Attachment 20170824145445-013.p

20170824145445-013.p

SUPPLEMENT

Supplement

2006-12-04

This document pretains to ITC-T/C-20061204-00541 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2006120400541_1621270

Telstra/Reach supplemental letters                                                                                      Page 1 of 1

  Mikelle Morra

  From:             David Krech
  Sent:             Wednesday, December 13, 2006 10:15 AM
  To:               Mikelle Morra
  Co:               Sumita Mukhoty
  Subject:          FW: Telstra/Reach supplemental letters
  Attachments: Application of Telstra Incorporated1.pdf; Application of Reach Ltd..pdf

Mikelie,

Please upload these into IBFS. Thanks.



*** Non—Public: For Internal Use Only ***




From: Sifers, Randall W. [mailto:RSifers@KelleyDrye.com]
Sent: Wednesday, December 13, 2006 9:11 AM
To: David Krech
Cc: Aamoth, Robert J.
Subject: Telstra/Reach supplemental letters

David,
As requested, attached are date—stamp copies of the supplemental letters that werefiled with the Secretary‘s Office in connection
with the applications filed December 4, 2006 to transfer control of international Section 214 authority on behalf of Telstra USA and
Reach Ltd. confirming that the entities agree to continue to be classified as dominant carriers on certain specified routes.

Randy

<<Application of Telstra Incorporated1.pdf>> <<Application of Reach Ltd..pdf>>



New Contact Information As of May 8, 2006
Randall W. Sifers
Kelley Drye Collier Shannon
3050 K Street NW, Suite 400
Washington, DC 20007—5108
(202) 342—8601 (tei)
(202) 342—8451 (fax)




12/13/2006


                                                                                                                  Page 1 of1

 Mikelle Morra

  From:      Jabloner, Amy [Amy.Jabloner@usdoj.gov]
  Sent:      Thursday, December 28, 2006 1:58 PM
  To:        David Krech; George Li; Joann Ekblad; Mikelle Morra; Susan OConnell
  Co:        James Ball; Myrva Charles; Gail Cohen; Aamoth, Robert J.
  Subject: RE: FCC application status update regarding 2006—67

Good Afternoon,

Please be advised that based upon the information in their application and discussions with the company, the FBI, DOJ, and DHS
have NO COMMENT on the followi_ng application:

   e Telstra — WC Docket No. 06—218


Thank You,

Amy Jabloner
Department of Justice




1/5/2007


                                         KELLEY DRYE & WARREN cur
                                                   A LIMITED LIABILITY PARTNERSHIP




                                        wWASHIN~TON HAR3GOUR SUITE 400

  NEew yoRrk. NY                                     10 <{ TF EET, NW                                                           F A C SIMILE

TYSONS   CORNER,      VA                                                                                                      (202)   342—8 451
                                           WASt      TN          D C. 2(007—510i}
   cHicaco, L                                                                                                             ww w.kelleydrye.com

  sTaAmFORD, CT
                                                       (2)2) 34      —84 00
 PA RSIPP ANY,   NJ



BRUSSELS,    BELGIUM
                                                                                                                     DIRZCT LINZ: (202) 342—8620

                                                                                                                   EMAIL: raamcth@kelleydrye.com
  AFFILIATE OFFICES
   MUMBAT,   INDIA



                                                                                       FILED/A CcEPTEp
                                                      an 1a y : , 200 7                   JAV ~ 52007
                                                                                     Federal »«o
                                                                                              r minuni satiion
                                                                                                               s Commission
                                                                                            ( ffice of tiie Secr
                                                                                                                 etary
  VIA HAND DELIVERY
  Marlene H. Dortch
  Federal Conmunications Commission
  445 12th Si., SW
  Washington, DC 20554

                           Re:                       C—20( 61 20 14—( 05 11, WC Docket No. 06—218;
                                 IB File No. ITC     C—20( 61 20 14—( 05 44;
                                 File No. SCL—T      2006 2( 4—000( 13

  Dear Ms. C ortch:

           Tel: tra Corporation Limited ("   stri") an 1 F.each Ltd. ("Reach"), by their attorneys, are
  filing this lctter in reference to the abo sef>re ac d ap; lic ations. In each :ipplication, Telstra
  and Reach vequested that the Commis:        conc iti n he gr int of such approval on compliance
  with the provisions of a November 29,      )1 A; re m snt by and between Reach Ltd., Telstra
  Corporatiot| Limited, and the Pacific C    ur ; C yt »r\Vo k: Limited, on the one hand, and the
  Federal Buweau of Investigation and th     .S. D sp; rtrie1 t c Justice, on the other hand (the
  "Agreement"). By this letter, Telstra and Reach hereby co ifirm their willingness to have the
  Commission condition the grant of the above—referenced aiplications on compliance with the
  provisions of the Agreement.

