Attachment 20161208144617-563.p

20161208144617-563.p

SUPPLEMENT

Supplement

2000-05-15

This document pretains to ITC-T/C-20000515-00317 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2000051500317_1380594


KELLEY DRYE & WARREN cur A LIMITED LIABILITY PARTNERSHIP 1200 I9"" STREET, N.W. NEW YORK, NY SsUITE 500 “N\fi FACSIMILE Los ANGELES, ca (202) ass—9792 wasHington, p.c. 20036 \_\‘Q\\ CHICAGO, IL STAMFORD, CT (202) 955—9600 gt® %\, ce PARSIPPANY, NJ BRUSSELS, BELGIUM HONG KONG AFFILIATE OFFiCES IVIay 12, 2000 BANGKOK, THAILAND JAKARTA, INDONESIA MANILA, THE PHILIPPINES MUMBAI, INDIA TOKYO, JAPAN Federal Communications Commission International Bureau — Telecommunications P.O. Box 358115 Pittsburgh, PA 15251—5115 Re: In the Matter of World Access, Inc. and Communications TeleSystems International d/b/a WorldxChange Application for Authority to Transfer Control of a CommonCarrier Holding an International Section 214 Authorizations And to Assign the Carrier‘s Section 214 Authorizations to A Surviving Corporation Dear Sir or Madam: On behalf of World Access, Inc. and Communications TeleSystems International d/b/a WorldxChange, enclosed for filing an original and five copies of the above— referenced Application. Also enclosed for this filing are the FCC Form 159 Remittance Advice, a check in the amount of $780.00 to cover the filing fee, and a duplicate copy of the filing. Please date—stamp the duplicate and return to the courier. If there are any questions regarding this filing, please contact me at (202) 955—9786. Thank you for your assistance with this matter. Sincerely, an M. Griffin Enclosures DCO1/GRIFJ/112431.1

APPROVED BY OMB 3060—0589 BEFORE PROCEEDING FEDERAL COMMUNICATIONS COMMISSION REMITTANCE ADVICE t ",’f‘E" PAGE NO. 1 OF 2 LOCKBOX # name as appears on your Kelley Drye & Warren LLP 7 § 1200 19th Street, N.W. Suite 500 Wash in DC 20036 (202) 955—9600 ~NAME ‘ IF MORE—THAN ONE ICANT, USE CONTINUATION SHEETS ( name as appears on your World Access, Inc. Resurgens Plaza, Suite 2210 945 East Paces Ferry Road Atlanta GA 30326 area not 404—261—6190 COMPLETE SECTION C FOR EACH SERVICE, IF MORE BOXES ARE NEEDED, USE CONTINUATION SHEETS 80 .00 AYER TIN o|1 |3 CANT TIN 1 oan * riffin , Certify under penalty of perjury that the and supporting information (PRINT NAME) true and correct to the best of my knowledge, infomation and belief. SIGNATURE ——»> hereby suthorize the FCG to charge my VISA or MASTERCARD service(s/authorizations(s) herein described.

FEDERAL COMMUNICATIONS COMMISSION APPRoVED BY OMB —3080—0589 I m eempmromnrmemnmmenmeemniom REMITTANCE ADVICE (Continuation Sheet) — _ s PaAGE No. _2 __or__2__ USETHIS SECTION_ONLYEOR_EACH ADDITIONAL APPLICANT—___ - SECTION BB — ADDITIONAL APPLICANT INFORMATION 11) APPLICANT NAME{if paying by credit card, enter name exactly as it appears on your card) Communication TeleSystems International: d/b/a. WorldxChange‘ §12) STREET ADDRESS LINE NO. 1 9999 Willow Creek Rd. fis) street Aporess LINE No. 2 K14 crrty (15) STATE (16) zip cope Sn plegs CA _ 92131 + [i(17) DAYTIME TELEPHONE NUMEER (Include area code} ((18) COUNTRY CODE (if not in U.S.A.) 858—547—5400 iE MORE BOXES ARE NEEDED, USE ADDITIONALFGC159:CCONTINUATIONSHEETS: - SECTION CC — PAYMENT INFORMATION f 19A) FCCCALL SIGNIOTHER ID I PTPE ’Hfl lwfl aUANTIY [22a) Fee oue ror (.I’TC) IN BLOCK 20A $ (234) FCC CODE 1 (24A) FCC CODE 2 f198) FCC CALL SIGN/OTHER ID (208) PAYMENT TYPE CODE (PTC) (218) auantiTy (228) FEE oue FoR (PTC) IN ELOCK 208 Fec.use oNLy e cs oo 0. s .l . ..z 3 f238) roc cone 1 (248) Fec cone 2 — coomenenemeemee :: 19) FCC CALL SIGN/OTHER ID (20C) PAYMENT TYPE CODE(PTC) (21C) QUANTITY [22c) FEE UE FOR (PTC) IN BLOCK 20C |FCC use OLY: 1.oo 0 uic l $ (K23¢) FCC Cope 1 (24C) FCC CODE 2 Htao) ree catt sienforneR i0 (20D) PAYMENT TYPE CODE (PTC) (21D) aUaANTITY (220) FEE DUE FOR (PTC) IN BLOCK 200 Eceuse onty 500 .0 — s asd 33 fls EZ:BD) FCC CODE 1 (24D) FCC CODE 2 SECTION DD — TAXPAYER INFORMATION — (25) COMPLETE THIS BLOCK ONLY IF SECTION BB IS APPLICABLE APPLICANT TIN 0 FCC FORM 159—C JULY 1997(REVISED) reset form

