Attachment September 23 GCN Lic

This document pretains to SCL-MOD-20140923-00009 for Modification on a Submarine Cable Landing filing.

IBFS_SCLMOD2014092300009_1061996

FI.rHMAN ADVISOFISPLLC 4OO Centnal Pank West 3R, New York, New York 1OO25 tel 24O-475-O62O September 23,2014 Via IBFS Marlene H. Dortch Secretary Federal Communications Commission 44512do Street, SW Washington, DC 20554 Re: Global Caribbean Network SAS File Nos. ITC-214-20050623-00237, ITC-ZI4-20050621-00231, and SCL-LIC- 20050418-00010 Modification of License Request Dear Ms. Dortch: By its attomey, Global Caribbean Network SAS ("GCN") hereby reports to the Commission that, effective September 8, 2014, together with its parent companies Global Caribbean Fiber SAS (*GCF") and Auto-Guadeloupe Investissement, S.A. ("AGI") (collectively, the 'ol,oret Companies"), it entered into the attached Network Security Agreement with the U.S. Department of Homeland Security and the U.S. Department of Justice (the "U.S. Govemment Parties"). GCN requests that the Commission condition GCN's above-captioned authorizations upon the compliance by the Loret Companies to the terms of the Network Security Agreement. Background. The Loret Companies entered into the Network Security Agreement at the request of the U.S. Government Parties in connection with their review of the application for transfer of control of Antilles Crossing - St. Croix, Inc. ("ACSC") from GCF to Fiber Investment Holdings Limited IBC (*FIHL"). By Public Notice, DA 14-1311, released September 10, 2014, the Commission announced its grant of that application subject to the compliance by ACSC and FIHL to the terms of the December 7,2007 Agreement by and among ACSC, Leucadia National Corporation and AGI, as amended by the September 8, 2014 Amendment No. I to the December 7,2007 Agreement. See SCL-T/C-20131219- 00017. In conjunction with their review of the ACSC transfer of control application, the U.S. Government Parties also requested the Loret Companies to enter into a separate Network Security Agreement governing the GCN submarine fiber optic network, and that the above- captioned GCN authorizations be conditioned upon compliance by the Loret Companies with the terms of the Network Security Agreement. Legal and consulting services for telecommunications and information technology eric@f ishmanadvisors. com www.f ishma nadvisors. com

Please direct any questions regarding this matter to the undersigned counsel. r* Sincerely, Eric Fishman Counsel to Global CaribbeanNetwork SAS Global Caribbean Fiber SAS and Auto-Guadeloupe lnvestissement, S.A. Enclosure cc: David Krech, Intemational Bureau david.krech@fcc.gov Deparhnent of Justice Assistant Attomey General National Security Division 950 Pennsylvania Avenue, NW Washington, DC 20530 ttelecom@usdoj.gov Deparfinent of Homeland Security Assistant Secretary Offfice of Policy C/O Director, Foreign lnvestnent Risk Management 245 Munay Lane, SW Mail Stop: 0445 Washington, D.C. 20528 ip-fcc@hq.dhs.eov 2


Document Created: 0250-04-12 00:00:00
Document Modified: 0250-04-12 00:00:00
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