC


            INSTRUCTIONS CAREFULLY                                                                                                                              APPROVED BY 0MB                        30e0.o5.,
  READ
       BEFORE PROCEEDING                                                   FEDERAL COMMUNICATIONS COMMISSION                                            ___________________________
                                                                                    REMITTANCE ADVICE                                                                           ___
                                                                                           PAGE NO.__ OF
                          .33011                                                                                                                             ____
 (1)LOCKBOX#
                                                                          SECTION A- PAYER INFORMATION                                          (3) TOTAL AMOUNT PAID (NouN. nod cool.)
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         Interoute Telecommunications,                                                               Inc.                                       *780.00
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 .1) DAYTNA TEI.EPNORE NLHIR (Mc(ud. a. cod.)                                                     (IS) COUNTRY CODA (if not N. U.S.A.)
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                                                                         ECTION B   -        A PPLICAN T INFORMATION
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                                                                                   SECTION E - CERTIFICATION
                                                                                                                                                                          I I I I I
2)3 CER11FICAT)OM STATEMENT
      Thomas             K.       Crowe                                  . Certify under penalty of perjury that the                             in and            pporting ØprmatiOn
                              (PRONT NAME)
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are    true   and   Correct   to the best of my knowledge, infomation and belief. SIGNATU                                                     - _--                       '-
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                              MASTERCAS1OMSA ACCOUNT )(CI*R:                                                                                           EXPIRATION DATE
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                                                                                     AIJTHO99ZED SIGNATURE                                                  DATE
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                                                     SEE PUBLIC BURDEN ES1SNATE ON REVERSE                                                             FCC TONAl 159   JUIY 1091 RE'.I1S€O)


                                    Before the
                      FEDERAL COMMUNICATIONS COMMISSION
                               Washington, D.C. 20554
In the Matter of                                )
                                                )
INTEROUTE                                       )
TELECOMMUNICATIONS, INC.                        )
                                                )
       Transferee,                              )
                                                )
AMERICAN iNTERNATIONAL                          )     File NoJ.1a-7/         /qqf//41-62/(
TELEPHONE, INC.                                 )
                                                )
       Transferor,                              )
                                                )
Application for Authority Pursuant to           )
Section 214 of the Communications Act           )
of 1934, as amended, to Transfer Control        )
of Authorized International Carrier             )
              4PPLICATION FOR CONSENT TO TRANSFER CONTROL
       Pursuant to Section 214 of the Communications Act of 1934, as amended, 47 U.S.C. §
214 (1997), and Section 63.18 of the Commission's Rules, 47 C. F. R. § 63.18 (1997), Interoute
Telecommunications, Inc. ("Interoute") and American International Telephone, Inc. ("AlT")
(collectively, "Applicants") hereby request authority to effectuate the transfer of control of AlT,
an international carrier, to Interoute. Applicants are non-dominant carriers separately authorized
by this Commission to provide international telecommunications services.
       As fully described herein, approval of the transfer will permit Interoute and AlT to
realize significant economic and marketing efficiencies which will enhance their ability to
continue providing high quality, low cost telecommunications services and to compete more
effectively in the international telecommunications marketplace.       Accordingly, grant of this
Application will benefit the public interest.