KELLEY DRYE & WARREN LLP 006091 1200 19TH STREET, N.W. WASHINGTON, DC 20036 15—122/540 BRANCH 00480 pate _May 5, 2000 M PAY i‘y TO THE it rommnpsmms |° onper or Federal Communications Commission ) $ i780.00 & $ E > Security teatures i° Seven Hundred Eighty And No/100 : — — DOLLARS is frpttsDuptnih o First Union National Bank F N R/T 054001220 (%;xfi:z; . *4 ©0000609 1 —20 54001220120000 31.5465 L3 3u- DETACH AND RETAIN THIS STATEMENT THE ATTACHED CHECK IS IN PAYMENT OF ITEMS DESCRIBED BELOW, IF NOT CORRECT PLEASE NOTFY US PROMPTY, NO RECEIPT DéS ED. KELLEY DRYE & WARREN LLP DATE DESCRIPTION A AOUNT 5/5/00 Filing Fee for Section 214 transfer of control ap»licai:ion $780 .00

Befor : the FEDERA L CCMMUNIC\TIO NS COMMISSION V/ashi igton, D.C. 20554 In the Matter 0:‘ Ns Nus! Nun! Num! Ne Nun! Nn N) Nus! Nus! Nus! WORLD 4CCISS, INC. AND File No. COMMUNICA TIONS TELE sSYST EMS INTERN@TIONAL d/b/a WORLD XCH |NGT Application for Authority to T ransfer Control 0‘ a Common Carrier Hold ng an I itern:iitional Section 214 A uthorizatio as anl to Assign che Ciurrier‘s Sectior. 214 Autiiorizations to a Surviving Corporatio 1 AP PLIC ATION I. Introduction World A :scess, Inc. ("World Ascess" ) and : Somn unicaiion TeleSystems International d/b/a WorldxChange ("WorldxChange") (eccllectr ely, t ie "Applicar ts"), by their attorneys and pursuant to Section 214 0: the Communications Act cf 193« , as ainende1 ("the Act"), 47 U.S.C. § 214, and Sect on 63.18(c) 3) of the Commission‘s Ru es, 4, C.F.I. § 62.18(c)(3), hereby request authority to (1) trans fer control of WorldxChange to Vorld . \cces::, and 2) assign WorldxChange‘s authorizations to a surviving corporation, as described herein. IL. Description of Transaction WorldxChange is a global telecommunications company that specializes in providing high—quality, low—cost services to retail and wholesale customers in 13 countries, including the United Kingdom, Germany, the U.S., France, the Netherlands, Belgium, Chile, Guatemala, Australia, Canada, and New Zealand. The Company operates 45 switches, which are connected DCOL/GRIFJ/111272.1

