Attachment Attachment 1

This document pretains to ROA-NEW-INTR2018-01955 for New Application on a Recognized Operating Authority filing.

IBFS_ROANEWINTR201801955_1404541

ROA Application Limitless Mobile, LLC Page 1 of 2 ATTACHMENT 1 Pursuant to the applicable requirements for Recognized Operating Agency Authority as set forth in 47 C.F.R. §63.701 and the instant application for Recognized Operating Agency, Limitless Mobile, LLC. (“Applicant”) hereby provides the following supplemental information: 47 C.F.R. §63.701(d). “A statement of the ownership of a non-corporate applicant or the ownership of the stock of a corporate applicant, including whether the applicant or its stock is owned directly or indirectly by an alien.” Applicant is a limited liability company organized under the laws of Delaware. The sole member in Applicant is Tower Bridge Mobile Holdings, LLC (“TBMH”) which is also a limited liability company organized under the laws of Delaware. The following entities hold membership interests of 10% or more in TBMH: Richard B. Worley 29.73% Sarah Miller Coulson 29.73% Roberto Sella 29.73% All membership interests in TBMH are held by U.S. citizens. Additionally, as noted in response to question 13 of the attached application form,, the foregoing members of TBMH also separately hold an indirect ownership interest of greater than 25% in three foreign carriers: Limitless Mobile AB (Sweden); Limitless Mobile SP Z.O.O. (Poland); and Limitless Mobile ApS (Denmark). These interests have been previously disclosed to the Commission. See IBFS File No. FCN-NEW-20140815- 00012. As noted in that filing, none of these carriers is dominant in the countries in which they operate and all three operate as non-facilities based resellers. 47 C.F.R. §63.701(f). “A statement whether the applicant is a carrier subject to Section 214 of the Communications Act, an operator of broadcast or other radio facilities, licensed under Title III of the Act, capable of causing harmful interference with the radio transmissions of other countries, or a non-carrier provider of services classed as ‘enhanced’ under Section 64.702(a).” Applicant is a carrier subject to Section 214 of the Act and holds a Section 214 authorization to provide Global Resale services. See IBFS File No. ITC-214-20100525- 00214. Applicant also holds two broadband PCS licenses and approximately a dozen related microwave licenses over which the Applicant provides domestic mobile voice and data services to customers in its licensed territory. None of these licenses or operations will cause harmful interference with the radio transmissions of other countries. 47 C.F.R. §63.701(g). “A statement that the services for which designated as a recognized private operating agency is sought will be extended to a point outside the United States or are

ROA Application Limitless Mobile, LLC Page 2 of 2 capable of causing harmful interference to other radio transmissions and a statement of the nature of the services to be provided.” The services, as described in the response to the 47 C.F.R. §63.701(h) inquiry, will extend to points outside the United States. The services are not capable of causing harmful interference to radio transmissions. 47 C.F.R. §63.701(h). “A statement setting forth the points between which the services are to be provided.” Applicant provides M2M and IOT services to Applicant’s customers in worldwide destinations. 47 C.F.R. §63.701(i). “A statement as to whether covered services are provided by facilities owned by the applicant, by facilities leased by another entity, or other arrangement and a description of the arrangement.” Applicant’s covered services provided over facilities that are resold or leased from other providers except as to Internet communications. Applicant’s data center location and switching facilities located in Harrisburg, PA are owned by Applicant.


Document Created: 2018-05-25 15:52:15
Document Modified: 2018-05-25 15:52:15
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