Attachment Transfer Application

This document pretains to ITC-T/C-INTR2019-02473 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTCINTR201902473_1743275

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of the Joint Application of ) ) Wyyerd Group LLC, Transferee ) WC Docket No. 19-_____________ ) and ) IB File Nos. ITC-T/C-2019________ ) Pinpoint Holdings, Inc., Transferor ) ) For Grant of Authority Pursuant to Section 214 ) of the Communications Act of 1934, as ) amended, and Sections 63.04 and 63.24 of the ) Commission’s Rules to Transfer Control of Ac- ) cipiter Communications, Inc. d/b/a Zona Com- ) munications, a Holder of Domestic and ) International Section 214 Authorizations, to ) Wyyerd Group, LLC JOINT APPLICATION Wyyerd Group LLC (“Transferee”) and Pinpoint Holdings, Inc. (“Transferor”) (together, “Applicants”), pursuant to Section 214 of the Communications Act of 1934, as amended (the “Act”), 47 U.S.C. § 214, and Sections 63.04 and 63.24 of the Commission’s Rules, 47 C.F.R. §§ 63.04 & 63.24, request Commission approval to transfer control of Accipiter Communications, Inc. d/b/a Zona communications (“Zona” or “Licensee”), a holder of domestic and international Section 214 authorizations, from Transferor to Transferee. In support of this Application, Applicants provide the following information: I. DESCRIPTION OF THE APPLICANTS A. Wyyerd Group LLC – Transferee Transferee is a Delaware limited liability company whose business is acquiring and owning telecommunications networks and providers of telecommunications services. John Scarano is the

managing member of Transferee. Through its subsidiaries AFN Wyyerd, LLC d/b/a Wyyerd Con- nect, LLC (“Wyyerd Connect”) and Atlantic Fiber Networks LLC (“Atlantic Fiber Networks” and together with Transferee and Wyyerd Connect, “Wyyerd”), Wyyerd provides low-cost, high-qual- ity fiber-based internet services to residential, business and government customers. Wyyerd’s goal is to become the cornerstone partner for internet connectivity, fiber and facilities interconnection, smart community enablement, and sustainable community growth one community at a time across the United States and Canada. Wyyerd currently owns facilities and serves customers in Atlanta, Georgia, and has limited facilities in Indiana and Texas. B. Pinpoint Holdings, Inc. – Transferor Transferor is a diversified communications company organized under the laws of Ne- braska, with its principal place of business located at 611 Patterson Street, Cambridge, Nebraska 69022. Transferor is a privately-held corporation, over 70% of the stock of which is owned by four individuals, all of whom are U.S. citizens.1 Pinpoint does not directly provide telecommuni- cations services but rather, through its telecommunications subsidiaries, provides local and long distance telephone services, internet services, and broadband and wireless communication ser- vices. C. Accipiter Communications, Inc. d/b/a Zona Communications Licensee currently is a direct, wholly owned subsidiary of Transferor. Licensee is an in- cumbent local exchange carrier that exclusively serves the Phoenix, Arizona metropolitan area. Licensee provides state-of-the-art high-speed internet, telephone and digital television services to residents and businesses within an 1,100 square mile area of north Phoenix. 1 These individuals are William E. Shoemaker (13.21%); J. Richard Shoemaker (25.88%); Eric B. Ei- senhart (21.23%) and G. Franklin Shoemaker (12.69%). Other than the four aforementioned shareholders, no other individual or entity owns a 10% or greater interest in Transferor. 2

