Attachment Attachment 1

This document pretains to ITC-T/C-20150722-00179 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2015072200179_1096691

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

In the Matter of                          )
                                          )
Roman LD, Inc.                            )
                                          )
Sapina Quayum,                            )
                                          )
               Transferor,                )
and                                       )
                                          )                File No. _________________
Monotaz Begum                             )
                                          )
               Transferee,                )
                                          )
Joint Application for Consent to Transfer )
International and Domestic Authority      )
Pursuant to Section 214 of the            )
Communications Act of 1934, as amended )

   JOINT APPLICATION FOR CONSENT TO TRANSFER INTERNATIONAL AND
         DOMESTIC AUTHORITY PURSUANT TO SECTION 214 OF THE
              COMMUNICATIONS ACT OF 1934, AS AMENDED

       Pursuant to Section 214 of the Communications Act of 1934, as amended (the

“Communications Act”), 47 U.S.C. § 214, and Sections 63.03, 63.04 and 63.24 of the

Commission’s Rules, 47 C.F.R. §§ 63.03, 63.04 and 63.24, Sapina Quayum (“Transferor”) and

Monotaz Begum (“Transferee”) (together, the “Applicants”) hereby request nunc pro tunc

approval to transfer control of Roman LD, Inc. (“Roman”) from Ms. Quayum to Ms. Begum.

Roman is a non-dominant carrier authorized by the Commission to provide international and

domestic telecommunications services. The Applicants seek streamlined processing of this Joint

Application pursuant to Sections 63.03(b) and 63.12 of the Commission’s Rules. This Joint

Application is being filed concurrently with the International Bureau and the Wireline

Competition Bureau.


          In support of this Joint Application, the Applicants respectfully submit the following

information:

                                             Background

          Roman is a privately-held company organized under the laws of the state of Texas.

Roman is a non-facilities-based interexchange carrier that provides domestic and international

long distance telecommunications service on a purely resold basis. Roman holds both

international and domestic Section 214 authorizations.1

          Roman has a market share in the interstate, interexchange market of less than ten percent

(10%) and is not dominant with respect to any service. The transaction did not result in any

change in the market share of Roman. Moreover, both Applicants are individuals; in other

words, the Applicants are not telecommunications providers or facilities-based carriers.

Consequently, this Joint Application is entitled to streamlined treatment pursuant to Sections

63.03(b)(2)(i) and 63.03(b)(1)(i) & (ii) of the Commission’s Rules.

                                       Description of the Transaction

          This transaction involves the transfer of control of Roman via the transfer of shares of

capital stock of the company from Transferor to Transferee pursuant to a stock purchase

agreement. As a result of this transfer, Transferor’s interest has been reduced from 100% to

zero, and Transferee’s interest in the company increased from zero to 100%. As this transaction

was consummated in January of 2013 without prior Commission approval, Applicants are

requesting nunc pro tunc approval of the transfer of control. Applicants recognize that any

action on this Joint Application is without prejudice to any action the Commission may take on

other matters.



1
    File No. ITC‐214‐20110512‐00132, granted June 10, 2011.

                                                   2


                        Transfer of International Section 214 Authorization

       In accordance with the requirements of Section 63.24(e) of the Commission’s Rules,

Applicants submit the following information:

(1) Name, address and telephone number of each Applicant:

Transferor:

Ms. Sapina Quayum
3550 Wilshire Blvd 17th Floor
Los Angeles, CA 90010
213-381-7160

Transferee:

Ms. Monotaz Begum
2300 Valley View Lane, Ste. 730
Irving, TX 75062-1780
972-746-2004

(2) Government, state or territory under the laws of which each corporate or partnership
Applicant is organized:

Roman is organized under the laws of the state of Texas. The Applicants are individuals.

