network services, circuits, or collocation services.[1] As with CTA and CUA, neither Verizon nor CenturyLink maintains any mitigation or other agreement focused on network security with ComNet under their current arrangements.[2] The U.S. carriers do, however, employ security measures that apply regardless of whether an interconnection agreement exists.[3]
＊＊＊＊＊
On April 24, 2020, the FCC issued an order requiring ComNet (and Pacific Networks) to demonstrate why its Section 214 authorizations should not be revoked.[4] The companies jointly responded to the order on June 1, 2020.[5] The companies stressed that they have successful business records and have complied fully with FCC regulatory requirements and Team Telecom requests.[6] Further, the companies stated that they have never been “asked by the Chinese government or the Chinese Communist Party to take any action that would ‘jeopardize the national security and law enforcement interests of the United States’ or would suggest that the Companies are vulnerable ‘to the exploitation, influence, and control of the Chinese government.’”[7] As with CUA, ComNet and Pacific Networks noted that the federal government has not highlighted any activity taken by either company that might endanger national security, aside from being “ultimately owned by public companies with partial Chinese state ownership.”[8] The companies distinguished their licensing history from that of China Mobile USA.[9] ComNet and Pacific Networks concluded their response by noting, although revocation is not warranted, should additional mitigation be deemed necessary, they are open to discussing appropriate conditions with the FCC or Team Telecom.[10] The FCC is evaluating the information ComNet and Pacific Networks submitted and considering whether to revoke their authorizations.
99
- ↑ Briefing with CenturyLink (Sept. 10, 2019)
- ↑ See Briefing with Verizon (Sept. 4, 2019); Briefing with CenturyLink (Sept. 10, 2019). According to Verizon, its agreements are consistent with those it has with other carriers. Teleconference with Verizon (June 2, 2020).
- ↑ See Briefing with Verizon (Sept. 4, 2019); Briefing with CenturyLink (Sept. 10, 2019); Teleconference with Verizon (June 2, 2020); Email from CenturyLink to the Subcommittee (June 2, 2020) (on file with the Subcommittee)
- ↑ See In the Matter of Pacific Networks Corp. and ComNet (USA) LLC, Order to Show Cause, DA 20-450 (Apr. 24, 2020), https://docs.fcc.gov/public/attachments/DA-20-450A1.pdf
- ↑ In the Matter of Pacific Networks Corp. and ComNet (USA) LLC, Response to Order to Show Cause, GN Docket No. 20-111 (June 1, 2020), http://licensing.ffc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/related_filing.hts?f_key=710677&f_number=ITC2142009042400199.
- ↑ Id. at i, 2, 20.
- ↑ Id. at i-ii, 2, 19.
- ↑ Id. at 2.
- ↑ Id. at 22-23.
- ↑ Id. at 31-32.