       In support of this Application, Applicants submit the following information:
I.     THE PARTIES
       A.      Interoute Telecommunications, Inc.
       Interoute is a privately-held Delaware corporation whose principal office is located at 230
Park Avenue, Suite 1000, New York, New York, 10169. A provider of telecommunications and
consulting services, Interoute has global authority to provide resold and facilities-based
international telecommunications services.'
       Interoute is considered non-dominant under the Commission's Rules. Interoute has no
affiliation, within the meaning of Section 63. 18(h)(1)(i) of the Commission's Rules, 47 C.F.R.
§ 63. 18(h)(1)(i) (1997), with a dominant U.S. or foreign facilities-based carrier.
       Information concerning Interoute' s legal, technical, and financial qualifications to provide
service was submitted with Interoute' s application for Section 214 authorization and is, therefore,
already a matter of record before the Commission.
               B.      American International Telephone, Inc.
       AlT, a Delaware corporation, has global authority to provide resold and facilities-based
     1 Overseas Common Carrier Section 214 Applications Actions Taken, Public Notice, ITC
97-720 (Jan. 9, 1998). Interoute Telecommunications, LLC, the original Section 214 licensee,
was merged with a new corporation formed on May 8, 1998 by Interoute Telecommunications,
LLC' s shareholders known as "Interoute Telecommunications, Inc." The purpose of the merger,
which occurred on May 11, 1998, was to change the company's status from a limited liability
corporation to a C corporation. Commission authorization for this p forma transfer, which
did not involve a change in underlying ownership and control, has already been requested.
In Re Interoute Telecommunications, Inc., Application for Consent to Transfer Control (Sept.
3, 1998); and Letter from Thomas K. Crowe and Elizabeth Holowinski to Troy Taimer at 2
(Nov. 9, 1998). Applicants therefore request that the Commission's determination in this matter
reflect that the transferee in the instant transfer of control is "Interoute Telecommunications,
Inc." and not the original licensee, "Interoute Telecommunications, LLC."
                                                  2


international telecommunications services •2 AlT is considered a non-dominant carrier under the
Commission's Rules. AlT has no affiliation, within the meaning of Section 63. 18(h)(1)(i) of the
Commission's Rules, 47 C.F.R. § 63.18(h)(1)(i) (1997), with a dominant U.S. or foreign
facilities-based carrier.
       Information concerning AlT's legal, technical, and fmancial qualifications to provide
service was submitted with the company's application for Section 214 authorization and is,
therefore, already a matter of record before the Commission.
II.    DESCRIPTION OF TRANSACTION
       On September 10, 1998, Interoute, H. Bruce Bronson, Jr. and AlT entered into a Letter
Agreement ("Letter") whereby Interoute agreed to acquire AlT by purchasing all of its
outstanding shares from AlT shareholders. The Letter provided for an immediate sale of 26%
of the shares of AlT (all of the shares owned by Mr. Bronson and certain other shareholders of
AlT) to Interoute on September 10, 1998.    Subject to the Commission's approval, shareholders
owning approximately 46% of the common stock and all preferred stock will transfer their
shares of AlT to Interoute according to a share purchase agreement expected to be executed in
the near future. Such shareholders will receive a cash payment in return for their interest in
   2 Overseas Common Carrier Section 214 Applications Actions Taken, Public Notice,
Report No. 1-8299, DA 98-780 (April 23, 1998); and Overseas Common Carrier Section 214
Applications Actions Taken, Public Notice, File No. ITC-95-578 (January 17, 1998).
       As part of this transaction, H. Bruce Bronson Jr., an officer and one of the two directors
of AlT, delivered a resignation which was accepted on September 25, 1998. To the extent that
either Mr. Bronson's resignation, effective September 25, 1998, and/or the sale of shares on
September 10, 1998 constitutes a transfer of control, AlT seeks Commission approval ppç p
tunc.
                                                3


AlT.   A definitive closing date has not been set at this time.         Essentially, the proposed
acquisition of AlT by Interoute will result in a transfer of control of AlT to Interoute.
       Upon consummation of the acquisition described herein, the Applicants expect that for
the foreseeable future both Interoute and AlT will continue operating their respective
telecommunications businesses under their current names, and they will continue to provide high
quality, affordable telecommunications services to the public. As such, this merger will not in
any way disrupt service or cause inconvenience or confusion to the customers of AlT. Indeed,
the merger will be virtually seamless to retail customers in terms of the services they currently
receive, but it may make additional products and services available to both Interoute' s and AlT's
customers throughout the country.
       Applicants expect to consummate the acquisition subject to the approval of the
Commission, as well as the U.S. District Court for the Southern District of New York.4
       Applicants request Commission approval for authority to effectuate this transaction,
thereby transferring control of AlT to Interoute.
       Pursuant to a ruling of the U.S. District Courtfor the Southern District of New York
("Court"), AlT is prohibited from selling or disposing of its assets or stock without prior Court
approval.      Order of Hon. Sonia Sotomayor, Index No. 98 Civ. 6123 (Oct. 9, 1998). This
matter stems from a complaint filed on August 28, 1998 by WorldCom, Inc. and WorldCom
Network Services, Inc. (collectively, "WorldCom") for amounts allegedly due to WorldCom
pursuant to a contract to furnish telecommunications services. AlT filed an answer to the
complaint on October 6, 1998 and asserted various counterclaims. Thus, the Applicants will not
consummate the instant transaction until requisite Court approval is obtained.
                                                 4


