AccessLine Letter 2

LETTER submitted by Telanetix, Inc.AccessLine Communications Corporation and HCP-TELA, LLC

Letter

2013-02-13

This document pretains to ITC-T/C-20130128-00032 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2013012800032_986051

 Pillsbury Winthrop Shaw Pittman LLP
 2300 N Street, NW | Washington, DC 20037-1122 | tel 202.663.8000 | fax 202.663.8007




                                                                                                 Glenn S. Richards
                                                                                                          202-663-8215
                                                                                       glenn.richards@pillsburylaw.com




February 13, 2013

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20544


        Re:       Request of Telanetix, Inc., AccessLine Communications Corporation
                  and HCP-TELA, LLC for Approval of the Transfer of Control of an
                  Authorized International and Domestic Carrier
                  FCC File No. ITC-T/C-20130128-00032 and
                  WC Docket No. 13-41

Dear Ms. Dortch:

       In response to an FCC staff request, Telanetix, Inc. (“Telanetix”), AccessLine
Communications Corporation and HCP-TELA, LLC, (collectively the “Applicants”),
through their undersigned counsel, provides additional information pertaining to the ten
percent or more ownership interests of the Applicants. The information presented herein
supplements the information presented in the original applications which were filed on
January 28, 2013. That information is incorporated by reference.

        As detailed in the original applications, EREF-TELA, LLC and CBG-TELA, LLC
hold a direct interest in the transferor, Telanetix. Additional ownership information for
EREF-TELA, LLC and CBG-TELA, LLC is presented below.

      The following entity holds a ten percent (10%) or greater direct or indirect equity
ownership in EREF-TELA, LLC and CBG-TELA, LLC:

Name:                                 Hale Fund Management, LLC
Address:                              570 Lexington Avenue, 49th Floor, New York, NY 10022
Citizenship:                          Delaware
Principal Business:                   Investment Company
Interest:                             Manager of EREF-TELA, LLC and CBG-TELA, LLC.
                                      EREF-TELA and CBG-TELA are otherwise comprised of


                              non-managing members, none of whom as a member can
                              exercise control, and all of whom that have greater than 10
                              percent interest are US citizens.

      The following person holds a ten percent (10%) or greater direct or indirect equity
ownership in Hale Fund Management, LLC:

Name:                         Martin M. Hale, Jr.
Name:                         Hale Fund Management, LLC
Address:                      570 Lexington Avenue, 49th Floor, New York, NY 10022
Citizenship:                  U.S.
Principal Business:           Investment Company
Interest:                     Mr. Hale, Jr. controls 85.1% of Telanteix.
                              He is the sole owner of Hale Fund Management, LLC and
                              Managing Member and sole owner of Hale Capital
                              Partners, LLC. No other entity or individual holds a direct
                              or indirect equity or voting interest in Hale Fund
                              Management, LLC.


       Should you have any questions, please do not hesitate to contact the undersigned.


                                                Respectfully submitted,

                                                      /s/
                                                Glenn S. Richards
                                                Pillsbury Winthrop Shaw Pittman LLP
                                                2300 N Street, N.W.
                                                Washington, D.C. 20037
                                                (202) 663-8215 (Tel)
                                                (202) 513-8006 (Fax)
                                                glenn.richards@pillsburylaw.com (Email)

                                                Counsel for HCP-TELA, LLC, AccessLine
                                                Communications Corporation, and
                                                Telanetix, Inc.




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Document Created: 2013-02-13 16:49:53
Document Modified: 2013-02-13 16:49:53

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