Section 214 International STA Amended Attachment 1 ERRATA, ERRATUM OR ADDENDUM by Ace Telephone Company of Michigan Inc ITC-T/C-20150922-00227 Section 214 Internat

Section 214 Internat

ERRATA, ERRATUM OR ADDENDUM submitted by Ace Telephone Company of Michigan Inc

Section 214 International STA Amended Attachment 1

2015-11-05

This document pretains to ITC-T/C-20150922-00227 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2015092200227_1114108

Ace Telephone Company of Michigan, Inc.
and Ace Telephone Association
Request for Special Temporary Authority
Amended Attachment 1

Amended Response to Question 10:

A. Time period for STA request:

Ace Telephone Company of Michigan, Inc. (“Ace Michigan”), and Ace Telephone
Association (“ATA”) pursuant to 47 C.F.R. § 63.25, hereby request Special Temporary
Authority (“STA”) for a period of 6 months for the continued provision of international service
to customers pending consideration of a separately filed application for transfer of control (File
No ITC-T/C-20150922-00227) of the international Section 214 authorization (“Joint
Application”) held by Great Lakes Comnet, Inc (“GLC”).

B: Circumstances leading to the need for an STA:

In several transactions occurring in 2014 and 2015, GLC issued new and additional
shares of its common stock to its existing common shareholders. Prior to a stock issuance that
occurred on October 6, 2014, no shareholder or entity had a fifty percent or greater ownership
interest in GLC, either directly or indirectly. On October 6, 2014, Ace Michigan, as well as
other GLC shareholders, purchased shares from GLC, and as a result of Ace Michigan’s stock
purchase on this date it became the holder of approximately 51% of the common stock of, and
thereby acquired a controlling interest in, GLC. Applying 47 CFR 63.03(d)(1) (footnote 1) and
47 CFR 63.09(b) (second sentence), as of October 6, 2014, ATA, as the parent company of Ace
Michigan is also deemed to have acquired a controlling interest in GLC as a result of Ace
Michigan’s stock acquisition. By virtue of Ace Michigan’s and ATA’s acquisition of a
controlling interest in GLC, they also acquired a controlling interest in GLC’s wholly-owned
subsidiaries, Clinton County Telephone Company (“CCTC”), Westphalia Telephone Company
(“WTC”), Westphalia Broadband, Inc. (“WBI”), and Comlink, LLC (“Comlink”).
The obtaining of the Commission’s prior approval of ATA’s and Ace Michigan’s
acquisition of a controlling interest in GLC was inadvertently overlooked. This situation was
discovered prior to any inquiry by the Commission, in connection with the transfer or otherwise.
By their Joint Application, Joint Applicants are seeking approval for the transfer of such control.
Since ATA’s and Ace Michigan’s acquisition of a controlling interest in GLC and its
subsidiaries, GLC and its subsidiaries have continued to provide high quality affordable services
that are uniquely tailored to the needs of their customers. GLC and its subsidiaries are managed
by the same executive management staff as before the transfer of control. Granting this STA
will have no adverse effect on the ability of any of the Joint Applicants to continue to serve their
customers without interruption or change.
The transaction involved only Ace Michigan’s acquisition of a majority of GLC’s
common stock, and did not result in a reduction or impairment of service to any customers of
Ace Michigan, ATA, WTC, WBI, or Comlink. However, the Joint Applicants did not seek the
FCC’s consent prior to the transfer of control, and are requesting this STA and approval of their

$underlying Joint Application as part of a plan to correct any deficiency that may have resulted from this oversight. C. STA is in the public interest. Granting the STA is in the public interest because it allows the continued provision of uninterrupted service to their customers and the avoidance of a discontinuance of service to customers while the Commission considers the underlying application. D. Steps being taken to ensure future compliance with Commission rules and regulation. Ace Michigan, ATA, GLC, Comlink, CCTC, WTC and WBI at all times intended to comply with the FCC’s transfer of control rules. The delay in filing for FCC approval of the transfer of control described above was the result of a purchase of stock which created a change in controlling interest the need to obtain prior FCC approval was inadvertently overlooked. The FCC’s authorizations at issue here are important to the Joint Applicants’ operations, and the stock purchase which gave rise to the transfer of control is not typical for the Joint Applicants. Ace Michigan, ATA, GLC, Comlink, CCTC, WBI and WTC are fully apprised of the need to obtain prior FCC approval for transfers of control and assignments. In the future, the ATA and Ace Michigan, as well as GLC, Comlink, CCTC, WBI and WTC, will carefully review with legal counsel whether any regulatory approvals, including § 214, is required for any transaction. E. Acknowledgment: The Joint Applicants acknowledge that the grant of this STA will not prejudice any action the Commission may take on the underlying application. The Joint Applicants further acknowledge that this STA can be modified or revoked by the Commission upon its own motion without a hearing. Response to Question 12: Not Applicable. 25415033.1\130050-00001$

Document Created: 2015-11-05 10:41:23
Document Modified: 2015-11-05 10:41:23