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items.[1] CUA also consults with its parent company before establishing any point of presence in the United States.[2]

CUG also manages CUA's U.S. customer records. According to a CUA representative, customer records are stored on servers in Hong Kong and maintained by CUG.[3] CUA and CUG have signed a confidentiality agreement that governs access to the records and also establishes procedures to protect customer proprietary network information.[4] Access to U.S. records is governed by this agreement, which includes requiring those seeking access to have a business justification; however, CUA representatives suggested that CUG decides what constitutes a sufficient justification.[5] When questioned about this arrangement, CUA representatives explained that it is necessary for CUG to have access to all customer records given the nature of the international services provided by CUG's subsidiaries.[6] The representatives described this treatment as "common among international carriers."[7] They also indicated that, for enterprise customers, the information shared between affiliates is that which is necessary for provisioning and customer service.[8] For mobile virtual network operator ("MVNO") services, CUA chooses to use a service platform in Hong Kong because "the subscriber base does not warrant a standalone U.S. platform."[9]

CUA also informed the Subcommittee that its parent company monitors CUA's network operations to ensure that the global network is performing consistently.[10] CUA also leverages CUG's network operations center, located in Hong Kong, for technical support.[11] CUA engineers manage CUA's U.S.-based network equipment; however, representatives confirmed that CUG can remotely configure CUA's network equipment.[12]

  1. ↑ Briefing with China Unicom Americas (Apr. 16, 2020). See also In the Matter of China Unicom (Americas) Operations Limited, Response to Order to Show Cause, GN Docket No. 20-110, at 20 (June 1, 2020), http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/related_filing.hts?f_key=-32708&f_number=ITC2142002072800361.
  2. ↑ Briefing with China Unicom Americas (Apr. 16, 2020).
  3. ↑ Id.
  4. ↑ Id. See also Email from Squire Patton Boggs, counsel to CUA, to the Subcommittee (June 3, 2020) (on file with the Subcommittee).
  5. ↑ Email from Squire Patton Boggs, counsel to CUA, to the Subcommittee (June 3, 2020) (on file with the Subcommittee); Briefing with China Unicom Americas (Apr. 16, 2020).
  6. ↑ Briefing with China Unicom Americas (Apr. 16, 2020).
  7. ↑ Id.
  8. ↑ Email from Squire Patton Boggs, counsel to CUA, to the Subcommittee (June 3, 2020) (on file with the Subcommittee).
  9. ↑ Id.
  10. ↑ Briefing with China Unicom Americas (Apr. 16, 2020).
  11. ↑ Id.
  12. ↑ Letter from Squire Patton Boggs, counsel to CUA, to the Subcommittee (Apr. 29, 2020) (on file with the Subcommittee).

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