                                                                 Very truly yours,

                                                                 Kelley Drye & Warren LLP



                                                           %Aamoth
                                                                 Counsel to Telstra Corporation Limited and
                                                                 Reach Ltd.
  ce:        George Li
             David Krech
             Gail Cohen


                                           December 22, 2006



Via Email and Overnight Delivery

Department of Homeland Security
Washington, D.C. 20528
Atin: Stewart A. Baker, Assistant Secretary of Homeland Security for Policy


Dear Sir or Madam:

       Reference is made to an Agreement dated as of November 29, 2001 (the "Agreement") by and
among Reach Ltd. ("Reach"), Telstra Corporation Limited ("Telstra"), and Pacific Century CyberWorks
Limited ("PCCW"), on the one hand, and the Federal Bureau of Investigation ("EBI") and the U.S.
Department of Justice ("DOJF"), on the other (unless defined otherwise herein, capitalized terms used
herein shall have the same meanings ascribed to such terms in the Agreement). A copy of the Agreement
is attached hereto as Exhibit and incorporated herein bythis reference.

          Since the Agreement predates the creation of the U.S. Department of Homeland Security
("DHS"), DHS is not a party to the Agreement. In order to afford DHS the same rights and
responsibilities under the Agreementas if it were an original signatory, from andafter the date of the last
signature affixed hereto, Telstra, Reach and DHS hereby agree that DHS shall have the same rights and
responsibilities under the Agreement as the FBI and DOJ as if DHS were a partyto the Agreernent having
the same common interests as the FBI and DOJ. For purposesof the agreement entered into pursuant to
this letter, all notices under the Agreement shall be sent to the DHS signatory to this letter.

        This letter amends and supplements the Agreement only to the extent expressly provided herein
and to the extent of the interests of the parties to this letter. The agreement entered into by Telstra,
Reach and DHS pursuant to this letter is severable from the Agreement. Telstra and Reach do
not waive or relinquish any rights under the Agreement or otherwise by entering into an
agreement with DHS pursuant to this letter.



                                           [Signaturepage(s)follow]


If the foregoing reflects our mutual understanding, please sign this letter below where indicated.



                                            Sincerely,




                                            Reach Ltd.



                                            By: _Dermot Keilthy

                                            Its: _Director of Regulatory Affairs

                                            Date:

                                            Address: ___Clarendon House,
                                                          2 Church Street
                                                          Hamilton HM 11
                                                          Bermuda.


                                            Telstra Corporation Litnited


                                            By:

                                            Its:

                                           Date:


                                           AGREED AND ACCEPTED:


                                           Department of Hon@ecurity

                                           By:       e Fé}é                     ~

                                                   StewaitA. Baker, Assistant Secretary of
                                                     Homeland Security for Policy

                                           Date: \-Sex/w\ . .’f c 716E 2


                                     KELLEY DRYE & WARREN uur
                                             A LIMITED LIABIU’(V PARTNERSHIP



                                    WASHINGTON HARBOUR, SUITE 400
  nEW YORK,. NY                             3050 K STREET, NV                                               FACSIMILE

esb enE —e                            WASHINGTON, D.C. 20007—5108                                         t262, s40.—04 51
   CHICAGO,    IL                                                                                        www.kelleydrye.com

  STAMFORD,     CT
                                                 (202) 342+8400
 PARSIPP ANY,    NJ


BRUSSELS, BELGIUM
            +                                                                                       DIRECT LINE: (202) 342—8601

                                                                                                    EMAIL: rsifers@kelleydrye.com
  AFFILIATE OFFICES
   MUMBAI, INDIA




                                             February 1, 2007


                                                                                 FILED/ACCEPTED
  By HAND DELIVERY
                                                                                       FEB— 12007
  Marlene H. Dortch                                                            FedorstCom   |
  Secretary                                                                       mmmecémymwm
  Federal Communications Commission
  445 12th Street, SW_
  Washington, DC 20554