II. DESCRIPTION OF THE TRANSACTION Pursuant to the Stock Purchase Agreement, dated June 14, 2019, by and among Transferee, Transferor, and Licensee, Transferee will acquire control of Licensee through a series of concur- rent transactions (the “Transaction”). Upon completion of the Transaction, Licensee will become a direct, wholly-owned subsidiary of Transferee. The Section 214 authorizations currently held by Licensee will continue to be held by Licensee following consummation of the Transaction, and the Transaction will be transparent to customers. Diagrams depicting the pre- and post-Transaction corporate ownership structures of Licen- see are appended hereto as Exhibit A. III. PUBLIC INTEREST CONSIDERATIONS Under 47 U.S.C. § 214(a), the Commission must determine whether a proposed transfer of control of a provider of interstate or international telecommunications services is consistent with the public interest, convenience, and necessity.2 In making such a determination, the Commission first assesses “whether the proposed transaction complies with the specific provisions of the Act, other applicable statutes, and the Commission’s rules.”3 Second, if a proposed transaction would not violate the Act, any other applicable statute, or any of the Commission’s rules, the Commission 2 See, e.g., Applications of Level 3 Communications, Inc. and CenturyLink, Inc. for Consent to Trans- fer Control of Licenses and Authorizations, Memorandum Opinion and Order, 32 FCC Rcd. 9581, 9585 ¶ 8 (2017) (“Level 3-CenturyLink Order”); Applications of AT&T Inc. and DIRECTV For Consent to Assign or Transfer Control of Licenses and Authorizations, Memorandum Opinion and Order, 30 FCC Rcd. 9131, 9139-40 ¶ 18 (2015) (“AT&T-DIRECTV Order”); Applications of XO Holdings and Verizon Communica- tions Inc. For Consent to Transfer Control of Licenses and Authorizations, Memorandum Opinion and Order, 31 FCC Rcd. 12,501, 12,504-05 ¶ 7 (Wireline Comp., Int’l, and Wireless Tel. Burs. 2016) (“Verizon- XO Order”). 3 See Level 3-CenturyLink Order, 32 FCC Rcd. at 9585 ¶ 8; AT&T-DIRECTV Order, 30 FCC Rcd. at 9139-40 ¶ 18 (citations omitted); Verizon-XO Order, 31 FCC Rcd. at 12,504-05 ¶ 7 (citations omitted); Applications of SoftBank Corp., Starburst II, Inc., Sprint Nextel Corp., and Clearwire Corp., Memorandum Opinion and Order, Declaratory Ruling, and Order on Reconsideration, 28 FCC Rcd. 9642, 9650 ¶ 23 (citations omitted) (“Softbank-Sprint-Clearwire Order”); Applications Filed by Qwest Communications In- ternational Inc. and CenturyTel, Inc. d/b/a CenturyLink For Consent to Transfer Control, Memorandum Opinion and Order, 26 FCC Rcd. 4194, 4198-99 ¶ 7 (citation omitted) (“Qwest-CenturyLink Order”). 3

then considers whether a proposed transaction “could result in public interest harms by substan- tially frustrating or impairing the objectives or implementation of the [Communications] Act or related statutes.”4 Third, where a transaction raises no public interest harms or where any such harms can be ameliorated by narrowly tailored conditions, the Commission considers the transac- tion’s public interest benefits, with the applicants bearing the burden of proving those benefits by a preponderance of the evidence.5 Finally, if the Commission finds that narrowly tailored, trans- action-specific conditions would ameliorate any public interest harms for a transaction that is oth- erwise in the public interest, it may approve the transaction as so conditioned.6 The proposed Transaction would not violate any provision of the Communications Act of 1934, as amended (the “Act”) or any Commission rule, nor would it substantially frustrate or im- pair the Commission’s implementation or enforcement of the Act or interfere with the objectives of the Act or other statutes. To the contrary, as detailed below, the proposed Transaction will offer substantial public interest benefits without any material countervailing harms. In the absence of any such harms, the Applicants believe that transaction-specific conditions are unnecessary. Consummation of the proposed Transaction will serve the public interest. The financial, technical, and managerial resources that Transferee will bring to Licensee are expected to enhance the ability of Licensee to compete in the communications marketplace. Immediately following the Transaction, Licensee will continue to provide service at the same rates, terms, and conditions, as 4 See Level 3-CenturyLink Order, 32 FCC Rcd. at 9585 ¶ 9; AT&T-DIRECTV Order, 30 FCC Rcd. at 9140 ¶ 18 (citation omitted); Verizon-XO Order, 31 FCC Rcd. at 12,504-05 ¶ 7 (citation omitted); Soft- Bank-Sprint-Clearwire Order, 28 FCC Rcd. at 9651 ¶ 23 (citation omitted); Qwest-CenturyLink Order, 26 FCC Rcd. at 4199 ¶ 7. 5 See Level 3-CenturyLink Order, 32 FCC Rcd. at 9586 ¶ 10. In earlier transactions, the Commission weighed any potential public interest harms of the proposed transaction against any potential public interest benefits. See AT&T-DIRECTV Order, 30 FCC Rcd. at 9140 ¶ 18 (citation omitted); Verizon-XO Order, 31 FCC Rcd. at 12,504-05 ¶ 7 (citation omitted); SoftBank-Sprint-Clearwire Order, 28 FCC Rcd. at 9650-51 ¶ 23 (citation omitted). 6 See Level 3-CenturyLink Order, 32 FCC Rcd. at 9586 ¶ 11. 4