by an extensive network of owned and leased undersea and land—based fiber optic cables. WorldxChange is a California corporation based in San Diego, California. At present, WorldxChange holds numerous Section 214 authorizations, as well as several cable landing licenses and an earth station license, and is regulated as a non—dominant carrier on all routes.‘ World Access is a leading provider of bundled voice, data and Internet services to key regions of the world. Through its licensed subsidiaries, World Access competitively provides end—to—end voice and data communications services including frame relay, IP, ATM, and multimedia applications via its redundant digital network. World Access‘ network backbone consists of gateway and tandem switches that are strategically located throughout the U.S. and 13 European countries and are linked by an extensive fiber network. World Access is a Delaware corporation that is based in Atlanta, Georgia. Its subsidiaries hold numerous Section 214 and cable landing licenses, and are subject to non—dominant regulatory treatment onall routes. The Applicants note that World Access has recently entered into an agreement to purchase STAR Telecommunications, Inc. ("STAR") and that appropriate applications to transfer control of STAR‘s authorizations and licenses are currently pending before the Commission.‘ World Access and WorldxChange have determined that their current business operations are complementar}f and that significant economies of scale, as well as other marketing and managerial benefits, would be achieved by the merger of World Access and WorldxChange. For this reason, the Applicants have entered into a merger agreement whereby the shareholders of Applications to transfer the cable landing and earth station licenses are being filed concurrent with the submission of this Application. 2 See Applications in File Nos. ITC—T/C—20000412—00225 and SCL—T/C—20000412—00014. DCO1/GRIFJ/111272.1 2

WorldxChange will receive approximately 31 million shares of World Access common stock, subject to adjustment under certain circumstances. In addition, World Access will assume approximately $225 million in WorldxChange debt. The merger will be accomplished by merging WorldxChange with and into WorldxChange Communications, Inc. ("WorldxChange Communications"), a Delaware corporation that is wholly—owned subsidiary of World Access and that was formedto effectuate the acquisition. Following the merger, the current business of WorldxChange will be conducted through WorldxChange Communications. Thus, WorldxChange Communications will hold and will continue to provide service under WorldxChange‘s existing licenses andauthorizations. III. Regulatory Treatment and Application Processing WorldxChange is affiliated with foreign carriers in the United Kingdom, Germany, Fran«;e, the Netherlands, Belgium, Chile, Guatemala, Australia, Canada, New Zealand, Italy, Spain, and Sweden. However, the Commission regulates WorldxChange as a non—dominant carrier on all of these routes, because each foreign affiliate holds significantly less than a fifty percent market share in the international transport and local access markets in its respective home country. Similarly, World Access is affiliated with foreign carriers in Austria, Belgium, Denmark, El Salvador, Finland, France, Germany, Guatemala, Hong Kong, Italy, Japan, the Netherlands, Norway, Portugal, Spain, Sweden, Switzerland, and the United Kingdom. No World Access foreign affiliate holds a fifty percent or greater market share in its respective market and thus World Access is regulated as a non—dominant carrier on all routes as well." All of the countries in which World 3 STAR is also regulated as a non—dominant carrier on all routes on which it is or is affiliated with a foreign carrier. Those routes are Canada, Germany, the United DCOL/GRIFJ/111272.1 3

Access and WorldxChange are affiliated with a foreign carrier are members of the WTO. Following consummation of the proposed transaction, World Access will control WorldxChange‘s Communications‘ foreign affiliates, and WorldxChange Communications will becomeaffiliated with World Access‘ foreign carrier subsidiaries.* However, the regulatory classification of World Access and WorldxChange Communications should remain unchanged. Since no foreign affiliate will havea greater than 50 percent market share post—merger," World Access and its licensed subsidiaries, including WorldxChange ’Communicatioins, are entitled to a presumption of non—dominant treatment under Section 63.10(a)(3) of the Commission‘s Rules. Streamlined processing is appropriate for this Application under Section 63.12(c)(1)(ii) of the Commission‘s Rules, since the Applicants are entitled to a presumption of non—dominant treatment post—merger. IV. Section 63.18 information Pursuant to Section 63.18 of the Commission‘s Rules, the Applicants set forth the following information in support of this Application. (a) The name, address, and telephone number of the Transferor/Assignor is: Communication TeleSystems International d/b/a WorldxChange 9999 Willow Creek Rd. San Diego, CA 92131 (858) 547—5400 Kingdom, and Japan. * If the FCC grants the transfer of control application for World Access and STAR, WorldxChange will become affiliated with STAR‘s foreign carrier affiliates as well. This is true even if World Access consummates its proposed merger with STAR. DCO1/GRIFJ/111272.1 4

