Attachment Supplement 6.23.08

This document pretains to SCL-LIC-20080516-00010 for License on a Submarine Cable Landing filing.

IBFS_SCLLIC2008051600010_680642

B IN G H A M Katie B. Besha Direct Phone: 202.373.6528 Direct Fax: 202.373.6001 katie.besha@bingham.com June 23, 2008 Via Courier Marlene H. Dortch, Secretary Federal Communications Commission R Office of the Secretary jos _ c/o Natek, Inc. ECE1VEF 236 Massachusetts Avenue, NE cR ; Suite 110 §EP q 4 2008 Washi ashington , DC 20002 Poligy DIVISIQ,) ’"fernat,y Di .. Re: . File No. ;SCL—LIC—20080516—00 ‘ e al By upplement {Sau Application for a License to nstruct, Land, and Operate an Undersea Fiber Optic Cable Connecting the United States and Japan Dear Ms. Dortch: This supplementis filed in connection with the above—captioned Application for a license to Construct, Land, and Operate an Undersea Fiber Optic Cable Connecting the United States and Japan, filed with the FCC on May 16, 2006. This supplement provides additional information with respect to the operation of the primary Network Operations Center for the Unity Cable System. Enclosed please find an original and six copies. Please contact the undersigned should you have any questions concerning this submission. Please date—stamp the enclosed extra Boston copy of this cover letter and return it with the courier. Hartford Hong Kong London Los Angeles New York Respectfully submitted, Orange County San Francisco Santa Monica Silicon Valley Katie B. Besha Tokyo Walnut Creek Washington Bingham McCutchen LLP 2020 K Street NW Washington, DC 20006—1806 T 202.373.6000 F 202.373.6001 bingham.com A/72556901.1

Before the FiL FEDERAL COMMUNICATIONS COMMISSION EE?/ACC*EPTEp Washington, D.C. 20554 JUN g Pedergy 3 2008 Off]g m nS C eofIh 8 $6or,OmIUIsS,On In the Matter of N/ NA NA NNN NNN NV N/ fary BHARTI AIRTEL LIMITED, GLOBAL TRANSIT LIMITED, GU HOLDINGS INC., KDDI CORPORATION, PACNET SERVICES (USA) INC., and SINGAPORE File No. SCL—LIC—20080516—00010 TELECOMMUNICATIONS LIMITED Application for a License to Construct, Land, and Operate an Undersea Fiber Optic Cable Connecting the United States and Japan SUPPLEMENT TO APPLICATION FOR A CABLE LANDING LICENSE STREAMLINED PROCESSING REQUESTED This supplement is filed in connection with the above—captioned Application for a License to Construct, Land, and Operate an Undersea Fiber Optic Cable Connecting the United States and Jépan ("Application"), filed with the Federal Communications Commission ("FCC") on May 16, 2008, to provide additional information with respect to the operation of the primary Network Operations Center for the Unity Cable System ("Unity"). In connection with the construction and operation of Unity, Applicants have entered into a NOC Operations and Administrations Agreement (the "NOC Agreement") between Singapore Telecommunications Ltd. ("SingTel") and the remaining Applicants. Pursuant to the NOC _ Agreement, the Network Operations Center ("NOC") for Unity will be located in Singapore and will be operated and administered by SingTel on behalf of Applicants. The NOC will provide a variety of specified functions related to the operation and ‘ management of the Common Infrastructure of Unity. Most fundamentally, the NOC will be A/T2564666.1

responsible for ensuring that Unity is operated and maintained in accordance with the performance levels established by the Unity parties and by international standards. This responsibility will include the ongoing monitoring of the Common Infrastructure of Unity, the collection and analysis of performance data from the various segments of the system, the coordination and oversight of routine maintenance, and the identification and resolution of faults affecting the Common Infrastructure. The NOC also will play a role in the activation, maintenance, and deactivation of capacity on the system, as well as the provisioning of equipment necessary to activate additional capacity. Specifically, the NOC will receive requests from an Applicant to activate (or deactivate) a portion of that Applicant‘s capacity and take the steps necessary to ensure that the requested capacity is provisioned in a timely manner. The NOC will serve as the point of contact for Applicants and their customers for issues related to the performance of capacity on Unity. Finally, the NOC will maintain the circuit database and the capacity ownership records for Unity. As described in the Application, a second, redundant, NOC will be located in the U.S. and will be controlled by Applicant GU Holdings. The Singapore NOC will have primary responsibility for the operation and administration of those portions of Unity located outside of the United States and will have secondary responsibility for those portions located in U.S. territory. Conversely, the U.S. NOC will be the primary NOC for the U.S. portions of Unity and will be the backup for all segments located outside U.S. territory. Because of this division of responsibility, the Singapore NOC also will be responsible for liaising with the U.S.‘NOC for operation and maintenance matters related to the U.S.—based facilities. Aside from its responsibilities related to the activation and maintenance of capacity on Unity, as described above, the NOC will have no role in the provision of services to customers of A/72564666.1

the Applicants or any ability to dictate how the Applicants utilize their assigned capacity. The NOC will not have access to customer information or records. More fundamentally, the NOC will receive only aggregate information regarding the usage by each Applicant of its assigned capacity and will be unable to determine how an Applicant is using its capacity, much less access the content of the communications of an Applicant or an Applicant‘s customers. Please do not hesitate to contact the undersigned if you have any questions regarding this filing. Respectfully subm‘ittefl,j Paul 0. Gagni William B. Wilhelm; Katie B. Besha Bingham McCutchen LLP 2020 K Street, N.W. Washington, DC 20006 Tel: (202) 373—6000 Fax: (202) 373—6001 Email: paul.gagnier@bingham.com william.wilhelm@bingham.com katie.besha@bingham.com Counsel for Applicants Dated: June 23, 2008 A/72564666.1

CERTIFICATE OF SERVICE The undersigned hereby certifies that the foregoing document was served this date upon the following: Hillary Morgan Ambassador David Gross Defense Information Systems Agency U.S. Coordinator Code RGC EB/CIP 701 S. Courthouse Road U.S. Department of State Arlington, VA 22204 2201 C Street, N.W. (via first class U.S. mail, postage prepaid) Washington, D.C. 20520—5818 (via first class U.S. mail, postage prepaid) David Krech Kathy Smith International Bureau . Office of Chief Counsel/NTIA Federal Communications Commission U.S. Department of Commerce 445 12th Street, S.W. 14"" Street and Constitution Ave., N.W. Washington, DC 20554 Washington, D.C. 20230 (via electronic mail to (via first class U.S. mail, postage prepaid) David.Krech@fee.gov) Susan O‘Connell International Bureau Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 (via electronic mail to Susan.O‘Connell@fec.gov) / 1 Katie Besha June 23, 2008 A/72564666.1


Document Created: 2008-11-26 15:50:07
Document Modified: 2008-11-26 15:50:07
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