III.   PUBLIC INTEREST
       Consummation of the proposed transaction will serve the public interest in promoting
competition in the international telecommunications market by providing Interoute and AlT the
opportunity to strengthen their competitive positions by combining their financial resources and
complementary services, facilities and expertise. The transaction creates access, by AlT, to the
larger capital base of its new parent company, Interoute. AlT' s operations will more readily
increase in size and profitability, due to enhanced economies of scale.        Accordingly, the
proposed acquisition will benefit consumers through improved services and lower rates, thereby
promoting competition in the international telecommunications market.
       The Commission recognizes that the international market for switched voice services is
becoming increasingly competitive in nature and that such competition benefits consumers
Given the Commission's desire to foster competition in the international switched services
market, grant of the proposed transaction is in the public interest.
IV.    SPECIFIC PART 63 INFORMATION
       As required by Section 63.18 of the Commission's Rules, Applicants submit the
following information:
      See In Re Rules and Policies on Foreign Participation in the U.S. Telecommunications
Market; Market Entry and Regulation of Foreign-Affiliated Entities, Report and Order and Order
on Reconsideration, 12 FCC Rcd 23891, 23891 (1997)("Foreign Entry Order").
                                                5


(a)   Name and address of applicants:
      Transferee:
      Interoute Telecommunications, Inc.
      230 Park Avenue
      Suite 1000
      New York, New York 10169
      (212) 808-6500
      Transferor:
      American International Telephone, Inc.
      287 Bowman Avenue
      Purchase, New York 10577
      (914) 251-1450
(b)   Interoute is a corporation organized under the laws of the State of Delaware.
      AlT is a corporation organized under the laws of the State of Delaware.
(c)   Correspondence concerning this application should be sent to:
      Thomas K. Crowe
      Elizabeth Holowinski
      Law Offices of Thomas K. Crowe, P.C.
      2300 M Street, N.W., Suite 800
      Washington, D.C. 20037
      (202) 973-2890
      with a copy to:
      Richard Young, Esq.
      Interoute Telecommunications, Inc.
      230 Park Avenue
      Suite 1000
      New York, New York 10169
      (212) 808-6500
      and
                                        6


                Charles Eisenberg, President
                Terry Vidal, Corporate Secretary
                American International Telephone, Inc.
                287 Bowman Avenue
                Purchase, New York 10577
                (914) 251-1450
       (d)      As discussed above, Interoute previously received authority from the Commission
                to provide global facilities-based and resale services.6 AlT received authority
                under Section 214 of the Communications Act to provide global facilities-based
                and resold services.7
       (e)      This Application requests transfer of control of AlT to Interoute.
       (f)      Not applicable.
       (g)      Not applicable.
       (h)      (1)    Interoute has affiliations with foreign carriers in the U.K., France,
                       Germany, Denmark, Netherlands, Switzerland, Portugal and Spain. A list
                       of the names and addresses of Interoute' s foreign affiliates is attached as
                       Exhibit A. AlT is not affiliated, as defined by Section 63.18(h)(1)(i) of
                       the Commission's Rules, 47 C.F.R. § 63.18(h)(1)(i) (1997), with any
                       foreign carriers.
       (h)      (2)    The following entities hold a ten percent (10%) or greater ownership
                       interest in Interoute:
Name/Address                          % Held         Citizenship    Principal Business
Interoute Telecommunications          48.4%          U.K.           Holding Company
  plc
7 Portland Place
London WIN3AA
England
   o         supraatn.1.
             supra at n.2.
                                                 7


