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Therefore, grant of [the] application would not be in the public interest.[1]

The FCC agreed that China Mobile USA was vulnerable to "exploitation, influence, and control by the Chinese government" and that there was a significant risk that the Chinese government would use the Section 214 authorization to further its economic and cyber espionage efforts against the United States.[2]

B. China Telecom Corporation and China Telecom Americas

China Telecom Corporation ("China Telecom"), a Chinese company and one of the Big Three providers in China, is an integrated information technology ("IT") services company that provides wireline, mobile telecommunications, Internet access, information and other telecommunications services.[3] It served more than 335 million subscribers worldwide as of December 31, 2019 and claims to be the largest fixed line and broadband operator in the world.[4]

China Telecom has been operating in the United States for nearly 20 years through its U.S. subsidiary, China Telecom Americas ("CTA"), a Delaware corporation.[5] CTA was founded in 2001 and obtained Section 214 authorization in 2002.[6] According to its website, CTA provides "a comprehensive range of high quality telecommunications services"[7] with the mission of delivering "high-quality data and voice solutions and services between the Americas and China to businesses and carriers."[8]

Team Telecom recently recommended the FCC revoke and terminate CTA's Section 214 authorizations. Although Team Telecom has recently begun exercising

  1. ↑ In the Matter of China Mobile Int'l (USA) Inc., FCC No. 19-38, 34 FCC Red 3361, 3361, ¶ 1 (May 10, 2019).
  2. ↑ Id. at 8, 14-19, 30-33.
  3. ↑ Overview, China Telecom, https://www.chinatelecom-h.com/en/company/company_overview.php.
  4. ↑ See China Telecom FY2019 Form 20-F, supra note 96, at 23; Company Overview, China Telecom Americas, https://www.ctamericas.com/company/company-overview/.
  5. ↑ See China Telecom FY2019 Form 20-F, supra note 96, at F-64. The company was originally named China Telecom USA, but changed its name to China Telecom Americas in October 2007 due to the company's expansion into Canada and Latin America. See FAQ's, China Telecom Americas, https://www.ctamericas.com/faqs/.
  6. ↑ See China Telecom FY2019 Form 20-F, supra note 96, at F-64; Briefing with Morgan, Lewis & Bockius LLP, counsel to CTA (May 7, 2020).
  7. ↑ Global Network, China Telecom Americas, https://www.ctamericas.com/company/global-network/. CTA informed the Subcommittee that it does not provide all services listed on its website in the United States. Its U.S. services are limited to "data/connectivity services between the Americas, China, and primarily Asia and Mobile Virtual Network Operator ('MVNO') services via the CTExcel brand name." Letter from Morgan, Lewis & Bockius LLP, counsel to CTA, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
  8. ↑ Company Overview—Mission, China Telecom Americas, https://www.ctamericas.com/company/company-overview/.

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