Attachment Level 3 214 Surrende

Level 3 214 Surrende

SURRENDER OF AUTHORIZATION

Surrender Letter

2008-07-14

This document pretains to SUR-NDR-20080714-00025 for Surrender (SUR-NDR) on a Surrender filing.

IBFS_SURNDR2008071400025_653567

                                                                     1200 18TH STREET, N.W.
                                                                     SUITE 1200
                                                                     WASHINGTON, D.C. 20036-2516
                                                                     UNITED STATES OF AMERICA

                                                                     TEL +1 202 730 1300
                                                                     FAX +1 202 730 1301
                                                                     WWW.HARRISWILTSHIRE.COM




14 July 2008



BY HAND DELIVERY

Ms. Marlene Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

       Re:     Surrender of International Section 214 Authorizations and Notification of
               Provision of International Telecommunications Services Through Wholly-Owned
               Subsidiaries of Level 3 Communications, LLC

Dear Ms. Dortch:

       Pursuant to Section 63.21(h) of the Commission’s rules, six wholly-owned subsidiaries of
Level 3 Communications, LLC (“Level 3”) surrender their international Section 214
authorizations and notify the Commission of their reliance on the international Section 214
authorization of their parent company.

        Between 2005 and 2007, Level 3 and its direct and indirect parent companies
consummated a number of corporate acquisitions resulting in its ownership of a variety of
entities holding international Section 214 authorizations. These authorizations are duplicative of
the global facilities-based and global resale authority in the international Section 214
authorization held by Level 3.

        To reduce the administrative burden associated with its Commission authorizations, these
six subsidiaries are surrendering their international Section 214 authorizations, as detailed in
Table 1 below. Instead, they will provide international telecommunications services in reliance
on the international Section 214 authorization of Level 3, FCC File No. ITC-214-19971229-


HARRIS, WILTSHIRE & GRANNIS LLP

Ms. Marlene Dortch
Federal Communications Commission
14 July 2008
Page 2 of 3




   00821 (Old FCC File No. ITC-98-016).1 Consistent with the requirements of Section 63.21(h) of
   the Commission’s rules, these six subsidiaries are entitled to rely on the international Section 214
   authorization of Level 3. Neither Level 3 nor any of these six subsidiaries is regulated as
   dominant for a particular route. Each of the six subsidiaries will commence service in reliance
   on Level 3’s international Section 214 authorization as of the date of this surrender notice.

                                                     Table 1

                                                                                 File Number Associated
                                        Place of
               Subsidiary                                 Original File Number   with Transfer of Control
                                      Organization
                                                                                        to Level 3

   Broadwing Communications, LLC      Delaware         ITC-214-20030313-00134    ITC-T/C-20061017-00475

   Eldorado Acquisition Three, LLC,   Delaware         ITC-214-19971128-00747    ITC-ASG-20060609-00313
   fka TelCove, Inc.

   ICG Telecom Group, Inc.            Delaware         ITC-214-19980508-00305    ITC-T/C-20060417-00237

   Looking Glass Networks Holding     Delaware         ITC-214-20000612-00357    ITC-T/C-20060615-00319
   Company, Inc.

   Vyvx, LLC                          Delaware         ITC-214-20050907-00365    ITC-T/C-20051102-00461

   WilTel Communications, LLC         Delaware         ITC-214-19970115-00025    ITC-T/C-20051102-00460


           These six subsidiaries will continue to provide the same services before and after these
   relinquishments and commencement of service in reliance on Level 3’s international Section 214
   authorization. At no time will any of these subsidiaries provide international
   telecommunications services without Commission authority—whether issued in the name of
   each subsidiary pre-surrender and in reliance on Level 3’s authorization post-relinquishment.




   1
       An affiliate of Level 3, Level 3 International, Inc., will continue to provide international
       telecommunications services in reliance on its own international Section 214 authorization,
       FCC File No. ITC-214-19981214-00867. Level 3 International, Inc., is not surrendering this
       authorization.


HARRIS, WILTSHIRE & GRANNIS LLP

Ms. Marlene Dortch
Federal Communications Commission
14 July 2008
Page 3 of 3




          Should you have any questions regarding this notification, please contact me by
   telephone at +1 202 730 1337 or by e-mail at kbressie@harriswiltshire.com.

                                                 Respectfully submitted,




                                                  Kent D. Bressie
                                                  HARRIS, WILTSHIRE & GRANNIS LLP
                                                  1200 18th Street, N.W.
                                                  Suite 1200
                                                  Washington, D.C. 20036
                                                  +1 202 730 1337

                                                  Counsel for Level 3 Communications, LLC,
                                                  and Its Subsidiaries

   cc:     James Ball (IB)
           David Krech (IB)



Document Created: 2008-07-14 13:10:25
Document Modified: 2008-07-14 13:10:25

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