governed by existing contracts. The Transaction will be transparent to customers because the only change immediately following the closing from a customer’s perspective is that ultimately Trans- feree will be the new direct owner of Licensee. Moreover, the addition of Licensee’s facilities into Wyyerd’s portfolio will enable Wyyerd to serve a broader customer set and better take advantage of its investments. Transferee and its affiliates will seek to build on Licensee’s existing assets, support investment in new infrastructure and continue to offer innovative and high-quality services to existing customers. The proposed Transaction will have no adverse impact on customers and will not alter the manner of service delivery or billing. Licensee’s managerial, technical and operational standards will be maintained and supplemented by management of Transferee. Licensee will continue to comply with existing contracts and tariffs, as applicable, subject to change in the ordinary course of business and in accordance with applicable law. The proposed Transaction would create no new combinations that would adversely affect competition in any domestic market or on any U.S.-international route. There is no overlap where both Licensee and the domestic telecommunications service provider affiliate of Transferee offers lit services. Transferee does not currently control, and is not affiliated with, any foreign carrier regulated as dominant on any U.S.-international route. IV. INFORMATION REQUIRED BY SECTION 63.24(e) Pursuant to Section 63.24(e)(2) of the Commission’s Rules, the Applicants submit the fol- lowing information requested in Section 63.18 (a)-(d) and (h)-(p) in support of this Application: (a) Name, address and telephone number of each Applicant: Transferee: Wyyerd Group, LLC FRN: 0027092774 5600 Arapahoe Avenue Suite 200 5

Boulder, CO 80303 Tel: 720-262-3863 Transferor: Pinpoint Holdings, Inc. FRN: 0001566967 611 Patterson St. Cambridge, NE 69022 Tel: (308) 697-3375 Licensee: Accipter Communications, Inc. FRN: 0004269833 d/b/a Zona Communications 28620 N. El Mirage Road Suite 101 Peoria, AZ 85383 Tel: (623) 455-4555 (b) Jurisdiction of Organizations: Transferee: Transferee is a limited liability company formed under the laws of Dela- ware. Transferor: Transferor is a corporation formed under the laws of Nebraska. Licensee: Licensee is a corporation formed under the laws of Nevada. (c) (Answer to Question 10) Correspondence concerning this Application should be sent to: For Transferee: For Licensee and Transferor: Tamar E. Finn Paul Halbur Patricia Cave Fraser Stryker PC LLO Morgan, Lewis & Bockius LLP 500 Energy Plaza 1111 Pennsylvania Ave, N.W. 409 South 17th Street Washington, DC 20004-2541 Omaha, NE 68102 202-739-3000 (tel) 402-341-8290 (tel) 202-739-3001 (fax) 402-968-5342 (fax) tamar.finn@morganlewis.com PHALBUR@FraserStryker.com patricia.cave@morganlewis.com 6

With copies for Transferee to: With copies for Licensee to: Scott Beer Mike Urdahl Chief Legal Officer President Wyyerd Group, LLC Accipiter Communications, Inc., dba 5600 Arapahoe Avenue Zona Communications Suite 200 28620 N El Mirage Road, Suite 101 Boulder, CO 80303 Peoria, AZ 85383 scott.beer@wyyerd.com murdahl@teamzona.com With copies for Transferor to: Pinpoint Holdings, Inc. P.O. Box 490 611 Patterson St. Cambridge, NE 69022 (d) Section 214 Authorizations Transferee: Transferee does not hold international or domestic (interstate) Section 214 authorization. Transferor: Transferor does not hold international or domestic (interstate) Section 214 authorization. Licensee: Licensee holds international Section 214 authority to provide global or lim- ited global facilities-based and resale services granted in IB File No. ITC- 214-20061026-00491. Licensee also is authorized to provide interstate ser- vice by virtue of blanket domestic Section 214 authority. 47 C.F.R. § 63.01. (h) (Answer to Questions 11 & 12) Upon completion of the Transaction, Licensee will become a direct, wholly-owned subsidiary of Transferee. The following entities will hold, directly or indirectly, a ten percent (10%) or greater interest in Transferee upon completion of the Trans- action as calculated pursuant to the Commission’s ownership attribution rules for wireline and international telecommunications carriers: (1) Name: Wyyerd Select Investors LLC (“WSI”) Address: 9460 Owl Lane Boulder, CO 80301 Citizenship: U.S. (Delaware) Principal Business: Investments % Interest: Approx. 19.20% (directly) 7

(2) Name: ESU Zona LLC Address: 9460 Owl Lane Boulder, CO 80301 Citizenship: U.S. (Delaware) Principal Business: Investments % Interest: Approx. 58.27% (directly) (3) Name: Pinpoint Holdings, Inc. (“Transferor”) Address: 611 Patterson St. Cambridge, NE 69022 Citizenship: U.S. (Nebraska) Principal Business: Investments % Interest: Approx. 19.20% (indirectly) The following entity will hold 10% or greater ownership interest in WSI: (1) Name: Pinpoint Holdings, Inc. (“Transferor”) Address: 611 Patterson St. Cambridge, NE 69022 Citizenship: U.S. (Nebraska) Principal Business: Investments % Interest: Approx. 61.73% (directly in WSI) The following individual will hold 10% or greater interest in ESU Zona, LLC: (1) Name: John Scarano Address: 9460 Owl Lane Boulder, CO 80301 Citizenship: U.S. Principal Business: Telecommunications % Interest: 100% (directly in ESU Zona, LLC) The following individuals will hold 10% or greater interest in Transferor: (1) Name: J. Richard Shoemaker Address: c/o Pinpoint Holdings, Inc. 611 Patterson Street Cambridge, Nebraska 69022 Citizenship: U.S. Principal Business: Telecommunications % Interest: Approx. 25.88% (2) Name: Eric B. Eisenhart Address: c/o Pinpoint Holdings, Inc. 611 Patterson Street Cambridge, Nebraska 69022 8

Citizenship: U.S. Principal Business: Attorney % Interest: Approx. 21.23% (3) Name: William E. Shoemaker Address: c/o Pinpoint Holdings, Inc. 611 Patterson Street Cambridge, Nebraska 69022 Citizenship: U.S. Principal Business: Retired Banker % Interest: Approx. 13.21% (4) Name: G. Franklin Shoemaker Address: c/o Pinpoint Holdings, Inc. 611 Patterson Street Cambridge, Nebraska 69022 Citizenship: U.S. Principal Business: Attorney % Interest: Approx. 12.69% To Applicants’ knowledge, other than the individuals set forth above, no other person or entity, directly or indirectly, owns or controls a 10% or greater interest in Transferee. Transferee does not have any interlocking directorates with a foreign carrier. (i) (Answer to Question 14) Transferee certifies that it is not a foreign carrier or affil- iated (as defined in 47 C.F.R. § 63.09) with any foreign carriers. Currently, neither Transferor nor Licensees are foreign carriers or affiliated with any foreign carrier(s). (j) (Answer to Question 15) Applicants certify that they do not seek to provide inter- national telecommunications services to any destination country where (1) an Applicant is a for- eign carrier in that country, (2) an Applicant controls a foreign carrier in that country, (3) any entity that owns more than 25 percent of an Applicant, or that controls an Applicant, controls a foreign carrier in that country; or (4) two or more foreign carriers (or parties that control foreign carriers) own in the aggregate more than 25 percent of an Applicant and are parties to, or the beneficiaries of, a contractual relation affecting the provision or marketing or international basic telecommuni- cations services in the United States. 9

