Attachment Waiver Request

This document pretains to SES-T/C-20131202-01168 for Transfer of Control on a Satellite Earth Station filing.

IBFS_SESTC2013120201168_1029274

Global Crossing Americas Solutions, Inc. Response to Form 312 Question 35 WAIVER REQUEST Global Crossing Americas Solutions, Inc. (“GCAS”), seeks Commission consent to a pro forma transfer of control of non-common-carrier transmit-receive earth station authorizations resulting from the Pro Forma Transactions described in Exhibit F of this application. The Pro Forma Transactions resulted from an internal corporate reorganization process following the acquisition of Global Crossing Limited by Level 3 Communications, Inc. (“Level 3 Parent”) in 2011, following Commission review and consent.1 Level 3 Parent undertook this internal reorganization process—involving indirect parent entities of GCAS—in order to simplify the ownership structure of its holding and operating companies and to discharge the debt of Global Crossing Limited. The need for a pro forma transfer of GCAS’s earth station authorizations may have been inadvertently overlooked. Out of an abundance of caution, GCAS has filed the attached application to update the Commission’s records. To the extent necessary, GCAS respectfully requests that the Commission waive 47 C.F.R. § 25.119 and accept this late-filed application. Pursuant to 47 C.F.R. § 1.3, the Commission may suspend, revoke, amend, or waive any of its rules upon a showing of good cause and where grant of the waiver will serve the public interest.2 GCAS submits that good cause exists in this case to permit a waiver of the Commission’s rules. The oversight was inadvertent, and ultimate control of the licenses has not changed. 1 Applications filed by Global Crossing Limited and Level 3 Communications, Inc. for Consent to Transfer Control, Memorandum Opinion and Order and Declaratory Ruling, 26 FCC Rcd. 14,056 (Int’l, Wireless Tel. and Wireline Comp. Burs. 2011). 2 See WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969).


Document Created: 2019-04-26 00:07:55
Document Modified: 2019-04-26 00:07:55
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC