2. Pacific Networks' Initial Section 214 Authorization Prompted Team Telecom Review and Resulted in a Security Agreement
Pacific Networks applied for international Section 214 authorization in 2007 to provide international resale services between the United States and permissible international points, including China, solely by reselling unaffiliated U.S. facilities-based carriers' international switched services.[1] Although not majority owned, Pacific Networks disclosed that it was affiliated with the Chinese government, which held a 14 percent indirect ownership (29 percent attributable interest) in Pacific Networks through numerous intervening foreign organized holding companies.[2] The FCC referred the application to Team Telecom on September 14, 2007.[3]
Unlike the initial CTA and CUA applications, Team Telecom requested that Pacific Networks' application be removed from streamlining.[4] It engaged Pacific Networks to better understand the company's existing and anticipated activities, employees, and infrastructure.[5] Pacific Networks informed Team Telecom that it was not providing services to customers within the United States at the time it applied for Section 214 authorization.[6] However, Pacific Networks anticipated providing "international resold voice and data service for U.S. customers," including voice and SMS services, resale of leased circuit services, and internet exchange services.[7] Pacific Networks further explained that it planned to establish three points of presence within the United States—two in California and one in New York—and to interconnect with Qwest to relay calls to other carriers.[8] Pacific Networks indicated that it would not directly provide access to the public switched telephone network, but rather make such connections available through other local carriers, including AT&T and Qwest.[9] In addition to its written responses, Pacific Networks provided copies of its standing operating procedures for its network operations center, interface control documents, SMS service description, list of equipment, and point of presence configurations.[10]
Nearly a year after the FCC referred the application, in September 2008, Team Telecom alerted the FCC that it had completed its review and had no
- ↑ See Pacific Networks Corp., International Section 214 Application File No. ITC-214-20070907-00368, https://fcc.report/IBFS/ITC-214-20070907-00368/590946 (unofficial website). See also DHS00460PSI.
- ↑ Pacific Networks Corp., International Section 214 Application File No. ITC-214-20070907-00368, at Attach. 1, https://fcc.report/IBFS/ITC-214-20070907-00368/590946 (unofficial website).
- ↑ FCC-PSI-000412-13.
- ↑ FCC-PSI-000415.
- ↑ Cf. TT-DOJ-045-60.
- ↑ See id. at TT-DOJ-045.
- ↑ See id.
- ↑ Id. at TT-DOJ-056.
- ↑ Id. at TT-DOJ-056-57.
- ↑ See generally TT-DOJ-061–101.
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