Oxford Petition to A

PETITION submitted by U.S. Department of Justice

Petition to Adopt Conditions

2014-04-30

This document pretains to ITC-T/C-20140116-00023 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2014011600023_1044620

                                      Before the
                        FEDERAL COMMUNICATIONS COMMISSION
                                 Washington, D.C. 20554

In the Matter of                              )
                                              )
                                              )
Oxford Networks Holdings, Inc. and Oxford     )
County Telephone & Telegraph Company          )           ITC—T/C-20140116-00023
Application for authorization under Section   )
214 of the Communications Act of 1934, as     )
amended                                       )
                                              )
                                              )

                          PETITION TO ADOPT CONDITIONS TO
                           AUTHORIZATIONS AND LICENSES


The Department of Justice (“DOJ”) submits this Petition to Adopt Conditions to Authorizations

and Licenses (“Petition”), pursuant to Section 1.41 of the Federal Communications Commission

(“Commission”) rules.1 Through this Petition, DOJ advises the Commission that it has no

objection to the Commission approving the authority sought in the above-referenced proceeding,

provided that the Commission conditions its approval on the assurance of Oxford Networks

Holdings, Inc. and Oxford County Telephone & Telegraph Company to abide by the

commitments and undertakings set forth in the April 28, 2014 Letter of Assurances (“LOA”),

which is attached hereto. The above-referenced proceeding involves an application filed with the

Commission requesting authority for the transfer of control of Oxford County Telephone &

Telegraph Company, the ultimate parent of Oxford Telephone Company, Oxford West

Telephone Company, Oxford County Telephone Service Company, Northeast Competitive

Access Providers, LLC, and Revolution Networks, LLC, by Oxford Networks Holdings, Inc. and

Oxford County Telephone & Telegraph Company, which hold certain domestic and international

authorizations under Section 214 of the Communications Act of 1934, as amended.

1
    47 C.F.R. § 1.41.


          The Commission has long recognized that law enforcement, national security, and public

safety concerns are part of its public interest analysis, and has accorded deference to the views of

other U.S. government agencies with expertise in those areas. See In the Matter of Comsat

Corporation d/b/a Comsat Mobile Communications, etc., 16 FCC Rcd. 21,661, 21707 ¶ 94

(2001).

          After discussions with representatives of Oxford Networks Holdings, Inc. and Oxford

County Telephone & Telegraph Company in connection with the above-referenced proceeding,

DOJ has concluded that the additional commitments set forth in the LOA will help ensure that

DOJ, a U.S Government agency with responsibility for enforcing the law, protecting the national

security, and preserving public safety, can proceed appropriately to satisfy those responsibilities.

Accordingly, DOJ advises the Commission that it has no objection to the Commission granting

the application in the above-referenced proceeding, provided that the Commission conditions its

consent on compliance with the LOA.



Respectfully submitted,

/S/ Richard C. Sofield
Richard C. Sofield
U.S. Department of Justice
Director - Foreign Investment Review Staff
National Security Division
Bicentennial Building
600 E Street, NW, Rm 10000
Washington, D.C. 20004


April 30, 2014




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Document Created: 2014-04-30 12:30:01
Document Modified: 2014-04-30 12:30:01

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