Ex parte Tekhelet.pd

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Tekhelet Holdings Ltd

Ex Parte Tekhelet

2015-02-27

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

IBFS_ITCTC2015011200008_1077742

                                                                                 Holdings Ltd
                                                                             Middlesex House
                                                                            29 / 45 High Street
                                                                            Edgware HAQ 7UU




February 27, 2015

VIA ELECTRONIC FILING
Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
445 12th Street, SW,
Room TW—A325
Washington, DC 20554

RE:    EX PARTE
       ITC—T/C—20150112—00008, Applications for consent to transfer control of
       international section 214 authorization ITC—21420070228—00088, held by
       Transtelco, Inc. (Transtelco), to Transtelco Holding Inc. (THD)

Dear Ms. Dortch:

Tekhelet Holdings Ltd ("Tekhelet") respectfully requests that the Commission take the
necessary actions to suspend the Streamlined International Application ITC—T/C—
20150112—00008 filed by Transtelco Inc according to the Public Comment period ending
on February 27, 2015 and open a larger review of the details of its application to transfer
control of the company. We seek an indefinite suspension ofthe transfer of control.

It has been brought to our attention that Transtelco intend to be granted transfer of control
to their holding company in lieu of their ongoing operations and prior proforma transfer
of control by virtue of commercial expansion. Tekhelet respectfully want to bring to the
FCC‘s attention that a significant share of Transtelco‘s current long haul fiber network
infrastructure has indeed been acquired through a mosaic of transactions that constitutes
handling of stolen goods. The fiber network we refer to is Circuits 7 and 8 currently
residing in the Bestel duct, and runs from Laredo Texas to Mexico City at a distance of
approximately 2,200 km

Transtelco unlawfully acquired these disputed fibers from Wicom in December 2012, and
recently obtained investment from Wicoms Principals. Wlcom unlawfully acquired same
from CCA, who had joint ownership with Latingroup.


                                                                                Holdings Ltd
                                                                            Middlesex House
                                                                           29 / 45 High Street
                                                                           Edgware HAQ 7UU



In April 201 1, Tekhelet entered into commercial discussions with Latingroup to acquire
Circuits 7 and 8 with the help ofPrivate Equity investment, and after 18 months
negotiation concluded with a written agreement to acquire the network, Tekhelet, their
outside investors, and legal team spent a great deal offinancial, commercial and
operational resources on this transaction, which was ultimately forced to discontinue its
actions to acquire the network from Latingroup after Transtelco ceased all interaction
with Latingroup in 2014.

As Managing Director of Tekhelet, I emphatically state to the Commission that Tekhelet
has continued to have interest in this transaction, and hopes that pressure may be put
upon Transtelco to immediately recognize the rightful title and ownership to Latingroup
in order for Tekhelet and our investors to complete our acquisition.

We further present to the Commission that Transtelco with related parties, seek to
petition the United States Federal Communications Commission to transfer assets and
obtained rights they do not own, to a new company and uninhibited entity for thc purpose
to protect the assets and rights from federal prosecution.

Please contact the undersigned should you have any questions about this filing.

Respectfully submitted,




Levi Russell
Managing Director



Document Created: 2019-04-07 16:16:18
Document Modified: 2019-04-07 16:16:18

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