CUA also provides a range of business data services, including international private lines and lease circuits.[1] According to CUG's website, private lines provide customers "end to end dedicated and permanent digital point to point connectivity between two regions."[2] CUA also provides end-to-end connectivity through international Ethernet connections and multi-protocol label switching ("MPLS") VPN.[3] MPLS VPN is either "built on the IP carrier network" or uses a "series of virtual switches leased to" customers to allow them to securely transmit data, such as internal data, voices, images and videos, between different locations.[4]
CUA's primary business line is broadband internet services for customers in both the United States and China.[5] CUG "ha[s] direct connection[s] to major [internet service providers] in many countries makes [sic] Internet access faster and minimizes distance delays."[6] CUA informed the Subcommittee that it peers with 26 IP partners for the exchange of internet traffic.[7] CUA also provides data center, and cloud computing services,[8] for which Section 214 authorization is not needed.[9]
To provide these services, CUA has established 11 points of presence—five on the East coast, five on the West coast, and one in the Midwest.[10] The points of presence consist of CUA-owned routers installed in colocation facilities leased from third-parties.[11] China Unicom also advertises that it operates points of presence across the world, specifically mentioning the locations in Los Angeles, New York, and San Jose, which "provide . . . for customer and partner network interconnections."[12] In fact, China Unicom promotes its international MPLS VPN
- ↑ Briefing with China Unicom Americas (Apr. 16, 2020). See also Customer Solutions, China Unicom Global, at 15, https://www.chinaunicomglobal.com/group1/M00/00/08/CngaWFoofQOAfarRAPYieoOnUf8345.pdf.
- ↑ See Customer Solutions, China Unicom Global, at 15, https://www.chinaunicomglobal.com/group1/M00/00/08/CngaWF00fQOAfarRAPYieoOnUf8345.pdf.
- ↑ Briefing with China Unicom Americas (Apr. 16, 2020). In its recommendation to revoke CTA's authorizations, Team Telecom described MPLS VPN services as falling into a "regulatory gray area." Executive Branch Recommendation re CTA, supra note 56, at 7-9 (Apr. 9, 2020).
- ↑ See MPLS VPN, China Unicom Global, https://www.chinaunicomglobal.com/hk/mplsvpn.
- ↑ Briefing with China Unicom Americas (Apr. 16, 2020).
- ↑ See Customer Solutions, China Unicom Global, at 25, https://www.chinaunicomglobal.com/group1/M00/00/08/CngaWF00fQOAfarRAPYieoOnUf8345.pdf.
- ↑ Briefing with China Unicom Americas (Apr. 16, 2020); 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). CUA resells the services of a data center provider. It does not own, control, or manage the data center itself. Id.
- ↑ Executive Branch Recommendation re CTA, supra note 56, at 10.
- ↑ Briefing with China Unicom Americas (Apr. 16, 2020). The points of presence are located in (1) Seattle, WA; (2) Hillsboro, OR; (3) Palo Alto, CA; (4) San Jose, CA; (5) Los Angeles, CA; (6) Dallas, TX; (7) Reston, VA; (8) Ashburn, VA; (9) Chicago, IL; (10) New York, NY; and (11) Miami, FL.
- ↑ Id. The routers are used for CUA's 3 IP data networks. Id.
- ↑ See Customer Solutions, China Unicom Global, at 17, https://www.chinaunicomglobal.com/group1/M00/00/08/CngaWF00fQOAfarRAPYieoOnUf8345.pdf.
81
