Letter dated March 2

SUPPLEMENT submitted by AT&T CORP

Americas I Supplement - March 27, 2019

2019-05-20

This document pretains to SCL-LIC-20190326-00009 for License on a Submarine Cable Landing filing.

IBFS_SCLLIC2019032600009_1689651

                                            James J.R. Talbot                      AT&T Services, Inc.
                                            Assistant Vice President-              1120 20th Street NW Ste. 1000
                                            Senior Legal Counsel                   Washington, D.C. 20036

                                                                                   Phone: 202.457.3048
                                                                                   Fax:    202.463.8066
                                                                                   E-mail: jjtalbot@att.com

March 27, 2019

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

               Re: The Americas I Submarine Cable System Operating between the United
               States Mainland and St. Thomas in the U.S. Virgin Islands, File No. SCL-LIC-
               19921110-00002

Dear Ms. Dortch:

        The Americas I Consortium supplements and amends the above-referenced Application
filed and accepted in the Commission’s database with the appropriate fee on March 26, 2019
(“Application”) as follows.

       The table set forth below replaces the table set forth in Appendix B, page 2, of the
Application for a cable landing license for the Americas I Cable System to allow the continued
operation of this domestic submarine cable for an additional 25- year term. In the application,
Atlantic Telecommunication Operation Company Limited (“ATOC”) is a proposed licensee of
the Americas I Cable System. No individual or entity other than those set forth in the table
below holds a ten percent or greater direct or indirect equity or voting interest in ATOC.

         Blackrock, Inc. (“Blackrock”) has been added to this new table. Although Blackrock will
not hold a ten percent or greater indirect interest in ATOC if the multiplier is used to calculate
Blackrock’s interest, use of the multiplier is inappropriate in this instance pursuant to the Note to
Section 63.18(h) of the FCC’s rules, 47 C.F.R. § 63.18(h), note. This is because the indirect
interest of ATN International, Inc. (“ATNI”) in ATOC is above 50 percent and is controlling,
and Blackrock holds a direct interest in ATNI. The multiplier is not used to dilute an indirect
interest in a submarine cable landing licensee held through the controlling ownership chain of
that licensee.

                                                                                      Percentage of
                                                         Citizenship Principal
 Name                      Address                                                    Equity/Voting
                                                         or Country Business
                                                                                      Held
 Atlantic                  Commerce House,
 Teleconnection            Wickhams Cay 1, POB           British
                                                                                      100% of
 Holdings Company          3140, Road Town,              Virgin         Telecom
                                                                                      ATOC
 Limited                   Tortola, British Virgin       Islands
 (“ATHC”)                  Islands, VG111TBC


                                                  2



                                                                                      Percentage of
                                                       Citizenship Principal
    Name                     Address                                                  Equity/Voting
                                                       or Country Business
                                                                                      Held
    GTT International
                             79 Brickdam                                              100% of
    Service SRL                                        Barbados       Telecom
                             Georgetown, Guyana                                       ATHC
    (“GTT SRL”)
    Guyana Telephone &       79 Brickdam
                                                                                      100% of GTT
    Telegraph Company        Georgetown, Guyana        Guyana         Telecom
                                                                                      SRL
    Ltd (“GTT”)
                             Room 2801A, Lippo
    Hong Kong Golden
                             Centre, Tower 1,
    Telecom Company                                    Hong Kong      Telecom         20% of GTT
                             89 Queensway, Hong
    Limited (“HKGT”)*
                             Kong
                             500 Cummings Center,
    ATN International,
                             Suite 2450, Beverly,      USA            Telecom         80% of GTT
    Inc. (“ATNI”)**
                             MA 01915
                             55 East 52nd Street New                  Investment 10.2% of
    Blackrock, Inc.                                    USA
                             York, NY 10055                           Management ATNI
                             P.O. Box 12030
                             St. Thomas,                                              27.4% of
    Cornelius B. Prior Jr.                             USA            Retired
                             U.S. Virgin Islands                                      ATNI
                             00801

*
 ATOC was informed by representatives of HKGT in May 2018 that HKGT is 100% owned by
Datang Telecom International Technology (Hong Kong) Co., Ltd. (“DTIT”) and that DTIT is
indirectly controlled, but not wholly owned, by China Academy of Telecommunications
Technology. ATOC does not have any additional information about HKGT’s ultimate
ownership.
**
  ATNI is a publicly traded company listed on the NASDAQ (Ticker: ATNI). As of the date of
this filing, no individual or entity, has reported to the Securities and Exchange Commission that
it holds a direct or indirect 10 percent or greater equity or voting interest in ATNI, other than the
individual and the entity listed in the table above.


                                              3




      Please let us know if you have any questions.

                                              Respectfully submitted,




Of Counsel:
                                              James Talbot
Mark D. Schneider                             AVP- Senior Legal Counsel
Sidley Austin LLP                             AT&T Services, Inc. &
1501 K Street, NW                             Assistant Secretary
Washington, DC 20005                          AT&T Corp.
(202) 736-8058
mschneider@sidley.com


CC:   Jodi Cooper, International Bureau
      David Krech, International Bureau
      U.S. Coordinator, EB/CIP, U.S. Department of State
      Office of Chief Counsel/NTIA, U.S. Department of Commerce
      Defense Information Systems Agency, Attn: GC/DOI


                                         CERTIFICATION

       I am authorized to enter this certification on behalf of Atlantic Teleconnection Operating

Company Limited. All of the information contained herein is true and correct to the best of my

knowledge and belief.




Dated: March 27, 2019                                      Christopher Pepper
                                                           c/oATOC
                                                           500 Cummings Center, Suite 2450
                                                           Beverly, MA 01915
                                                           (561) 414-5543



Document Created: 2019-03-27 14:48:26
Document Modified: 2019-03-27 14:48:26

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