Interoute Communications          33.1 %        Bahamian       Holding Company
  Group, Ltd.
Suffrey Square, Suite 205
Bank Lane
P.O. Box N. 8188
Nassau, Bahamas
                    Interoute Telecommunications plc is 100% owned by Interoute
                    Communications Group, Ltd.
                    The following entities hold a ten percent (10%) or greater ownership
                    interest in Interoute Communications Group, Ltd.:
Name/Address                      % Held        Citizenship    Principal Business
Sandoz Family Foundation          50.7%         Swiss          Trust
85 Avenue Generale Guisan
Lausanne, Switzerland
                    An Executive Committee is entrusted with operational management of the
                    Sandoz Family Foundation. The Executive Committee consists of the
                    following individuals:
Name/Address                      Citizenship           Principal Business
Pierre Landolt                    Swiss                 Chairman, Executive Committee
c/o Sandoz Family Foundation
85 Avenue Generale Guisan
Lausanne, Switzerland
Victor Bischoff                   Swiss                 Member, Executive Committee
c/o Sandoz Family Foundation
85 Avenue Generale Guisan
Lausanne, Switzerland
Oskar Flolenweger                 Swiss                 Member, Executive Committee
c/o Sandoz Family Foundation
85 Avenue Generale Guisan
Lausanne, Switzerland
Olivier Verrey                    Swiss                 Member, Executive Committee
do Sandoz Family Foundation
85 Avenue Generale Guisan
Lausanne, Switzerland
                                            8


                    The following entities hold a ten percent (10%) or greater ownership or
                    management interest in AlT:
Name/Address                          % Held       Citizenship     Principal Business
Charles S. Eisenberg                  11 %         U.S.A.         Individual
One Landmark Square
Port Chester, New York 10573
Marand Holdings, LLC                19%            U.S.A.         Holding Company
445 Broad Hallow Road
Melville, New York 11747
                    The following are ten percent or greater shareholders of Marand
                    Holdings, LLC:
Randall S. Appel                   50%             U.S.A.         Individual
445 Broad Hallow Road
Melville, New York 11747
Mans Appel                         50%             U.S.A.         Individual
445 Broad Hallow Road
Melville, New York 11747
      (h)     (3)   Not applicable.
      (h)     (4)   Interoute' s affiliated carriers in the U.K., France, Germany, Denmark,
                    Netherlands, Switzerland, Portugal and Spain own and/or control
                    telecommunications facilities in each of these countries.
      (h)     (5)   Applicants acknowledge that they are responsible for the continuing
                    accuracy of the certifications required herein, and that they will notify the
                    Commission of any change in substance as required by the Commission's
                    rules.
      (h) (6)-(7)   Interoute's affiliated carriers in the U.K., France, Germany, Denmark,
                    Netherlands, Switzerland, Portugal and Spain do not have the ability to
                    discriminate against unaffiliated U.S. international carriers through control
                    of bottleneck services or facilities in any of these countries or in any other
                    destination country to which Applicants will provide service.
                    Additionally, the Commission has found the U.K., France, Germany,
                                               9


                      Denmark, and the Netherlands to be equivalent countries.8
       (h)     (8)    Interoute desires to be regulated as a non-dominant carrier for all of the
                      services included in its 214 Authorization and destination countries
                      including the U.K., France, Germany, Denmark, Netherlands,
                      Switzerland, Portugal and Spain. Interoute' s affiliated carriers do not
                      have the potential to discriminate against unaffihiated U.S. carriers through
                      such means as preferential operating agreements, preferential routing of
                      traffic, exclusive or more favorable transiting agreements, or preferential
                      domestic access and interconnection arrangements. None of Interoute's
                      foreign affiliated carriers are monopoly, duopoly or oligopoly providers
                      of services in their respective home countries. Rather, each of Interoute 'S
                      foreign affiliated carriers are resellers which compete against such
                      carriers. In addition, all of Interoute ' s foreign affiliated carriers control
                      less than fifty percent (50%) of the market share in each of their
                      respective home countries . As such, because Interoute' s foreign carrier
                      affiliates clearly do not have the potential to discriminate against
                      unaffihiated U.S. carriers, Interoute should be regulated as a non-dominant
                      carrier.
       (i)     As required by Section 63.18(i) of the Commission's Rules, 47 C.F.R. § 63. 18(i)
               (1997), Applicants certify that they have not agreed to accept nor shall they
               accept in the future any special concessions, as defined by the Commission's
               Rules, directly or indirectly from any foreign carrier or administration with
               respect to traffic or revenue flows between the U.S. and any foreign country for
               which Applicants may be authorized to serve.
       (j)     Applicants are not subject to a denial of Federal benefits pursuant to Section 5301
               of the Anti-Drug Abuse Act of 1988. Applicants' certifications pursuant to
               Section 1.2002 of the Commission's Rules, 47 C.F.R. § 1.2002 (1997),
               (implementing the Anti-Drug Abuse Act of 1988, 21 U.S.C. § 3301 (1997)) are
               attached.
   8 See Overseas Common Carrier Section 214 Application Actions Taken, Public Notice,
DA 98-1233 at General Condition 8 (June 25, 1998).
        See Foreign Entry Order at 23996 (stating that there is a presumption that U.S. affiliates
of foreign carriers with less than 50% market share in the relevant foreign market should be
regulated as non-dominant).
                                                10