(k) Not applicable. (m) Not applicable. (n) Applicants certify that they 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 of the route and will not enter into such agree- ments in the future. (o) Applicants certify that they are not subject to denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1998. See 21 U.S.C. § 853a; see also 47 C.F.R. §§ 1.2001-1.2003. (p) Applicants respectfully submit that this Application is eligible for streamlined processing pursuant to Section 63.12(a)-(b) of the Commission’s Rules, 47 C.F.R. § 63.12(a)-(b). In particular, Section 63.12(c) is inapplicable because none of the Applicants is or is affiliated with any foreign carriers, and none of the scenarios outlined in Section 63.12(c) of the Commission’s Rules applies. V. INFORMATION REQUIRED BY SECTION 63.04 Pursuant to Commission Rule 63.04(b), 47 C.F.R. § 63.04(b), Applicants submit the fol- lowing information in support of their request for domestic Section 214 authority to transfer con- trol of Licensee to Transferee in order to address the requirements set forth in Commission Rule 63.04(a)(6)-(12): (a)(6) A description of the proposed Transaction is set forth in Section II above. (a)(7) (i) Licensee operates as an incumbent local exchange carrier in portions of Maricopa County, Arizona and Yavapai County, Arizona, pursuant to a Certificate of Convenience and Necessity granted by the Arizona Corporation Commission in 1995. In these areas, Licensee provides local exchange and long distance telephone services, with approximately 4,047 access 10

lines. In addition to regulated telephone services, Licensee also provides deregulated services, in- cluding broadband Internet access and DirecTV® television services in the aforementioned geo- graphic areas. (ii) Transferor does not itself offer any domestic telecommunications services. Its subsidiaries, Cambridge Telephone Company, Pinpoint Communications, Inc. and Pinpoint Wireless offer domestic telecommunications services as follows: (a) Pursuant to a certificate of public convenience and necessity to provide telecommunications services in the State of Nebraska, Cambridge Telephone Com- pany is a rural, incumbent local exchange carrier and, in this capacity, provides local exchange voice services and long distance telephone services in the commu- nities of Cambridge and Bartley, Nebraska, with approximately 979 access lines. Cambridge Telephone Company also offers a variety of broadband voice and data services, including broadband Internet access and IPTV, in the communities of Bartley and Cambridge, Nebraska (b) Pursuant to a certificate of public convenience and necessity to operate as a competitive local exchange carrier in the State of Nebraska and, in this capac- ity, Pinpoint Communications, Inc. provides local exchange carrier and long dis- tance telephone services in the communities of Gothenburg, McCook, and Oxford, Nebraska, with approximately 818 access lines. Pinpoint Communica- tions, Inc. provides DSL services in McCook and Oxford, Nebraska, and offers a variety of broadband voice and data services, including broadband Internet access and IPTV, in the communities of Bartley, Beaver City, Cambridge, Gothenburg, 11

Indianola, McCook and Oxford, Nebraska.7 (c) Pinpoint Wireless provides fixed and mobile wireless voice and data services in the communities of McCook, Cambridge, Indianola, Arapahoe, Dan- bury, Hendley, Lebanon, and Wilsonville, Nebraska (iii) Transferee is a holding company that does not provide telecommunications services directly. Transferee’s subsidiary Wyyerd Connect provides internet access services in Georgia and is authorized to provide competitive local exchange services in Georgia. Transferee’s subsidiary Atlantic Fiber Networks does not provide regulated telecommunications services or hold authorization(s) to provide telecommunications services in any state. Transferee currently does not own or control a 10% or greater, direct or indirect interest in any other domestic telecom- munications carrier. To Transferee’s knowledge, Transferee currently is not affiliated with any domestic telecommunications carriers through the persons or entities that own or control a 10% or greater, direct or indirect interest in Transferee. (a)(8) Applicants respectfully submit that this Application is eligible for streamlined pro- cessing pursuant to Sections 63.03 of the Commission’s Rules, 47 C.F.R. §63.03. In particular, with respect to domestic authority, this Application is eligible for streamlined processing pursuant to Sec- tion 63.03(b)(2)(ii) because, immediately following the Transaction, (i) Transferee will have a mar- ket share in the interstate, interexchange market of less than ten percent (10%), (ii) the Transferee will provide competitive telephone exchange services or exchange access services (if at all) exclu- sively in geographic areas served by a dominant local exchange carrier (other than Licensee) that is not a party to the transaction; and (iii) Transferee does not provide telecommunications services in Arizona where Licensee is an incumbent local exchange carrier. Moreover, Licensee has fewer 7 The specific services offered vary on a community-by-community basis. Pinpoint Communications also offers cable television service to the communities of Beaver City, Indianola and Oxford, Nebraska. 12

