service, noting that through its "international network and comprehensive worldwide partnerships, [its] global MPLS VPN service allows customers to gain access to extensive international network infrastructure, in-country facilities and committed services [,] and support resources."[1]
CUA has built relationships with major U.S. carriers. CUA does not own transmission networks in the United States.[2] It leases transmission circuits from major U.S. carriers for data capacity between CUA's points of presence, as well as between those points of presence and CUA's end customers.[3] Through these connections, CUA ensures that its U.S.-based customers can connect between the United States and China, or other international points.[4] CUA informed the Subcommittee that its U.S. carrier partners operate the same way to reach U.S. customers in China. For example, a U.S. carrier with customers in mainland China would lease network capacity in China from China Unicom to connect to the U.S. carrier's end-customer.[5]
CUA has established relationships with AT&T, Verizon, and Century Link, among other U.S. carriers.[6] These relationships include the provision of network or other retail services.[7] Verizon maintains an interconnection agreement and peering arrangement with CUA, as well as separate agreements with its Chinese parent companies.[8] AT&T sells voice and data transport services, which CUA uses to provide services to its customers in the United States.[9] Although it did not specify the particular services sold to CUA, Century Link informed the Subcommittee that it has limited commercial relationships with all of the Chinese carriers, which include selling network services, circuits, or collocation services.[10]
- ↑ See id. at 19.
- ↑ Briefing with China Unicom Americas (Apr. 16, 2020).
- ↑ Id.; Email from Squire Patton Boggs, counsel to CUA, to the Subcommittee (June 3, 2020) (on file with the Subcommittee).
- ↑ Briefing with Verizon (Sept. 4, 2019); Briefing with AT&T (Sept. 17, 2019); Briefing with CenturyLink (Sept. 10, 2019).
- ↑ 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 Verizon (Sept. 4, 2019); Briefing with AT&T (Sept. 17, 2019); Briefing with CenturyLink (Sept. 10, 2019).
- ↑ Briefing with Verizon (Sept. 4, 2019); Briefing with AT&T (Sept. 17, 2019); Briefing with CenturyLink (Sept. 10, 2019).
- ↑ Briefing with Verizon (Sept. 4, 2019).
- ↑ Briefing with AT&T (Sept. 17, 2019). As with CTA, AT&T representatives told the Subcommittee that the revenue generated by its agreements with CUA is relatively small, particularly when compared to similar agreements with other large international carriers. For example, similar arrangements with other large international carriers generate up to 36 to 62 times as much revenue as arrangements with the Chinese state-owned carriers discussed in this report. Id.; Email from Gibson, Dunn & Crutcher LLP, counsel to AT&T, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
- ↑ Briefing with CenturyLink (Sept. 10, 2019).
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