V.     CONCLUSION
       For the reasons stated herein, Interoute and AlT respectfully submit that the public
interest, convenience and necessity would be furthered by grant of this application.
                                                    Respectfully submitted,
                                                    INEEROUTE TELECOMMUNICATIONS,
                                                     INC. AND AMERICAN
                                                     INTERNATIONAL TELEPHONE, INC.
                                                                        Lf
                                                                        '     L
                                                    Thomas K. Crowe
                                                    Elizabeth Holowinski
                                                    LAW OFFICES OF THOMAS K. CR0 WE,
                                                      P.C.
                                                    2300 M Street, N.W.
                                                    Suite 800
                                                    Washington, D.C. 20037
                                                    (202) 973-2890
                                                    COUNSEL FOR INTEROUTE
                                                    TELECOMMUNICATIONS, INC. AND
                                                    AMERICAN INTERNATIONAL
                                                     TELEPHONE, INC.
November 12, 1998
                                               11


11-09-1998 7: dOPM        FROM THOMAS K CROWE 202 973 2891                                                 P_ 11.
                                 CERTIFICATIONS OF APPLICANt
            On behalf of Interoute Telecommunications. Inc., and in accordance with Sections
    1.2001-1.2003 of the Commission's Rules, 47 C.F.R. § 12001-1.2003 (1997), 1 hereby certify
    that neither Interoute Telecommunications, Inc., its officers and directors, or any party with a
    five percent or greater interest in Interoute Telecommunications, Inc., is subject to a denial of
    the Federal benefits requested herein pursuant to Section 5301 of the Anti-Drug Abuse Act of
    1988. ç21 U.S.C § 853(a) (1997). I also hereby certify that the statements in the foregoing
    application are true, complete. and correct to the best of my knowledge and are made in good
    faith.
            Interoute Telecommunications, Inc. has not agreed to accept any concessions directly or
    indirectly from any foreign carrier or administration with respect to traffic or revenue flow
    between the Untied States and various international points under the authority granted under
    Section 214 of the Communications Act of 1934, as amended, and the Commission's Rules, and
    has not agreed to enter into such agreements in the future.
            Pursuant to Section 63.18(h) of the Commission's Rules, 47 C.FR. § 63.18(h) (1997),
    I certify that Interoute Telecommunications, Inc. has an affiliation with foreign carriers in the
    U.K., France, Germany, Denmark, Netherlands, Portugal, Spain and Switzerland. Although
    these affiliates own and control telecommunications facilities, they do not have the ability to
    discriminate against unaffihiated U.S. international carriers through control of bottleneck services
    or facilities in any of the aforementioned countries or in any of the other designation countries
    covered by this application. These affiliates do not have the potential to discriminate against
    unaffihiated U.S. international carriers through such means as preferential operating agreements,
    preferential routing of traffic, exclusive or more favorable transiting agreements, or preferential
    domestic access and interconnection arrangements                 I further certify that Interoute
    Telecommunications, Inc. does not have an affiliation with any U.S. carrier whose facilities-
    based services Interoute Telecommunications, Inc. proposes to resell, either directly or
    indirectly.
                                          INTEROUTE TELECOMMUNICATIONS, INC.
                                          By:
                                          Name:                  JtC1LL2           ze
                                          Titie:
                                          Date:                                       LW


