Attachment Attachment 1

This document pretains to ITC-T/C-20141222-00325 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2014122200325_1071816

                                            ATTACHMENT 1

Pursuant to Section 63.24(f) of the Commission’s rules, Stanacard, LLC (“Stanacard”) and Stanacard
Holdings, LLC (“Holdings”) notify the Commission of a pro forma assignment of Stanacard’s international
Section 214 authorization (ITC-214-20090624-00301) in connection with an assignment of ownership
interest consummated on December 11, 2014 (the “Assignment”). Specifically, the pro forma
assignment involved the assignment of an ownership interest in Stanacard from Mr. David Michael
Choupak (“Choupak”) to Stanacard Holdings, LLC.

Because the assignment is from an individual to a limited liability company owned and controlled by
such individual without any substantial change in their relative interests, it constitutes a pro forma
assignment under Section 63.24(d), Note 2 of the Commission’s rules. The assignor wholly owns the
assignee.

Answer to Question 10:

       Contact Information for this Notification:

               Manlio Carrelli
               Stanacard, LLC
               424 West 33rd Street, No. 410
               New York, NY 10001

       With a copy to:

               Vineetha Pillai
               Marashlian & Donahue, LLC
               1420 Spring Hill Road, Suite 401
               McLean, Virginia 22102
               Tel: (703) 714-1309
               Email: vmp@commlawgroup.com

Prior International Section 214 Authorizations:

       Choupak, an individual, does not hold domestic or international Section 214 authority.

       Stanacard Holdings, LLC does not hold domestic or international Section 214 authority.

        Stanacard holds blanket domestic Section 214 authority and holds international Section 214
authority granted in File No. ITC-214-20090624-00301.

Answer to Question 11: The following are the names, addresses, citizenship, and principal business of
any person or entity that directly or indirectly owns at least ten percent of the equity in Stanacard
Holdings, LLC:

       David Michael Choupak
       424 West 33rd Street
       No. 410


        New York, NY 10001
        Citizenship: U.S.
        Principal Business: Telecommunications
        Percentage of Ownership: 100

       No other entity or individual held or currently holds a ten percent (10%) or greater attributable
ownership interest in Stanacard Holdings, LLC.

Answer to Question 13:

        Prior to December 11, 2014, Choupak held 8,000 Class A Units of Stanacard, LLC (“Stanacard”)
which constitute all of the issued and outstanding Class A Units. Pursuant to an Assignment Agreement
and Consents thereto, all dated December 11, 2014, Choupak assigned 80 Class A Units (1% of Class A
Units) to Stanacard Holdings, LLC (“Holdings”), a newly formed Delaware limited liability company of
which Choupak is the sole member and manager. Because Holdings is wholly owned by Choupak, all
issued and outstanding Class A Units remain indirectly or directly held by Choupak.

         This transaction qualifies as presumptively pro forma under Note 2, 47 C.F.R. § 63.24(d).
Choupak assigned shares to a company in which he is the sole member. Choupak’s assignment of 80
Class A shares to Holdings did not change the relative ownership of current Stanacard Class A shares.
Moreover, the assignment does not impact the daily operations and management of Stanacard.
Accordingly, the assignment did not result in a change in ultimate control of Stanacard or Stanacard’s
authorizations. The assignment is therefore properly classified as a pro forma transaction. The parties
filed this instant notice to provide notification to the Commission of the pro forma change in ownership
of Stanacard’s authorizations.



Document Created: 2014-12-22 13:05:17
Document Modified: 2014-12-22 13:05:17

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