FCC Supplement.pdf

SUPPLEMENT submitted by GTT America,s LLC

Supplement

2017-07-13

This document pretains to ITC-T/C-20170626-00116 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2017062600116_1247637

Andrew D. Lipman
Brett P. Ferenchak
andrew.lipman@morganlewis.com
brett.ferenchak@morganlewis.com




July 13, 2017

VIA ECFS & IBFS

Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Re:      WC Docket No. 17-176
         IB File No. ITC-T/C-20170626-00116
         Applications Filed for Consent to the Proposed Transfer of Control of GC Pivotal, LLC to
         GTT Americas, LLC
         SUPPLEMENT

Dear Secretary Dortch:

By this letter, GTT Americas, LLC (“Transferee”), Pivotal Global Capacity, LLC (“Transferor”), and
GC Pivotal, LLC d/b/a Global Capacity (“Global Capacity”) (collectively, the “Applicants”)
supplement the Applications with information and clarification requested by Wireline Competition
Bureau Staff. First, Transferee clarifies that its affiliate, Hibernia Atlantic U.S., LLC (“HB Atlantic”),
is a Washington limited liability company. Transferee also clarifies that none of GTT
Communications, Inc., Universal Telecommunications, Inc. or Brian Thompson holds a 10% or
greater, direct or indirect, interest in any U.S. Telecommunications Carrier other than Transferee
and HB Atlantic.

Transferee and HB Atlantic manage a leased fiber network within the United States. Similarly,
Global Capacity also leases its U.S. fiber network. None of these companies owns its own fiber
within the United States.

In addition to the foreign carriers listed on page 6 of the Application, Transferee is also affiliated
with the following non-dominant foreign carrier: Perseus do Brasil Servicos de Tecnologia da
Informacao Ltda, a Brazilian entity which operates in Brazil.




                                                      Morgan, Lewis & Bockius        LLP

                                                      1111 Pennsylvania Avenue, NW
                                                      Washington, DC 20004                 +1.202.739.3000
                                                      United States                        +1.202.739.3001


Marlene H. Dortch, Secretary
July 13, 2017
Page 2

Please do not hesitate to contact us with any additional questions.

Respectfully submitted,

/s/ Brett P. Ferenchak

Andrew D. Lipman
Brett P. Ferenchak

Counsel for GTT Americas, LLC

Cc:     Gregory Kwan (FCC, Wireline Competition Bureau)
        Katherine K. Mudge (Counsel for Transferor and Global Capacity



Document Created: 2017-07-13 18:26:36
Document Modified: 2017-07-13 18:26:36

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