The name, address, and telephone number of the Transferee is: World Access, Inc. Resurgens Plaza, Suite 2210 945 East Paces Ferry Road Atlanta, Georgia 30326 (404) 261—6190 The name, address, and telephone number of the Assignee is: WorldxChange Communications, Inc. Resurgens Plaza, Suite 2210 945 East Paces Ferry Road Atlanta, Georgia 30326 (404) 261—6190 (b) World Access and WorldxChange Communications are corporations organized under the laws of the state of Delaware. WorldxChange is a corporation organized under the laws of California. (c) Correspondence concerning this Application should be sent to: Richard Heidecke, Esq., L.C.E. World Access, Inc. 1919 South Highland Suite 129, Building D Lombard, Illinois 60148 Tel: (630) 268—6620 Fax: (630) 268—6898 Eric G. Lipoff, Esquire Communications TeleSystems International d/b/a WorldxChange 9999 Willow Creek Drive San Diego, CA 92131 Tel: (858) 547—5400 Fax: (858) 452—3780 With copies to: DCO1/GRIFJ/111272.1 n

Danny E. Adams Joan M. Griffin Kelley Drye & Warren, LLP 1200 19th Street, NW Washington, DC 20036 (202) 955—9600 (d) A list of the Applicants‘ Section 214 authorizations is provided in Attachment 1. (e) The Applicants are applying for transfer of control and assignment of license authority pursuant to Section 63.18(e)(3) of the Commission‘s Rules. (£) No response required. (g) No response required. (h) WorldxChange Communications is a wholly—owned subsidiary of World Access. The name, address, citizenship, andprincipal businesses of World Access‘s ten percent or greater shareholders are as follows: Name: Armstrong Group Address: 1 Armstrong Place Butler, Pennsylvania 16001 Citizenship: United States Principal Business: Investment Percentage Interest: 16.4% The name, address, citizenship, and principal businesses of Armstrong Group‘s ten percent or greater shareholders are as follows: Name: Jud L. Stedwick Grandchildrens‘ Trust Address: 1 Armstrong Place Butler, Pennsylvania 16001 Citizenship: United States Principal Business: Investment Percentage Interest: 100% There are no 50 percent or greater owners of the Jud L. Stedwick Grandchildrens‘ Trust. Lawrence C. Tucker is a director of both World Access and MCI WorldCom, Inc. John D. Phillips and W. Tod Chmar both are directors of World Access and World Access Telecommunications Group Limited. Dennis Bay is a director of both World Access Telecommunications Group, Inc. and World Access Telecommunications Group Limited. Walter J. Burmeister, President of World Access and a director of FaciliCom International DCO1/GRIFJ/111272.1

LLC, is also: President Director of FaciliCom International SA de CV (El Salvador); President of the Board of Directors of FaciliCom International Guatemala; Chairman of the Board of Call One B.V. (Netherlands); Director of FaciliCom International SARL (Switzerland), FaciliComInternational (Hong Kong) Limited, FaciliCom International K.K. (Japan), and FaciliCom International BVBA/SPRL (Belgium); and a Member ofthe Management Committee of FaciliCom International (UK) Limited. William Gerety, Chief Operating Officer of FaciliCom International LLC, is also: Chairmanof the Board of Directors of FaciliCom International A/S (Denmark), FaciliCom Finland OY, FaciliCom International AS (Norway), and FaciliCom International Sweden AB; Director of FaciliCom International S.R.L. (Italy); and Sole Member of the Board of FaciliCom International B.V. (Netherlands). . G).) Information on foreign affiliations post—mergeris contained inthe certification provided in Attachment 2. (1), (m) Since no foreign affiliate will have a greater than 50 percent market share post—merger, World Access and its licensed subsidiaries, including WorldxChange Communications, are entitled to a presumption of non—dominant treatment under Section 63.10(a)(3) of the Commission‘s Rules. (n) As evidenced by the certification provided in Attachment 2, neither World Access nor WorldxChange Communications has agreed to accept special concessions directly or indirectly from any foreign carrier with respectto any U.S. international route where the foreign carrier possesses sufficient market power on the foreign end of the route to affect competition adversely in the U.S. market, and neither World Access nor WorldxChange Communications will enter into such agreements in the future. (0) As evidenced by the certification provided in Attachment 2, no party to this Application is subject to a denial of federal benefits pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988. (p) World Access requests streamlined processing pursuant to Section 63.12(c) of the Commission‘s Rules. Streamlined processing is appropriate for this Application under Section 63.12(c)(1)(ii) of the Commission‘s Rules, since the Applicants are entitled to a presumption of non—dominant treatment post—merger. DCO1/GRIFJ/111272.1 J