                      Re:    Reach Global Networks Limited, File No. SCL—T/C—20061204—00013;
                             Reach Ltd., File No. ITC—T/C—20061204—00544;
                             TelstraIncorporated,FileNo.ITC—T/C—20061204—00541, WC Docket No.
                             06—218 (Domestic 214 application)

  Dear Ms. Dortch:

            On behalfof Reach Global Networks Limited ("RGNL"), Reach Ltd. ("Reach"), and
  Telstra Incorporated("Telstra"), collectively, the "Parties", this letter reports to the Commission
 that the Agreement dated as ofNovember 29, 2001, by and among Reach Ltd., Telstra
  Corporation Limited, and the Pacific Century CyberWorks Limited, on the one hand, and the
  Federal Bureau of Investigation and the U.S. Department of Justice on the other hand (the
  "Apgreement"), has been revised by a side letter, which became effective on January 8, 2007.
  The side letter amends and supplements the Agreement by making the U.S. Department of
  Homeland Security a party to the Agreement as if it were an original signatory. A copy of the
  side letter is enclosed.

           Grant of each of the above—referenced applications was conditioned on compliance with
   the provisions of the Agreement. While the Parties believe that the filing of each application
   referenced above fulfills the reporting requirement in Section 8.7 of the Agreement, this letter is
 — submitted to ensure that the records in the above referenced proceedings reflect that a timely
   report was made to the Commission. The Parties hereby request that the compliance conditions
   identified in the authorizations in the above—referenced proceedings, be modified to refer to the
  Agreement, as amended.


                             KELLEY DRYE & WARREN cur


Marlene H. Dortch
February 1, 2007
Page Two


       Please direct any questions or inquiries to the undersigned attorneys.

                                                 Very truly yours,

                                                 Kelley Drye & Warren LLP

                                                   Ramdallt 4.hife:
                                                 Robert J. Aamoth
                                                 Randall W. Sifers
                                                 Counsel to
                                                 Reach Global Networks Limited
                                                 Reach Ltd.
                                                 Telstra Incorporated
Enclosure

cc (by email): James Ball
              Renee Crittendon
              David Krech:
              George Li
              Susan O‘Connell


                                           KELLEY DRYE & WARREN cur
                                                     A LIMITED LIABILITY PARTNERSHIP




                                           WASHINGTON HARBOUR, SUITE 400

  NEW    YORK,    NY                                3050 K STREET, NWV                                                FACSIMILE
TYSONS   CORNER,

   CHICAGO,      IL
                           VA
                                               WASHINGTON, D.C. 20007—5108                                         e io
                                                                                                                  www.kelleydrye.com

  sTAMFORD,       CT
                                                         (202) 342—8400
 PA RSIPP A NY,       NJ                                       ~
                                                                                                                  RANDALL W. SIFERS
BRUSSELS,    BELGIUM
                                                                                                             DIRECT LINE: (202) 342—8601

                                                                                                            EMAIL: rsifers@kelleydrye.com
  AFFILIATE OFFICES

   MUMBAT,   INDIA




                                                       March 1, 2007

                                                                                          FILED/ACCEPTED
                                                                                             MAR —1 2007
  VIA COURIER
                                                            RECEIVED                      Eederal Communicatio
                                                                                                                  ns Commission
  Marlene H. Dortch, Secretary                                                                    Office of the Secretary

  Federal Communications Commission                           MAR 0 5 2006
  445 12th Street, SW                                          Policy Division
  Washington, DC 20554                                     international Bureau

                                  Notification of Consummation of Transfer of Control of International
                                   Section 214 Authority held by Telstra Incorporated, File No. FFE—T/G—
                                  20061204—00541~—

  Dear Ms. Dortch:

         . Telstra Incorporated, by its counsel, herebynotifies the Commission that the transaction
   described in the application identified by the above—referenced—filenumber—was.consummated—on
  «EFebruary—28,—2007+ Should youhave any questions regarding this matter, please contact the
   undersigned.

                                                                   Verytruly yours,

                                                                   Kelley Drye & Warren LLP

                                                                      amkM #. Afe»
                                                                   Randall W. Sifers
                                                                   Counsel to
                                                                   Telstra Incorporated

  cc (via email): Jim Ball
                            Kate Collins
                            Susan O‘ Connell
                            David Krech
                            Richard Hindman



Document Created: 2019-05-02 09:06:14
Document Modified: 2019-05-02 09:06:14

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