Attachment Letter

This document pretains to ITC-T/C-20060406-00226 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2006040600226_495096

Chin Kyung Yoo 1776 K STREET NW April 14, 2006 202.719.3581 WASHINGTON, DC 20006 cyoo@wrf.com PHONE 202.719.7000 FAX 202.719.7049 Virginia Office VIA ECFS 7925 JONES BRANCH DRIVE SUITE 6200 Marlene Dortch McLEAN, VA 22102 Secretary PHONE 703.905.2800 Federal Communications Commission FAX 703.905.2820 445 12th Street, SW Washington, DC 20554 www.wrf.com Re: Applications for Consent to the Transfer of BellSouth Corporation to AT&T Inc., WC Docket No. 06-74, File Nos. SCL-T/C- 20060331-00003, ITC-T/C-20060406-00226 Dear Ms. Dortch: BellSouth Corporation (“BellSouth”), by counsel, hereby submits additional information to update the above-referenced applications (“Applications”), pursuant to Section 1.65 of the Commission’s rules.1 Specifically, this letter advises the Commission that BellSouth’s wholly owned subsidiary, BellSouth Long Distance, Inc., (“BSLD”) holds a Class B license issued by the Canadian Radio-television and Telecommunications Commission for the provision of international telecommunications services in Canada on a resale basis. Therefore, BSLD is a “foreign carrier” in Canada, as that term is defined in Section 63.09 of the FCC’s rules.2 A description of this foreign carrier affiliation was inadvertently omitted from the Applications. This additional information specifically affects the Description of Transaction, Public Interest Showing and Related Demonstration (submitted via ECFS in Docket No. 06-74) (“Public Interest Statement”), the application to transfer control of BellSouth’s cable landing licenses (SCL-T/C-20060331-00003) (“Cable Landing License Application”), and the lead international Section 214 application (ITC-T/C-20060406-00226) (“Lead International Section 214 Application”).3 The changes are described below. 1 47 C.F.R. § 1.65. 2 See 47 C.F.R. § 63.09. 3 The other international Section 214 applications filed in conjunction with the BellSouth- AT&T merger incorporate Attachments 1 and 2 of the Lead International Section 214 Application by reference. As described below, only Attachment 1 of the Lead International Section 214 Application is affected by the additional information provided in this letter.

Marlene Dortch April 14, 2006 Page 2 • The first two sentences in the first paragraph of Section VI.E (page 110) of the Public Interest Statement should be replaced with the following (revised text in italics): The merger will not reduce competition in international telecommunications traffic or otherwise adversely affect that already competitive segment of the telecommunications industry. BellSouth’s wholly owned subsidiary, BellSouth Long Distance, Inc., (“BSLD”) holds a Class B license issued by the Canadian Radio-television and Telecommunications Commission for the provision of international telecommunications services in Canada on a resale basis. Apart from its interest in BSLD, which provides a minimal amount of services on the U.S.-Canada route, BellSouth has no other holdings in foreign carriers.382 BellSouth does not hold an equity interest in any satellite provider, and its international facilities are limited to small equity interests in two international submarine cables and an IRU in 12 miles of a third submarine cable.383

Marlene Dortch April 14, 2006 Page 3 • The following paragraph should be added to the Cable Landing License Application: o At the end of Section I.(8)(i) (page 9): In addition, BSLD holds a Class B license issued by the Canadian Radio-television and Telecommunications Commission for the provision of international telecommunications services in Canada on a resale basis. Therefore, BSLD is a “foreign carrier” in Canada, as that term is defined in Section 63.09 of the FCC’s rules, 47 C.F.R. § 63.09. • The following paragraph should be added to Attachment 1 of the Lead International Section 214 Application: o At the end of the Answer to Question 14 – Section 63.18(i) (page 5): In addition, BellSouth Long Distance, Inc. (“BSLD”) holds a Class B license issued by the Canadian Radio-television and Telecommunications Commission for the provision of international telecommunications services in Canada on a resale basis. Therefore, BSLD is a “foreign carrier” in Canada, as that term is defined in Section 63.09 of the FCC’s rules, 47 C.F.R. § 63.09. Per discussions with the International Bureau, BellSouth is enclosing a corrected Attachment 1 to the Lead International Section 214 Application for uploading to the International Bureau Filing System.

Marlene Dortch April 14, 2006 Page 4 Please contact the undersigned counsel with any questions. Respectfully submitted, ____/s/________________ Peter D. Shields Chin Kyung Yoo Counsel for BellSouth Corporation cc (via first class U.S. mail): U.S. Coordinator, EB/CIP U.S. Department of State 2201 C Street, N.W. Washington, D.C. 20520-5818 Office of the Chief Counsel/NTIA U.S. Department of Commerce 14th Street and Constitution Avenue, N.W. Washington, D.C. 20230 Defense Information Systems Agency Code RGC 701 S. Courthouse Road Arlington, VA 22204


Document Created: 2006-04-14 16:01:34
Document Modified: 2006-04-14 16:01:34
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