Attachment Attachment

Attachment

LETTER submitted by America Movil

Letter filed

0000-00-00

This document pretains to ITC-T/C-20060510-00269 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2006051000269_504948

WILLKIE FARR & GALLAGHER n Psc3 h Ki Em o ds Sower, NM Wishimoon, DX 20006 1208 WF Teh: 207 03 1008 G [us. 202 303 20u0 June 8, 2006 Via Hand Delivery RECEIVED Ms. Marlene H. Dortch JUN — 8 2006 Secretary Federal Communications Commission Federal Communications Commisston 445 12th Street, S.W., TW—A325 Office of Secretary Washington, DC 20554 Re: Combined Application for Consent to the Transfer of Control of Telecomunicaciones de Puerto Rico, Inc., Holder of Domestic and International Section 214 Authorizations, from Verizon Communications Inc. to América Movil, S.A. de C.V. File No. ITC—T/C—20060510—00269 Dear Ms. Dortch: Pursuant to the request of the staff of the International Bureau, América Movil, S.A. de C.V. ("América Movil"), by its undersigned counsel, hereby supplements the information provided in the above—referenced application by stating the following: In response to Question 17 on the International Section 214 Authorization Application for Transfer of Control, América Movil certified that it agreed to comply with the "dominant carrier safeguards in Section 63.10 (c) & (e) of the Commission‘s rules in the provision of international service" between the United States and Mexico, Brazil, Guatemala, Nicaragua, El Salvador. In the narrative accompanying that question, América Movil noted that several of its affiliates are presumed by the Commission to possess market power in those markets. América Movil wrote: "[wlith respect to the U.S.—Mexico, U.S.—Guatemala, U.S.— Nicaragua, and U.S.—El Salvador routes . . . América Movil will comply with the Commission‘s rules applicable to carriers affiliated with foreign carriers that the Commission considers dominant under its rules . . .." América Movil inadvertently did not include the U.S.—Brazil route in this sentence, though it did acknowledge earlier in the narrative that its affiliate Embratel is presumed to possess market power in Brazil, and it did list the Brazil route on the Application as one of the routes for which it agrees to comply with "dominant carrier safeguards." This omission was inadvertant. With regard to the U.S.—Brazil route, América Movil will comply with the Commission‘s rules applicable to NeEw York WasHingron Paris Lownpon Miran Romk FRankrURT BRUSSELS

Federal Communications Commission June 8, 2006 Page Two carriers affiliated with foreign carriers that the Commission considers dominant under its rules, without prejudice to América Movil‘s right to seek reclassification of Embratel in the future. Please do not hesitate to contact the undersigned should you have any questions regarding this submission. Michael Jgnes Daniel K¢ Alvarez* WILLKIE FARR & GALLAGHER, LLP 1875 K Street, NW. Washington, D.C. 20006 202—303—1141 Counselfor América Mévil, 8.A. de C.V. *Admitted to Practice in Virginia ce: Susan O‘ Connell David Krech


Document Created: 2019-04-23 12:19:03
Document Modified: 2019-04-23 12:19:03
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