These services allow CUA to deliver traffic from a CUA point of presence through. CenturyLink's network to a CUA customer located in the United States.[1]
Neither Verizon, AT&T, nor CenturyLink maintains any mitigation or other agreement focused on network security with CUA.[2] As noted above, however, the U.S. carriers employ security measures that apply regardless of whether an interconnection agreement exists.[3]
*****
On April 24, 2020, the FCC issued an order requiring CUA to demonstrate why its Section 214 authorizations should not be revoked.[4] CUA responded to the order on June 1, 2020.[5]CUA argued that it has complied with FCC regulations and provided quality services to its customers for over two decades.[6] Further, CUA stressed that it is subject to U.S. corporate laws and has "demonstrated willingness to cooperate with U.S. law enforcement agencies when asked."[7] CUA also argued that the federal government has not highlighted any CUA activity that might endanger national security, aside from partial and indirect ownership by the Chinese government.[8] The latter, according to CUA, is not a sufficient basis for revocation.[9] Finally, CUA detailed why it is not subject to exploitation, influence, or control by the Chinese government.[10] The FCC is evaluating the information CUA submitted and considering whether to revoke its authorizations.
Similarly, in anticipation of this report being released, CUA submitted a letter to the Subcommittee seeking to distinguish CUA from "other, similar companies in the market in terms of shareholding structure, corporate governance,
- ↑ Id. CenturyLink purchases the same network services from the Chinese carriers in China, to allow CenturyLink to deliver traffic to a CenturyLink customer based in China. Id.
- ↑ See Briefing with Verizon (Sept. 4, 2019); Briefing with CenturyLink (Sept. 10, 2019); Briefing with AT&T (Sept. 17, 2019). Verizon representatives indicated that the company's contractual agreements with CUA are substantially identical to those it maintains with other carriers. Teleconference with Verizon (June 2, 2020).
- ↑ Briefing with Verizon (Sept. 4, 2019); Briefing with CenturyLink (Sept. 10, 2019); Briefing with AT&T (Sept. 17, 2019); Teleconference with Verizon (June 2, 2020); Email from CenturyLink to the Subcommittee (June 2, 2020) (on file with the Subcommittee); Email from Gibson, Dunn & Crutcher LLP, counsel to AT&T, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
- ↑ See In the Matter of China Unicom (Americas) Operations Limited, Order to Show Cause, DA 20-449 (Apr. 24, 2020), https://docs.fcc.gov/public/attachments/DA-20-449A1.pdf.
- ↑ See In the Matter of China Unicom (Americas) Operations Limited, Response to Order to Show Cause, GN Docket No. 20-110 (June 1, 2020), http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/related_filing.hts?f_key=-32708&f_number=ITC2142002072800361.
- ↑ Id. at i.
- ↑ Id. at ii.
- ↑ Id. at ii, 2.
- ↑ Id. at 9-10.
- ↑ Id. at 30-32.
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