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and other areas."[1] In the letter, CUA reiterated many of the points made in its response to the FCC's show cause order. This includes that CUA has complied with U.S. laws, has never been accused of criminal conduct or violation of FCC regulations, and is not subject to the exploitation, influence, or control of the Chinese government.[2] The letter also details CUG's and China Unicom Hong Kong's independence and describes recent actions taken by CUA to strengthen its corporate governance and compliance program.[3]

D. ComNet (USA) LLC and Pacific Networks Corp.

ComNet (USA) LLC ("ComNet") (formerly known as CM Tel (USA) LLC[4]) is a telecommunications service provider that "offer[s] telecom partners and operators international termination services, calling card[s] and global SIM card[s]."[5] Its website also states that it provides "enterprise business phones system, [messaging], managed network and IT service, website and WeChat related development, etc."[6] ComNet (then CM Tel (USA) LLC) was incorporated in Delaware in July 1999.[7] At that time, the company was a subsidiary of CM Telecom International Limited, a Hong Kong based company.[8] In 2009, ComNet was acquired by CITIC Telecom International Holdings Limited ("CITIC"),[9] which describes itself as one of Asia Pacific's leading telecommunications service providers of "mobile international roaming, international voice, international SMS, international data and international value-added telecommunications services, etc.

  1. ↑ Letter from Squire Patton Boggs to Rob Portman, Chairman, Permanent Subcomm. on Investigations, and Tom Carper, Ranking Member, Permanent Subcomm. on Investigations (June 3, 2020).
  2. ↑ Id.
  3. ↑ Id.
  4. ↑ CM Tel (USA) LLC changed its name to ComNet in 2009. See ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee).
  5. ↑ About Us, ComNet (USA) LLC, https://www.comnet-telecom.us/about-us. ComNet resells SIM cards of mobile wireless companies; it does not provide wireless service over its network. Letter from Lerman Senter PLLC, counsel to ComNet, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
  6. ↑ See ComNet (USA) LLC, LinkedIn, https://www.linkedin.com/company/comnet-telecom.
  7. ↑ ComNet (USA) LLC, Statement of Information for the Fiscal Year Ended Dec. 31, 2018 (LLC-12) Filed with the Sec'y of State of the State of California, File No. 19-C86032 (July 29, 2019), https://businesssearch.sos.ca.gov/Document/RetrievePDF?Id=199920510003-26628618; ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee).
  8. ↑ See In the Matter of CM Tel (USA) LLC Application for Authority Pursuant to Section 214 of the Communications Act of 1934, as Amended, for Global Authority to Operate as an International Facilities-Based and Resale Carrier (Sept. 27, 1999), https://fcc.report/IBFS/ITC-214-19990927-00607 (unofficial website).
  9. ↑ See CITIC Pacific, Annual Report 183 (2010), https://www.citic.com/uploadfile/2017/0525/20170525102539646.pdf ("In 2009 a listed subsidiary group of the Company CITIC Telecom acquired the remaining 51% equity interest in CM Tel (USA) LLC (renamed as ComNet (USA) LLC in July 2009 . . . ."). At this time, CM Tel (USA) LLC formally changed its name to ComNet (USA) LLC. ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee).

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