Page:2020-06-09 PSI Staff Report - Threats to U.S. Communications Networks.pdf/64

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anticipated providing in the future.[1] CTA informed Team Telecom that it was providing and anticipated continuing to provide international voice and data. services, including wholesale voice traffic, private line, internet protocol ("IP"), and virtual private network ("VPN") services to China, Asia, and other international locations.[2] Notably, CTA stated that it did not market domestic U.S. voice or data services; rather, it was focused on international data services.[3] To transmit data internationally, CTA indicated that it maintained switches and routers in various U.S. cities and from these locations connected to U.S. carrier networks.[4] CTA "[took] traffic that is delivered to [its points of presence in the United States] through leased private circuits to [CTA's leased] submarine cable landing stations . . . where the traffic is routed to China and other foreign destinations."[5]

[6]

CTA's responses also indicated that, as of May 2007, its customers were split among enterprise customers and other telecommunications carriers throughout the United States.[7] While CTA stated that it had no government customers, it did note that it was a subcontractor to Qwest (subsequently acquired by CenturyLink) to provide services to the U.S. Embassy in Mongolia.[8] CTA told the Subcommittee that it ceased subcontracting with Qwest to serve the U.S. Embassy in Mongolia in 2012, and that, as of May 2020, it does not serve as a subcontractor to any entity that provides services to a U.S. governmental facility.[9]


  1. See TT-DOJ-001-10. The Department of Justice was unable to locate the correspondence in which it transmitted questions to China Telecom Americas.
  2. See id. at TT-DOJ-001.
  3. Id.
  4. Id. at TT-DOJ-006.
  5. Id. See also DHS00475PSI ("CTA does not provide last mile service to customers in the U.S., nor does it operate its own transmission infrastructure within the U.S. Instead, CTA uses its U.S. points of presence in major U.S. cities to aggregate customer data traffic for transmission across Tier 1 U.S. networks to its software switch with access to the Los Angeles endpoint of a trans-Pacific consortium submarine cable.").
  6. The diagram is derived from information contained at TT-DOJ-001-10.
  7. TT-DOJ-001-10, at TT-DOJ-001.
  8. Id. at TT-DOJ-002.
  9. Letter from Morgan, Lewis & Bockius LLP, counsel to CTA, to the Subcommittee (June 2, 2020) (on file with the Subcommittee); Letter from Morgan, Lewis & Bockius LLP, counsel to CTA, to the Subcommittee (May 22, 2020) (on file with the Subcommittee).

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