barti en qA aicc h a + E2t at M bebst ib B COAUHU Y CS d oa sduze epay V. Conclusion For these reasons, the Applicants request thiit the Co. nmission process and grart t is Application as quickly as possible. Respectfully Submitte 1, WoORrLD AccCEss, INC. COMMUNICATION TELESYSTEMS INTERNATIONAL D/B/A WORLDXC HANGE By: By: W&I Richard Heidecke, Esq. L.C.E. Edward S. Soren World Access, Inc. Executive Vice President 1919 South Highland Communications TeleSystems Suite 129, Bldg. D International d/b/a WorldxChange Lombard, Illinois 60148 9999 Willow Craek D—ive: (630) 268—6620 San Diego, CA 32031 (858) 547—5400 Danny E. Adams Joan M. Griffin Kelley Drye & Warren LLP 1200 19th Street, N.W. Suite 500 Washington, D.C. 20036 (202) 955—9600 Its Attorneys Date: 5//0[00 1 DCOUVGRIFI/111272.1

©5/09/2000 16:1>2 5302686899 WORLD ACccESS TELECO M PAGE 27 V. Conclusion For these reasons, the Applicants request that tie Commission process ind griint this Application is quickly as possible. Respectfully Sut mitted, WORLD AccEss, Inc. COMMUNICATION TELES¥«TEMS INTERNATIONAL D/B/Aa WonLbpxCHaAnNGE By: O _{leGGa ce «£.6C.€. By: _ Richard Heigecks, Esq. LC.E. Edward 5. Soren Wonld Access, Inc. Executive Vice President 1919 South Highland Communications TeleSystems Suite 129, Bidg. D International W/b/a WorldxChange Lombard, Minois 60148 9999 Willow Creek Drive (630) 268—6620 San Diego, CA 92131 (858) 547—5400 Danny E. Adams Joan M. Griffin Kelley Drye & Warren LLP 1200 19th Street, N.W. Suite 500 Washington, D.C. 20036 (202) 955—98500 Its Attorneys Date: _ 5_/O qC DCOVGRIFJ/111272.1 8

Attachment 1 Existing Section 214 Authorizations of the Applicants WorldxChange WorldxChange currently holds the following Section 214 authorizations. The Applicants seek authority to transfer these authorizations as well as any other authorizations that may be held by WorldxChange. 1. Resale of switched services, File No. ITC—93—023; 2. Facilities—based switched and private lines services via satellite, File No. ITC—94—217; Facilities—based switched and private lines services via PTAT—1 cable, File No. ITC— 94—476; Facilities—based switched and private lines services via multiple cables, File No. ITC— 95—058; Resale of private line for switched services to Sweden, File No. ITC—95—116; MAYA—I cable, File No. ITC—214—19990325—00153; Facilities—based switched and private lines services via Columbus—III cable, File No. ITC—98—437; AMERICAS—II cable, File Nos. ITC—98—342 and ITC—98—342A; Pan American Cable System, File No. ITC—97—221; 10. Resale services to New Zealand, File No. ITC—95—444; 11. Circuits on Russia Express II satellite, File No. ITC—96—634; © 12. AMERICAS—I and Taino—Caribe Cable Systems, File No. ITC—94—475; 13. Global facilities—based and resale authority, File No. ITC—98—333; 14. ISR to the U.K., File No. 95—115; 15. Resale of private lines to Finland, File No. 95—143; 16. ISR to Canada, File No. 94—402. DCOL/GRIFJ/111272.1

World Access World Access, through licensed subsidiaries, holds numerous Section 214 authorizations to provide global facilities—based and resold switched services. See File No. ITC—96—378 (licensed to World Access Telecommunications Group, Inc. ("WAXS"), an indirect, wholly owned subsidiary of World Access) (originally granted to Cherry and transferred to WAXS, see File No. ITC—T/C—19980811—00555). In addition, World Access has recently entered into an agreement to purchase STAR; appropriate applications to transfer control of STAR‘s Section 214 authorizations are currently pending before the Commission. See Applications in File Nos. ITC— T/C—20000412—00225 and SCL—T/C—20000412—00014. Information concerning World Access authorizations will be provided upon request. DCO1/GRIFJ/111272.1 2