(3) Name, title, post office address, and telephone number of the officer or contact point of
each Applicant to whom correspondence concerning the Joint Application is to be
addressed:

For the Transferor:
Ms. Sapina Quayum
3550 Wilshire Blvd 17th Floor
Los Angeles, CA 90010
213-381-7160

For the Transferee:
Mr. Cheng-yi Liu
Member
Fletcher, Heald & Hildreth, PLC
1300 N. 17th Street, Suite 1100
Arlington, VA 22209
703-812-0400

Mr. Robert Schill


                                               3


Of Counsel
Fletcher, Heald & Hildreth, PLC
1300 N. 17th Street, Suite 1100
Arlington, VA 22209
703-812-0400

(4) Statement as to whether the Applicants have previously received authority under
Section 214 of the Act.

Roman holds international authority pursuant to File No. ITC‐214‐20110512‐00132, granted
June 10, 2011.

Neither Applicant, as individuals, has ever received any authority under Section 214.

(5) Name, address, citizenship and principal business of any person or entity that directly
or indirectly owns at least ten percent of the equity of the Transferee:

Ms. Begum, the Transferee, owns 100% of Roman.

Ms. Monotaz Begum
2300 Valley View Lane, Ste. 730
Irving, TX 75062-1780
Citizenship: U.S.
Principal Business: Telecommunications

(6) Certification as to whether or not Transferee is, or is affiliated with, a foreign carrier:

Transferee certifies she is not a foreign carrier, and that neither she nor any affiliate is affiliated
with any foreign carrier. Roman is not a foreign carrier, and neither Roman nor any affiliate is
affiliated with any foreign carrier.

(7) Certification as to whether or not Transferee seeks to provide international
telecommunications services to any country for which certain conditions are true:

Transferee certifies that she does not seek to provide international telecommunications to any
destination country for which Transferee (1) is a foreign carrier in that country; (2) controls a
foreign carrier in that country: or (3) is owned more than 25% by or controlled by an entity that
controls a foreign carrier in that country; (4) is in a joint venture or market alliance with two or
more foreign carriers (or parties that control foreign carriers) who own in the aggregate more
than 25% of the Section 214 holder.

(8) Showing regarding provision of international telecommunications service to a country
where the Transferee is a foreign carrier or is affiliated with a foreign carrier.

Not applicable.



                                                   4


(9) Regulatory classification under Section 63.10 of the Rules for foreign-affiliated carrier.

Not applicable.

(10) Certification that Transferee has not agreed to accept special concessions directly or
indirectly from any foreign carrier.

Transferee certifies that she has not agreed to accept special concessions directly or indirectly
from any foreign carrier with respect to any U.S. international route where the foreign carrier
possesses market power on the foreign end of the route and will not enter into such agreements
in the future.

(11) Explanation for Answer to Question 22:

Applicant is unable to certify "yes" to this question because the 2013 Transaction was
consummated without prior Commission approval on January 2, 2013.

(12) Certification by Transferee pursuant to 47 C.F.R. §§ 1.2001-1.2003 that no party to the
Joint Application is subject to denial of federal benefits pursuant to Section 5301 of the
Anti-Drug Abuse Act of 1988, 21 U.S.C. § 583.

Transferee hereby certifies, pursuant to 47 C.F.R. §§ 1.2001-1.2003, that to the best of her
knowledge, information, and belief, no party to this Joint Application is subject to denial of
federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. § 583.

(13) Qualification for streamlined processing.

This Joint Application qualifies for streamlined processing under Sections 63.12(a) and (b) of the
Commission’s Rules. No Applicant is affiliated with any foreign carrier in any destination
market. No Applicant has an affiliation with a dominant U.S. carrier. No Applicant seeks
authority to provide switched basic services over private lines to a country for which the
Commission has not previously authorized the provision of switched services over private lines.
Authorization is sought for the transfer of control of Roman from Transferor to Transferee.


                       Transfer of Domestic Section 214 Authorization

Pursuant to Section 63.04(b) of the Commission’s Rules, the Applicants supply the following
information required pursuant to Sections 63.04(a)(6) through 63.04(a)(12) of the Commission’s
Rules:

(1) Description of the transaction.

Please refer to the description of the transaction provided above.




                                                 5


(2) Description of the geographic areas in which the Transferor and Transferee (and their
affiliates) offer domestic telecommunications services, and what services are provided in
each area.

