Page:2020-06-09 PSI Staff Report - Threats to U.S. Communications Networks.pdf/84

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CUA provides a range of communications services in the United States with its Section 214 authorizations. Like CTA, CUA is an international common carrier authorized to provide facilities-based and resale-based services.[1] Under its Section 214 authorizations, CUA may provide "international basic switched, private line, data, television and business services" directly through its own facilities or by reselling the services of any other authorized common carrier.[2] CUA informed the Subcommittee that it primarily resells the services of U.S. carriers, given that it does not own transmission infrastructure within the United States.[3]

CUA offers "reliable end-to-end global integrated telecommunication services and solutions" and "provides personal customers with premium voice and mobility services."[4] CUA advertises that it provides a range of services, including global connectivity services, global internet access, cloud, video conferencing, and content and security services.[5] As highlighted by Team Telecom in connection with CTA, some of these services are regulated by Section 214 and others are not.[6] For example, CUA operates as a MVNO, reselling mobile services of major U.S. providers to retail customers.[7] CUA's retail customers are primarily Chinese speaking individuals visiting or living in the United States.[8] CUA offers a "one-card-multiple-number" service that provides customers in the United States with a Chinese telephone number so that individuals in China can call the Chinese number to reach the U.S. customer without paying international toll charges.[9] U.S. customers in the United States can also use the service to call China using a local number.[10]


  1. See Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-00581, DA 02-2500, 17 FCC Red 19181, 19182 (Oct. 3, 2002). See also Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-00576, DA 02-2234, 17 FCC Red 16825, 16826 (Sept. 12, 2002) (China Netcom USA's 2002 authorization). China Netcom USA's authorization was subsequently assigned to CUA. See Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-01391, DA 09-2218, 24 FCC Red 12611, 12613 (Oct. 15, 2009).
  2. 47 C.F.R. § 63.22(d) (facilities-based international common carrier); 47 C.F.R. § 63.23(c) (resale-based international common carrier).
  3. Briefing with China Unicom Americas (Apr. 16, 2020).
  4. About—China Unicom Americas, LinkedIn, https://www.linkedin.com/company/china-unicom-americas.
  5. Id.
  6. Briefing with China Unicom Americas (Apr. 16, 2020); Executive Branch Recommendation re CTA, supra note 56, at 7-9 (Apr. 9, 2020).
  7. Briefing with China Unicom Americas (Apr. 16, 2020).
  8. Id.
  9. Id.; Email from Squire Patton Boggs, counsel to CUA, to the Subcommittee (June 3, 2020) (on file with the Subcommittee).
  10. Email from Squire Patton Boggs, counsel to CUA, to the Subcommittee (June 3, 2020) (on file with the Subcommittee).

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