                            CERTIFICATIONS OF APPLICANT
       On behalf of American International Telephone, Inc. ("AlT"), in accordance with
Sections 1.2001-1.2003 of the Commission's Rules, 47 C.F.R. § 1.2001-1.2003 (1997), I
hereby certify that neither AlT, its officers and directors, or any party with a five percent or
greater interest in AlT is subject to a denial of Federal benefits requested herein pursuant to
Section 5301 of the Anti-Drug Abuse Act of 1988.             21 U.S.C. § 853(a) (1997). I also
hereby certify that the statements in the foregoing application are true, complete, and correct to
the best of my knowledge and are made in good faith.
        AlT has not agreed to accept any concessions directly or indirectly from any foreign
carrier or administration with respect to traffic or revenue flow between the Untied States and
various international points under the authority granted under Section 214 of the Communications
Act of 1934, as amended, and the Commission's Rules, and has not agreed to enter into such
agreements in the future.
                                     AMERICAN INTERNATIONAL TELEPHONE, INC.
                                     By:
                                                          /     /                   I
                                                      /-       (         r7.   i
                                     Name:            I                  fri   tc
                                     Title:                   rcr /e                ('/   /c ry
                                     Date:                          Qr         O          /99




                                        EXHIBIT A
                           INTEROUTE'S FOREIGN AFFILIATES
Interoute Denmark A/S                          Interoute SA
Smedahoim 13C                                  36 Avenue Cardinal-Mermilled
DK - 2730 Herley                               1227 Carouge
Denmark                                        Switzerland
tel: +45 44 53 22 00                           tel: +41 22 827 00 00
Interoute Communications France                ITS
16 - 18 Rue Rivay                              Interoute Telecommunications Services
92300 Levalloie - Perret                       63-65 Berners St.
France                                         London W1P3AE
tel: +33 1 55 46 57 00                         England
                                               tel: +44 171 323 4902
Interoute Telecom Deutschland GmbH
Lyoner Strasse 15                              Gateway
D - 60528                                      Interoute Telecommunications (U.K.) Ltd.
Frankfurt en Main                              7 Portland Place
Germany                                        London WIN3AA
tel: +49 69 66 98 38 0                         England
                                               tel: +44 171 299 7000
Interoute Netherlands BY
World Trade Center
Strawinskyiaan 919
1077 XX
Amsterdam
The Netherlands
tel: +31 20 47 10 616
Geolink
Prmon Duque de Saldanha
No 1 - 10 D
1050 Lisboa
Portugal
tel: +351 1 319 19 00
Interoute Telecomunicaciones (Viacom)
Vias de Comunicaciones SA
C/Acanto, 22 14-I
28045 - Madrid
Spain
tel: +34 1 467 67 51


                                CERTIFICATE OF SERVICE
        I, Melissa Sheehy, a paralegal with the Law Offices of Thomas K. Crowe, P.C., certify
that on November 12, 1998, a copy of the foregoing Application was served by first class U.S.
mail, postage prepaid, on the parties listed below.
Deputy Assistant Secretary of                     Troy Tanner
 Defense (Telecommunications)                     Chief, Policy and Facilities Branch
Office of the Assistant Secretary                 International Bureau, Telecommunications
 of Defense                                       Division
Pentagon, Room 3E160                              Federal Communications Commission
Washington, D.C. 20401                            2000 M Street, N.W.
                                                  Room 800
National Security Agency                          Washington, D.C. 20554
G042, NSA, EMC Center
Room 1C166                                        Francis Eisenstein
9800 Savage Road                                  International Bureau, Telecommunications
Fort George Meade, MD 20755                       Division
                                                  Federal Communications Commission
U.S. Coordinator and Director                     2000 M Street, N.W.
Office of International Communications            Room 843
 Policy (EB-TD)                                   Washington, D.C. 20554
Department of State
21st and C Streets, N.W.
Washington, D.C. 20305-2000
Attn: Code 15
Chief Regulatory Counsel
Defense Communications Agency
Washington, D.C. 20305-2000
Attn: Code 115
National Telecommunications and
 Information Administration
14th & Constitution Ave., N.W.
Room H4717
Washington, D.C. 20320



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Document Modified: 0000-00-00 00:00:00

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