Roman provides resold competitive, non‐facilities‐based, interexchange telecommunications
services in various states, including: Alabama, Arkansas, Colorado, Florida, Georgia, Kansas,
Kentucky, Louisiana, Massachusetts, Minnesota, Nevada, New Hampshire, New York, North
Carolina, Oklahoma, Pennsylvania, South Carolina, Texas, Utah, and Washington. Prior to this
transaction, Ms. Begum was not a provider of telecommunications services and did not own or
operate any providers of domestic telecommunications services.

(3) Statement as to how the Joint Application fits into one or more of the presumptive
streamlined categories in Section 63.03 of the Commission’s Rules or why it is otherwise
appropriate for streamlined treatment.

Roman and Transferee affirm that (a) the transaction resulted in Roman and Transferee having a
market share in the interstate, interexchange marketplace of less than ten (10) percent; (b)
following the transaction Roman has not and will not provide competitive telephone exchange
service and exchange access services; and (c) none of the Applicants is dominant with respect to
any service. Consequently, this transaction qualifies for streamlined processing under Section
63.03(b)(2)(i) and 63.03(b)(1)(i) & (ii) of the Commission’s Rules.

The proposed transaction will have no adverse effect on competition. Grant of streamlined
treatment for this Application is consistent with Commission precedent.

(4) Identification of all other Commission applications related to the same transaction.

This transaction did not result in the transfer of control of any other authorizations.

(5) Statement of whether the Applicants are requesting special consideration because either
party to the transaction is facing imminent business failure.

No Applicant is facing imminent business failure. Therefore, the Applicants are not requesting
special consideration for this reason.

(6) Identification of any separately filed waiver requests being sought in conjunction with
the transaction.

No separately filed waiver requests are being sought in conjunction with the transaction.

(7) Statement showing how grant of the Joint Application will serve the public interest,
convenience and necessity, including any additional information that may be necessary to
show the effect of the proposed transaction on competition in domestic markets.

The transfer of Roman from Transferor to Transferee enables the continued provision of high-
quality communications services to Roman’s customers. As the transaction involves the transfer

                                                  6


of control of Roman to an individual who does not hold any other telecommunications interests,
competition will not be adversely affected.

                                           Conclusion

       For the foregoing reasons, the Applicants respectfully submit that grant of this Joint
Application by the Commission would serve the public interest, convenience and necessity.

                                                     Respectfully submitted,

                                                            /s/
                                                     Cheng-yi Liu
                                                     Robert Schill
                                                     Counsel to Roman LD, Inc.

                                                     Fletcher, Heald & Hildreth, PLC
                                                     1300 N. 17th Street
                                                     11th Floor
                                                     Arlington, VA 22209
                                                     703-812-0400


July 22, 2015




                                                7


I, Monotaz Begum, hereby certify the following:

       All statements made in this application and in the exhibits, attachments, or documents
       incorporated by reference are material, are part of this application, and are true, complete,
       correct, and made in good faith.
       I am not a foreign carrier, nor is Roman LD, Inc. ("Roman‘) a forcign carrier, nor am I or
        Roman affiliated with any foreign carrier, within the meaning of Sections 63.18() and
        63.09(d) and (c) of the rules of the Federal Communications Commission. 47 C.F.R. §§
       63.18(), 63.09(d) and (e);
       I do not seek and Roman does not seek to provide international telecommunications
       services to any destination country to which paragraphs(})(1)—(4) of Section 63.18 of the
       Commission‘s rules apply;
       I and Roman have not agreed to accept special concessions directly or indirectly from any
        foreign carrier with respect to any U.S. international route where the foreign carrier
       possesses market power on the foreign end ofthe route and will not enter into such
       agreements in the future; and
       No party to this application is subject to a denial of Federal benefits pursuant to Section
        5301 ofthe Anti—Drug Abuse Act of 1988.

I certify under penalty of perjury that the foregoing is true and correct.




Executed on:        13    is




                                                               Monotaz Be};fi          ;



Document Created: 2015-07-22 15:29:32
Document Modified: 2015-07-22 15:29:32

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