Sec. 1.65 Letter - I

Section 1.65 Notification submitted by Transtelco, Inc.

Section 1.65 Letter (1-27-2015)

2015-01-27

This document pretains to ITC-T/C-20150112-00008 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2015011200008_1074318

               L ERMAN
               E NTER
                 JX


     WASHINGTON, DC                                                                       Davip S. Kem
                                                                                           202.416.6782
                                                                                      dkeir@lermansenter.com

                                       January 27, 2015


BY ELECTRONIC POSTING

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12"" Street, S.W.
Washington, D.C. 20554

        Re:     Transtelco, Inc. — Application for Transfer of Control of Section 214
                Authorization (FCC File No. ITC—T/C—20150112—00008)

Dear Ms. Dortch:

         Transtelco, Inc. ("Transtelco"), by its attorneys and pursuant to Sections 1.65 and
63.21(a) of the Commission‘s Rules, 47 C.F.R. §§ 1.65 & 63.21(a), hereby supplements
the above—referenced application in response to a request for clarification from FCC staff.
In its application, Transtelco notes that the filing of its request for approval of both a pro
\forma and a separate material transfer of control was not fully consistent with Sections
 63.24(a) and 63.24(f)(2) of the FCC‘s Rules, which require, respectively, prior approval
 of material transfers ofcontrol and notification within thirty (30) days following a pro
forma transfer of control. Accordingly, it requests waivers of these rules. This request
was intended solely to allow processing of the application, not to seek an exemption or
 other determination excusing non—compliance with the Commission‘s requirements. As
 Transtelco now understands that waiver of these rules is not necessary for the
International Bureau to process its application, it hereby withdraws the requests for
 waiver included in the explanatory statement in File No. ITC—T/C—20150112—00008.

        Please contact the undersigned counsel if you have any questions or require any
additional information.

                                            /Rfip@\fwy7]“12%%



                                               David S. Keir
                                               Counsel to Transtelco, Inc.


                   2000 K STREET, NW SuITE 600 | WaASHINGTON, DC 20006—1809
                 TEL 202.429.8970 | FAX 202.293.7783 | WWW.LERMANSENTER.COM



Document Created: 2015-01-27 16:57:27
Document Modified: 2015-01-27 16:57:27

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