Attachment DOJ Ltr dtd 2.10.11.

DOJ Ltr dtd 2.10.11.

LETTER submitted by DOJ/DHS/FBI

Ltr dtd 2.10.11

2011-02-10

This document pretains to ITC-T/C-20101216-00486 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2010121600486_870508

                             LAWLER, METZGER, KEENEY & LOGAN, LLC

                                                2001 K STREET, NW
                                                    SUITE 802
                                             WASHINGTON, D.C. 20006
GIL M. STROBEL                                                                            PHONE (202) 777—7728
gstrobel@lawlermetzger.com                                                             FACSIMILE (202) 777—7763




                                               February 9, 2011

    Marlene H. Dortch, Secretary
    Federal Communications Commission
    445 Twelfth Street, S.W.
    Washington, D.C. 20554

                         Re:    Joint Application of Shamrock TeleGuam Holdings, LLC and
                                AP TeleGuam Holdings, Inc. — WC Docket No. 10—260;
                                ULS File No. 0004531711; Petition for Declaratory Ruling —
                                IBFS File No. ISP—PDR—2010216—00021

    Dear Ms. Dortch:

               AP TeleGuam Holdings, Inc. (AP TeleGuam Holdings), by its attorneys, hereby
    provides the following responses to the questions listed in the February 3, 2011 letter
    from James Ball, Chief of the Policy Division of the International Bureau.‘ Specifically,
    analyses of investor interests in AP IV GP Partnership and AP Cayman Partners II
    General Partner, L.P. are attached as Exhibit 1 to this letter. In addition, in response to
    the second question posed in Mr. Ball‘s letter, a document providing the principal place
    of business and related information for each of the non—U.S. entities listed in Annex 1 to
    the above—referenced Petition* is attached as Exhibit 2.

               In the course of preparing this filing, AP TeleGuam Holdings discovered that the
    "Analysis of Investor Interests in the Limited Partners of the AP TG Funds," filed as
    Annex 2 to the Petition for Declaratory Ruling," inadvertently included information about
    the limited partners of Japan Ireland Investment Partners, L.P. in the table labeled "Japan




     ‘ Letter from James Ball, FCC, to Gil Strobel, Lawler, Metzger, Keeney & Logan, LLC (Feb. 3, 2011).
    * Petition for Declaratory Ruling of AP TeleGuam Holdings, Inc., IBFS File No. ISP—PDR—20101216—
    00021 (Dec. 16, 2010) ("Petition for Declaratory Ruling"), also aftached to Joint Application, WC Docket
    No. 10—260 (filed Dec. 17, 2010), and to ULS Application File No. 0004531711 (filed Dec. 16, 2010).
    * 1d. at Annex 2.


Ms. Marlene Dortch
February 9, 2011
Page 2


Ireland Investment Partners."* Information about the investors in Japan Ireland
Investment Partners is already set forth on page 7 of the Petition."

         Please let me know if you have any questions regarding the information provided
in this letter, or in the above—referenced application or petition.

                                                      Sincerely,
                                                      /

                                                      Gil M. Strobe
                                                      Counsel for AP TeleGuam Holdings, Inc.

ce:      James Ball
         Carrie—Lee Early
         Jodie May
         Kathy Harris
         David Krech
         Neil Dellar




* See id. at Annex 2, page 5.
* Id. at 7; see also id. at Annex 1 (providing ownership information regarding each investor in Japan Ireland
Investment Partners).



Document Created: 2011-02-10 14:47:23
Document Modified: 2011-02-10 14:47:23

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