Attachment Attachment 2

This document pretains to ITC-T/C-INTR2019-00643 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTCINTR201900643_1633743

Attachment 2 Page 1 Attachment 2 Domestic Section 214 Assignment Application Pursuant to Section 63.04(b) of the Commission’s rules, 47 C.F.R. § 63.04(b), Applicants submit the following information in support of their Application to assign CP-TEL’s domestic Section 214 authorization to Epic Touch and address the requirements set forth in Section 63.04(a)(6)-(12): 63.04(a)(6): Description of Transaction A description of the transaction is set forth in Attachment 1, Answer to Question 13. 63.04(a)(7): Description of the geographic areas in which the transferor and the transferee (and their affiliates) offer domestic telecommunications services, and what services are provided in each area Epic Touch provides telephone and internet access services (through its affiliates) in Southwest Kansas and portions of the Oklahoma panhandle. CP-TEL provides telephone and internet access services through its wholly-owned subsidiaries, Campti and CPTN, in Louisiana. Specifically, Campti provides services in portions of Natchitoches, Sabine, and Desoto Parishes. CPTN provides competitive services in Northwest Louisiana. 63.04(a)(8): Statement as to how the application fits into one or more of the presumptive streamlined categories in section 63.03 or why it is otherwise appropriate for streamlined treatment The Application is eligible for streamlined processing under Section 63.03(b)(2)(iii) because (1) Epic Touch (the Transferee) will have a total market share of less than ten percent (10%) in the interstate, interexchange market, (2) Epic Touch, both pre- and post-transaction will provide competitive telephone exchange services or exchange access services in areas served by a dominant local exchange carrier that is not a party to the Agreement or this Application, and (3) Applicants are incumbent independent local exchange carriers that have, in combination, fewer than two percent (2%) of the nation’s subscriber lines and no overlapping or adjacent service areas. 63.04(a)(9): Identification of all other Commission applications related to the same transaction Applicants seek authority to transfer all relevant international and domestic Section 214 authorizations by this Application and have filed no other applications relevant to this transaction.

Attachment 2 Page 2 63.04(a)(10) Statement of whether the applicants are requesting special consideration because either party to the transaction is facing imminent business failure The Applicants seek no special consideration because no party to the transaction is facing imminent business failure. 63.04(a)(11): Identification of any separately filed waiver request being sought in conjunction with the transaction No separately filed waiver requests are being sought in conjunction with the transaction.\ 63.04(a)(12): Statement showing how grant of the 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 proposed transfer will serve the public interest by making the CP-TEL entities and Epic Touch financially stronger and better able to compete to provide service to current and prospective customers. The modern telecommunications industry is highly competitive, and customer demand for cutting edge services continues to grow. As a unified organization, Epic Touch and CP-TEL will be able to share their management, financial, and technical expertise and resources, giving both Epic Touch and the CP-TEL entities access to new competitive opportunities and more robust financing opportunities. Moreover, because Epic Touch and its affiliates do not currently compete with or provide service in any of the territories served by the CP-TEL entities the proposed transaction will not reduce competition.


Document Created: 2019-03-05 16:38:43
Document Modified: 2019-03-05 16:38:43
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