than two (2) percent of the nation’s subscriber lines, and there will be no overlapping or adjacent service areas following completion of the Transaction. (a)(9) Applicants will file an application seeking Commission approval for the transfer of control of Licensee’s common carrier wireless microwave license associated with call sign WQIC640. (a)(10) No party is requesting special consideration because it is facing imminent business failure. (a)(11) Not applicable. (a)(12) A statement showing how grant of the application will serve the public interest, convenience and necessity is provided in Section III, above. VI. CONCLUSION For the reasons stated above, Applicants respectfully submit that the public interest, convenience and necessity would be furthered by a grant of this Application to transfer ownership and control of Licensee to Transferee. Respectfully submitted, /s/Paul Halbur /s/Tamar E. Finn Paul Halbur Tamar E. Finn FRASER STRYKER PC LLO Patricia Cave 500 Energy Plaza MORGAN, LEWIS & BOCKIUS LLP 409 South 17th Street 1111 Pennsylvania Avenue, N.W. Omaha, NE 68102 Washington, DC 20004 402-341-8290 (tel) 202-739-3000 (tel) 402-968-5342 (fax) 202-739-3001 (fax) PHALBUR@FraserStryker.com tamar.finn@morganlewis.com patricia.cave@morganlewis.com Counsel for Transferor and Licensee Counsel for Transferee Dated: June 20, 2019 13

EXHIBIT A Pre- and Post-Transaction Corporate Ownership Structure Charts

Current Corporate Ownership Structure of Licensee* J. Richard Shoemaker Eric B. Eisenhart Other Owners Holding William E. Shoemaker G. Franklin Shoemaker (U.S.) (U.S.) Less than 10 Percent (U.S.) (U.S.) 25.88% 21.23% Collectively, 13.21% 12.69% 26.99% Pinpoint Holdings, Inc. * The entities listed herein only include (“Transferor”) Licensee and those entities or individuals (Nebraska) currently in its chain of ownership. The chart excludes subsidiaries of Transferor whose control will not change following the Transaction. Accipiter Communications, Inc. d/b/a Zona Communications (Nevada) Unless otherwise indicated, all ownership percentages are 100%. Exhibit A - Page 1

Post-Transaction Corporate Ownership Structure of Licensee* J. Richard Shoemaker Eric B. Eisenhart William E. Shoemaker G. Franklin Shoemaker Other Owners Holding (U.S.) (U.S.) (U.S.) (U.S.) Less than 10 Percent 25.88% 21.23% 13.21% 12.69% Collectively, 26.99% Pinpoint Holdings, Inc. (“Transferor”) Other Members Holding (Nebraska) Less than 10 Percent John Scarano (U.S.) 61.73% Collectively, 38.27% Wyyerd Select Investors, LLC ESU Zona, LLC (“WSI”) (“ESU Zona”) Other Owners Holding (Delaware) (Delaware) Less than 10 Percent 19.20% 58.27% Collectively, approx. 23.53% Wyyerd Group, LLC * The entities listed herein only include (“Transferee”) Licensee and those entities or individuals (Delaware) currently in its chain of ownership. The chart excludes subsidiaries of Transferor whose control will not change following the Transaction. Accipiter Communications, Inc. d/b/a Zona Communications (Nevada) Unless otherwise indicated, all ownership percentages are 100%. Exhibit A - Page 2

VERIFICATIONS

VERIFICATION I, Scott Beer, state that I am Executive Vice President and Secretary of Wyyerd Group LLC (the "Company"); that I am authorized to make this Verification on behalf of the Company; that the foregoing filing was prepared under my direction and supervision; and that the contents thereof and the certifications contained therein regarding the Company and its affiliates, are true and cor— rect to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct. Executed this 72 0 day of June 2019. Name: Scott Beer—" a/ Title: Executive Vice President d Secretary Wyyerd Group LLC

VERIFICATION I, Michael Urdahl], state that I am President and Chief Executive Officer of Pinpoint Hold— ings, Inc., the parent company of Accipiter Communications Inc. d/b/a Zona Communications (the "Company"‘); that I am authorized to make this Verification on behalf of the Company; that the foregoing filing was prepared under my direction and supervision; and that the contents thereof and the certifications contained therein regarding the Company and its affiliates, are true and cor— rect to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct. Executed this 20" day of June 2019. Title: President and Chief Executive Officer Pinpoint Holdings, Inc.


Document Created: 2019-06-20 18:36:22
Document Modified: 2019-06-20 18:36:22
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