Telstra-Pacnet SCL T

LETTER submitted by Telstra Holdings Pty Limited

Letter re: 1.767(a)(11)(i) Ownership Information

2015-02-13

This document pretains to SCL-T/C-20150202-00004 for Transfer of Control on a Submarine Cable Landing filing.

IBFS_SCLTC2015020200004_1076810

KELLEY DRYE & W ARREN LLP A LI MIT E D LIA BI LIT Y P ART NER SHI P WASHI NGT ON HARBOUR, SUIT E 400 NEW YO RK, NY F ACSIM I LE LOS A NGE LES, CA 3050 K STREET , NW ( 202) 342 - 8451 CHI CAGO, I L www.kelleydrye.com WASHI NGT ON, D. C. 20 007- 5108 S TAM FORD, CT P A RSI PP A NY, NJ (202) 342-8400 DENISE N. SMITH B RUS SE LS, BE LGI UM DIRECT L INE: (202) 3 42-8614 EMA IL: ds mi th@kelleyd rye.co m AFFILIATE OFFICES MUMBAI, INDIA February 13, 2015 BY IBFS Ms. Jodi Cooper International Bureau Federal Communications Commission 445 12th Street, SW Washington, D.C. 20554 Re: Transfer of Control of Application of Pacnet International Limited, Pacnet Limited, Pacnet Services (USA) Inc., Telstra Holdings Pty Limited and Bedrock Holdings (Bermuda) Limited for a Transfer of Control of a Submarine Cable Landing License, SCL-T/C-20150202-00004 Supplemental Ownership Information Dear Ms. Cooper: On February 2, 2015, an application was filed with the Federal Communications Commission (“FCC”) requesting consent to the transfer of control that will occur as a result of a merger transaction (“Merger Transaction”) involving Pacnet International Limited, Pacnet Limited, Pacnet Services (USA) Inc., Telstra Holdings Pty Limited (“Telstra Holdings”) and Bedrock Holdings (Bermuda) Limited (“Bedrock Holdings”) (“Telstra Holdings” with “Bedrock Holdings”, the “Telstra Applicants”). Pacnet Services holds a submarine cable landing license on the Unity Cable System. In response to your e-mail request made on February 11, 2015, the Telstra Applicants provide additional information, pursuant to section 1.767(a)(11)(i) of the FCC’s rules, 47 C.F.R. § 1.767(a)(11)(i), regarding the percentage of voting and ownership interests held by the three entities that hold ten percent or more of the stock of Telstra Corporation Limited (“Telstra Corp.”). Telstra Corp. is the direct parent of Telstra Holdings and indirect parent of Bedrock Holdings. Telstra Corp. is a company formed under the laws of Australia with registered offices at Level 25, 242 Exhibition Street, Melbourne in Victoria, Australia 3000. Telstra Corp.

KELLEY DRYE & WARREN LLP Ms. Jodi Cooper February 13, 2015 Page 2 is a publicly traded company and, as such, its ownership is widely held. The following three entities hold 10 percent or more of the outstanding stock of Telstra Corp. The percentage of voting and ownership interests held by each entity is included below. 1. HSBC Custody Nominees (Australia) Limited Address: HSBC Centre Level 32, 580 George Street Sydney, NSW 2000 Citizenship: Australia Principal business: Asset management company Percent Ownership Interest: 15.48% Percent Voting Interest: 15.48% 2. J.P. Morgan Nominees Australia Ltd. Address: Level 26, Grosvenor Place 225 George Street Sydney, NSW 2000 Citizenship: Australia Principal business: Asset management company Percent Ownership Interest: 12.26% Percent Voting Interest: 12.26% 3. National Nominees Limited Address: Level 12, 500 Bourke Street Melbourne, VIC 3000 Citizenship: Australia Principal business: Asset management company Percent Ownership Interest: 11.96% Percent Voting Interest: 11.96% Should you have any questions regarding this filing please direct them to the undersigned at (202) 342-8400.

KELLEY DRYE & WARREN LLP Ms. Jodi Cooper February 13, 2015 Page 3 Respectfully submitted, John Heitmann. Denise N. Smith Counsel to Telstra Corporation Limited, Telstra Holdings Pty Limited and Bedrock Holdings (Bermuda) Limited cc: Jodi Cooper, FCC (by e-mail) Adrienne Downs, FCC (by e-mail) David Krech, FCC (by e-mail) Edward A. Yorkgitis, Jr. (by e-mail) Caroline Brown, DOJ (by e-mail) John Carlin, DOJ (by e-mail) Jonathan Frenkel, FBI (by e-mail) Richard Hagar, DHS (by e-mail) Defense Information Systems Agency (by overnight delivery) U.S. Department of Commerce (by overnight delivery) U.S. Department of State (by overnight delivery)


Document Created: 2015-02-13 14:15:49
Document Modified: 2015-02-13 14:15:49
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