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after accepting it for filing.[1] In June 2002, after establishing CTA, China Telecom assigned its Section 214 authorization to its American subsidiary.[2]

The 2001 authorization limited CTA to providing international services between the United States and international points, other than China.[3] A month after receiving the authorization from China Telecom, CTA separately applied for international Section 214 authorization to serve as a facilities-based carrier between the United States and China.[4] Again, the FCC sought Team Telecom's input on the application, directly stating that CTA was "100% owned by [a People's Republic of China] state-owned entity. . . ."[5] As with the 2001 application, neither the FCC nor Team Telecom had records of Team Telecom responding to the FCC's request. The FCC streamlined and approved CTA's application within two weeks of accepting the application for filing.[6]

2. After a Change in Ownership in 2007, Team Telecom Sought a Security Agreement with CTA

Team Telecom did not interact with CTA between 2002 and 2007. In fact, documents suggest that Team Telecom may not have understood that, prior to 2007, CTA was providing services between the United States and China.[7] In 2007,

  1. ↑ Compare Fed. Commc'ns Comm'n, Public Notice—International Applications Accepted for Filing, Rep. No. TEL-00417S, at 2 (July 6, 2001) with Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-00423, DA No. 01-1794, 16 FCC Red 14695, 14696 (July 26, 2001) (listing the authorization "date of action" as July 20, 2001-14 days after the public notice of acceptance of filing).
  2. ↑ See Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-00576, DA No. 02-2234, 17 FCC Red 16825, 16829 (Sept. 12, 2002) (listing the consummation date of the transfer as June 7, 2002).
  3. ↑ See Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-00423, DA No. 01-1794, 16 FCC Red 14695, 14696 (July 26, 2001). The authorization specifically noted that China Telecom was "prohibited from using its authorized U.S. international facilities or services to provide direct or indirect service to or from China unless and until it secures additional specific authority for such service. . . ." See id.
  4. ↑ See Fed. Commc'ns Comm'n, Public Notice—International Applications Accepted for Filing, Rep. No. TEL-00558S, at 2 (Aug. 7, 2002).
  5. ↑ FCC-PSI-000040-41.
  6. ↑ Compare Fed. Commc'ns Comm'n, Public Notice—International Applications Accepted for Filing, Rep. No. TEL-00558S, at 2 (Aug. 7, 2002) with Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-00567, DA 02-2060, 17 FCC Red 16199, 16201 (Aug. 22, 2002) (listing the authorization "date of action" as August 21, 2002-14 days after accepting the application for filing).
  7. ↑ Team Telecom's report detailing its March 2017 site visit states, "CTA was established in the U.S. in 2002 with the transfer to CTA of an FCC Section 214 license originally issued to China Telecommunications Corporation. In 2007, CTA applied for FCC authorization to modify the 2002 license to provide direct data service between the U.S. and China for the first time. This service was explicitly prohibited under the 2002 license. The request was approved in 2007. . . . See DHS00473PSI. This, however, misstates the distinction between China Telecom's June 2002 transfer of its Section 214 authorization to CTA and CTA's separate Section 214 authorization,

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