Attachment 2 CERTIFICATE I hereby certify to the following: 1. Foreign Carrier Affiliates. World — Access, Inc. ("World Access") is affiliated with and controls the following foreign carriers in the following countries: Country Carrier Austria FaciliCom Telekommunikation GmbH NETnet Austria Belgium FaciliCom International BVBA/SPRL Denmark FaciliCom International A/S LDI Denmark ApS El Salvador FaciliCom International SA de CV Finland FaciliCom Finland OY France FaciliCom International, SARL NETnet Telecom SA Germany FaciliCom Telekommunikation GmbH LDI Telecommunikations GmbH NETnet Germany NewTel Communications GmbH Guatemala FaciliCom International Guatemala Hong Kong FaciliCom International (Hong Kong) Limited Italy FaciliGCom International S.R.L. LDI SpA NETnet Italy DCOL/GRIFJ/111272.1

Japan FaciliCom International K.K. Netherland _ Call One B.V. FaciliCom International B.V. Norway FaciliCom International AS NETnet Norway Portugal FaciliCom International Telecommunicacoes, LDA Spain FaciliCom International SL Dynamic Telecom de Espana Sweden FaciliCom International Sweden AB NETnet International AB (former knownas NETnet Europe) NETnet Sweden NETcenter PhoneLine Sweden AB (formerly known as Cruisetel— AB) Switzerlan FaciliCom International SARL NETnet Switzerland United Kir om Central Cellphone Ltd. FaciliCom International (UK) Ltd. LDI Southern Europe LDI Communications Ltd. LDI Ltd. LDI UK Ltd. Speedial Newgate Communications World Access Telecommunications Group Limited Following its planned merger with STAR Telecommunications, Inc., World Access will also become affiliated with and control the foreign carrier affiliates of STAR, which include: (1) STAR Telecommunications, Inc. itself, which is licensed as a carrier in Canada; (2) STAR Telecommunications Deutschland GmbH, a carrier licensed in Germany; (3) STAR Europe Ltd., a carrier licensed in the United Kingdom; (4) PT—1 Communications UK Ltd., a carrier licensed in the United Kingdom; PT—1 Canada, Inc., a carrier licensed in Canada; and (5) ITO Telecom, Inc., a carrier licensed in Japan. Following its planned merger with WorldxChange, World Access will also become affiliated with and control the foreign carrier affiliates of WorldxChange DCO1/GRIFJ/111272.1 2

Communications, which include: Country Carrier Australia WorldxChange Pty., Ltd. Belgium WorldxChange B.V.B.A. Canada WorldxChange Communications, Inc. Chile WorldxChange Communications S.A. France WorldxChange Communications SA ACC Long Distance France SARL Germany WorldxChange Communications GmbH ACC Telekommunikation GmbH Guatemala WorldxChange Communications S.A. Italy ACC Telecom SRL Netherlands WorldxChange B.V. New Zealand WorldxChange Limited Spain WorldxChange Spain, SL Sweden WorldxChange AB United Kingdom ACC Long Distance UK Limited WorldxChange Communications Ltd. Austria, Australia, Belgium, Canada, Chile, Denmark, El Salvador, Finland, France, Germany, Guatemala, Hong Kong, Italy, Japan, the Netherlands, New Zealand, Norway, Portugal, Spain, Sweden, Switzerland, and the United Kingdom are members of the World Trade Organization. Special Concessions. Neither World Access nor WorldxChange Communications has agreed to accept special concessions directly or indirectly from any foreign carrier with respect to any U.S. international route where the foreign carrier possesses sufficient market power on the foreign end of the route to affect competition adversely in the U.S. DCO1/GRIFJ/111272.1

~~/ 777 2900 16;1]2 53026856899 WORLD AcoEse TELECOM PAGE 33 market and neither World Access nor WorldxChange Communications will enter into such agreements in the future. 3. Anti—Drug Abuse Act Certification. In accordance with the Anti—Drug Abuse Act of 1988, 21 U.S.C. § 862, and Sections 1.2001—1.2003 of the Commission‘s Rules, 47 C.F.R. §§ 1,.2001—1.2003, neither World Access, Inc. nor any other party to this applic ation is subject to a denial of U.S. federal benefits pursuant to Section 5301 ofthe Anti— )rug Abuse Act of 1988. World Access, Inc. Date: figf‘/_g_,}_aa 2 DCOVGRIPI111272.) 4 ~— rew *k TOTRL PQGE 45»ork


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