Wikisource

Page:2020-06-09 PSI Staff Report - Threats to U.S. Communications Networks.pdf/102

This page has been proofread, but needs to be validated.

can make both domestic and international calls through ComNet's voice services platform.[1] According to Team Telecom, incoming VoIP calls are delivered to end-customers through 7G Network.[2] Team Telecom's records also indicate that ComNet provided basic enterprise IT services, such as video conferencing and website and software development.[3] Team Telecom flagged that these services were not contemplated at the time the security agreement was entered into and thus, the existing reporting requirements did little to address the associated risks.[4]

Unlike the other carriers discussed above, ComNet has only one point of presence in the United States, located in Los Angeles, California.[5] Team Telecom records describe the Los Angeles facility as "the premier communications hub of the Pacific Rim and arguably the single most important point of connectivity in the Western United States."[6] ComNet's servers, equipment, and data center are all housed at the Los Angeles facility, including the servers that support its various services and a billing server.[7]

ComNet has built relationships with major U.S. carriers. Like the other Chinese carriers, ComNet does not own transmission networks in the United States. It leases network capacity and equipment from major U.S. carriers to transport data from the Los Angeles facility to its end customers.[8] ComNet has established relationships with Verizon and Century Link, among other U.S. carriers.[9] Verizon maintains an interconnection agreement with ComNet and leases customer premise equipment, Ethernet private lines, general internet access, and private IP access.[10] Although not providing specifics, Century Link indicated that it had some limited commercial relationships with ComNet related to providing

  1. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); DHS00466-71, at DHS00468PSI.
  2. ↑ DHS00466-71, at DHS00468PSI. 7G Network is a U.S.-based telecommunications company. About—7G Network, Inc., LinkedIn, https://www.linkedin.com/company/7g-network-inc-/about/.
  3. ↑ DHS00466-71, at DHS00467PSI; TT-DOJ-521-23, at TT-DOJ-522.
  4. ↑ TT-DOJ-521-23, at TT-DOJ-522.
  5. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee).
  6. ↑ DHS00460PSI-65, at DHS00463PSI; DHS00466-71, at DHS00468PSI.
  7. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020).
  8. ↑ See generally DHS00460PSI–65; TT-DOJ-521–23.
  9. ↑ Briefing with Verizon (Sept. 4, 2019); Briefing with CenturyLink (Sept. 10, 2019). As noted above, in addition to voice and data termination services, ComNet obtains local access numbers needed for its retail calling card services from local carriers. Briefing with ComNet (Apr. 13, 2020); Letter from Lerman Senter PLLC, counsel to Com Net, to the Subcommittee (June 2, 2020) (on file with the Subcommittee). Unlike its relationships with CTA and CUA, AT&T's relationship with ComNet is limited to providing ComNet retail telephone and TV services for its own consumption. See Email from Gibson, Dunn & Crutcher LLP, counsel to AT&T, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
  10. ↑ Briefing with Verizon (Sept. 4, 2019).

98

Retrieved from "https://en.wikisource.org/w/index.php?title=Page:2020-06-09_PSI_Staff_Report_-_Threats_to_U.S._Communications_Networks.pdf/102&oldid=14521269"