Page:2020-06-09 PSI Staff Report - Threats to U.S. Communications Networks.pdf/89

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to global carriers."[1] At the time CITIC acquired ComNet, it also owned Pacific Networks Corp. ("Pacific Networks"), another U.S. company.[2] In integrating ComNet into its corporate organization, CITIC made ComNet a wholly-owned subsidiary of Pacific Networks.[3]

The integration of the companies prompted Team Telecom to enter into a security agreement with the companies in March 2009. Yet, like CTA, Team Telecom has exercised minimal oversight of the companies and their operations in the United States—relying on intermittent email communication and completing only two site visits in more than ten years.

1. ComNet's Initial Section 214 Authorization Did Not Require Team Telecom's Review

ComNet (then CM Tel (USA) LLC) applied for international Section 214 authorization in 1999 to provide global international facilities-based and resale services between the United States and all international points.[4] ComNet certified that it had no affiliation with any foreign or U.S. facilities-based carrier.[5] The FCC did not refer the application to Team Telecom. The application was accepted for filing on October 13, 1999[6] and granted on October 27, 1999.[7]

  1. ↑ Corporate Profile, CITIC TELECOM INTERNATIONAL, https://www.citictel.com/about-us/corporate-profile/.
  2. ↑ See CM Tel (USA) LLC, Application for Transfer of Control of International Section 214 Authority, File No. ITC-T/C-20080913-00428, Attach. 1 (filed Sept. 13, 2008), https://fcc.report/IBFS/ITC-T-C-20080913-00428 (unofficial website); CM Tel (USA) LLC, Application for Transfer of Control of International Section 214 Authority, File No. ITC-T/C-20080913-00428, Supplement (filed Sept. 25, 2008), https://fcc.report/IBFS/ITC-T-C-20080913-00428 (unofficial website) (stating "CITIC 1616 [Holdings Limited] will acquire CM Tel (USA) LLC through CITIC 1616's indirectly wholly owned subsidiary, Pacific Networks Corp.").
  3. ↑ See CM Tel (USA) LLC, Application for Transfer of Control of International Section 214 Authority, File No. ITC-T/C-20080913-00428, Attach. 1 (filed Sept. 13, 2008), https://fcc.report/IBFS/ITC-T-C-20080913-00428 (unofficial website).
  4. ↑ 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).
  5. ↑ See id. at 5.
  6. ↑ Fed. Commc'ns Comm'n, Public Notice—International Applications Accepted for Filing, Rep. No. TEL-00144S, at 2 (Oct. 13, 1999).
  7. ↑ Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-00151, DA No. 99-2328, 14 FCC Red 17862, 17864 (Oct. 28, 1999) (listing the "date of action" authorizing the application as October 27, 1999).

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