Clarification Letter

SUPPLEMENT submitted by Transtelco, Inc.

Clarification Letter (2-11-2015)

2015-02-11

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

IBFS_ITCTC2015011200008_1076586

     WASHINGTON, DC                                                                     DAVID S. KEIR
                                                                                        202.416.6782
                                                                                   dkeir@lermansenter.com

                                      February 11, 2015


BY ELECTRONIC POSTING

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th 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.
Transtelco reports that Axiscom, S.A. de C.V. (“Axiscom”), identified as a current 39.1%
shareholder in Transtelco’s parent company, Transtelco Holding, Inc. (“THI”), first
became a shareholder in Transtelco in January 2009, when it acquired a total of 26.15%
of the company by purchasing shares from Miguel Fernandez and Rodrigo Fernandez.
As detailed in the application, this stake was subsequently increased to a 40% interest
held through THI, when that entity was formed on May 1, 2010. At that time and
continuing to the present, Aida Floridet del Carmen Destarac Saenz has been the largest
single shareholder in Axiscom. No other individual holds a 10% or greater share in THI,
or Transtelco, through the Axiscom investment.

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

                                             Respectfully submitted,

                                                /s/ David S. Keir
                                             David S. Keir
                                             Counsel to Transtelco, Inc.


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Document Created: 2015-02-11 18:23:59
Document Modified: 2015-02-11 18:23:59

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