public shareholders.[1] CUA is a wholly-owned subsidiary of China Unicom Global Limited, which is wholly-owned by China Unicom (Hong Kong) Limited.[2] Through multiple intervening holding companies, China Unicom owns approximately 52.1 percent of China Unicom Hong Kong.[3] Thus, China Unicom and the Chinese government-through intermediary companies-own CUA. The diagram below depicts the relevant ownership structure:
CUA's parent company influences CUA's operations and has access to U.S. customer records. China Unicom Global ("CUG"), which is based in Hong Kong, plays an important role in CUA's operations. It appoints CUA's management team, sets CUA's budget, and provides support for technical solutions, among other
- ↑ Id. at 32. See also Briefing with China Unicom Americas (Apr. 16, 2020).
- ↑ See generally China Unicom (Americas) Operations Limited, Notification of Pro Forma Transfer of Control of Section 214 Authority, File No. ITC-T/C-20170301-00025, Attach. 1 (filed Mar. 1, 2017), https://fcc.report/IBFS/ITC-T-C-20170301-00025 (unofficial website).
- ↑ In the Matter of China Unicom (Americas) Operations Limited, Response to Order to Show Cause, GN Docket No. 20-110, at 18 (June 1, 2020), http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/related_filing.hts?f_key=-32708&f_number=ITC2142002072800361.
- ↑ The diagram is based on information from the following: China Unicom FY2019 Form 20-F, supra note 434; Company Profile, China Unicom, https://www.chinaunicom.com.hk/en/about/profile.php; Briefing with China Unicom Americas (Apr. 16, 2020); In the Matter of China Unicom (Americas) Operations Limited, Response to Order to Show Cause, GN Docket No. 20-110, at Exhibit 2 (June 1, 2020), http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/related_filing.hts?f_key=-32708&f_number=ITC2142002072800361.
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