Attachment STA Attachment 1

This document pretains to ITC-STA-20130120-00016 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2013012000016_982032

Attachment 1

QUESTIO: 10. In Attachment 1, provide justification of need for special temporary authority
requested.

ASWER: Five9 has been providing resale of international telecommunications services for
several years but, as a result of good faith reliance on previous legal advice, was unaware of its
need to register with the Federal Communications Commission or to secure Section 214
authorization. Five9 has now registered with the Commission as a contributor to the Universal
Service Fund and is required to bring itself into compliance as promptly as possible under
Section 214. Following a voluntary disclosure of its failure to register with the Commission as a
reseller of long distance services, it is now responding to a Letter of Inquiry from the
Enforcement Bureau, which has asked for proof that Five9 has received Section 214
authorization. Grant of Five9’s request for Special Temporary Authority to provide resale of
international common carrier services will expedite Five9’s conformance with Commission’s
regulations and, therefore, will serve the public interest.



QUESTIO: 15. In Attachment 2, respond to paragraphs (d), (e)(3) and (g) of Section 63.18.

ASWER: Five9 filed for Section 214 authority from the Commission on January 19, 2013
(Submission ID: IB2013000159). At this time, Applicant does not seek authority to provide
service not covered by either paragraphs (e)(1) or (e)(2) of Section 63.18 of the Commission’s
Rules. Five9 is not seeking authority under paragraph (e)(3) of Section 63.18 of the
Commission’s Rules. Therefore, Section 63.18(g) is not applicable to it.



Document Created: 2013-01-20 15:26:40
Document Modified: 2013-01-20 15:26:40

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