Attachment Supplemental

This document pretains to SCL-LIC-20070516-00008 for License on a Submarine Cable Landing filing.

IBFS_SCLLIC2007051600008_598012

Pending Columbus Cable Landing Application                                                                       Page 1 of 4

 Mikelle Morra

  From:      Hector Mora [hmora@wmr-intl-law.com]
  Sent:      Thursday, October 04, 2007 3:54 PM
  To:        David Krech
  Cc:        Imani Ellis; George Li; 'Linda Wellstein'
  Subject: RE: Pending Columbus Cable Landing Application

Yes, that is correct.

          -----Original Message-----
          From: David Krech [mailto:David.Krech@fcc.gov]
          Sent: Thursday, October 04, 2007 3:40 PM
          To: Hector Mora
          Cc: Imani Ellis; George Li; Linda Wellstein
          Subject: RE: Pending Columbus Cable Landing Application

          Thank you.

          Since one does not need to have a 50% or greater equity or voting interest to exercise de facto control over a
          corporation, I want to clarify that CFFI Ventures and, in turn, John Risley do not exercise control over Columbus
          International. Is that correct?


          From: Hector Mora [mailto:hmora@wmr-intl-law.com]
          Sent: Thursday, October 04, 2007 3:30 PM
          To: David Krech
          Cc: Imani Ellis; George Li; 'Linda Wellstein'
          Subject: FW: Pending Columbus Cable Landing Application
          Importance: High

          Dear Mr. Krech,

          Columbus International Inc. is the ultimate parent corporation of Columbus Networks USA, Inc.
          within the Columbus Group. See Chart N# 1 of Attachment 2. The owners of Columbus
          International, Inc. (the ultimate parent) are investors without direct involvement in the
          management of the group. The person with the highest equity and voting rights is Mr. John Risley
          who has control over CFFI Ventures ( Barbados) Inc. and consequently equity and voting rights
          equal to 47.5% in the ultimate parent corporation of the Applicant, nonetheless he does not reach
          the equity and voting right threshold to have control over Columbus International, Inc. Therefore,
          there is not an entity or person with a majority interest (>50%) in the ultimate parent corporation
          as to have sole control over the Applicant.

          Please find enclosed the list of entities and persons with direct and indirect interest in Columbus
          International, Inc. The attached list, if compared to the list already submitted to the Commission in
          Attachment # 2, includes additional details requested by, and provided to, the Department of
          Homeland Security.

          The voting rights of entities with equity or ownership interest in Columbus International, Inc. are
          equivalent or proportional to the equity participation of the interest holder, thus I confirm that the
          ownership percentage used in Attachment # 2 of the pending Application are for both equity and
          voting interests.

          Finally, please find below the information about Ironbound Holding Capital Limited (current
          corporate name Ironbound Island Capital) that certainly is missing in the narrative:


10/9/2007


Pending Columbus Cable Landing Application                                                      Page 2 of 4
      Entity Name: Ironbound Island Capital
      Address: 757 Bedford Hwy
               Bedford Nova Scotia
               B4A 3Z7
      Percentage Held: 47.5% through CFFI Holding SARL
      Citizenship: Canadian.
      Principal Business: Investment holding company.
      Involvement with Applicant: Investor in the Columbus Group.

      Please do not hesitate to contact me or Linda Wellstein directly with any other question. Thank you
      again for receiving me last week with such short notice, and for all your time and effort invested in
      this matter. We greatly appreciate it.


      Sincerely,

      Hector Mora


      -----Original Message-----
      From: David Krech [mailto:David.Krech@fcc.gov]
      Sent: Tuesday, October 02, 2007 11:48 AM
      To: David Krech; Hector Mora
      Cc: George Li; Imani Ellis
      Subject: RE: CFX -1 Cable Landing Application - File No.
      SCL-LIC-20070516-00008

      I almost forgot, does any person or entity control Columbus
      International Inc.?

      ________________________________

      From: David Krech
      Sent: Tue 10/2/2007 10:53 AM
      To: David Krech; 'Hector Mora'
      Cc: George Li; Imani Ellis; Mikelle Morra
      Subject: RE: CFX -1 Cable Landing Application - File No.
      SCL-LIC-20070516-00008


      Mr. Mora,

      We need some additional ownership information regarding the application.

      In Attachment 2 you provide ownership information for Columbus Networks
      USA, Inc. Can you please verify that the ownership percentage used in
      the attachment are for both equity and voting interests or if not,
      please provide the separate voting and equity ownership interests.
      Also, please provide information regarding Ironbound Holdings Capital
      Limited, which is shown in Cart #2, but is not discussed in the
      narrative.

      Thank you.

      David Krech

      ________________________________

      From: David Krech

10/9/2007


Pending Columbus Cable Landing Application                                       Page 3 of 4
      Sent: Wed 9/26/2007 11:55 AM
      To: 'Hector Mora'
      Cc: George Li; Imani Ellis; Mikelle Morra
      Subject: RE: CFX -1 Cable Landing Application - File No.
      SCL-LIC-20070516-00008


      Thank you for delivering the supplemental filing today. It was nice to
      meet you.

      We have scanned the filing and placed it in the file for the
      application. It is available through IBFS.

      We review the filing and let you know if we have any questions or need
      any further information in order to place the application on Public
      Notice.

      David Krech

      ________________________________

      From: Hector Mora [mailto:hmora@wmr-intl -law.com]
      Sent: Friday, September 14, 2007 3:25 PM
      To: David Krech
      Subject: RE: CFX -1 Cable Landing Application - File No.
      SCL-LIC-20070516-00008


      Mr. Krech,

      I am writing to follow up on our client's application for a Cable
      Landing License. Our brief was submitted to the Secretary by certified
      mail and for that reason I do not have a stamped copy of the same.
      Nonetheless, I have confirmation of its delivery on September 4, 2007. I
      hope you received one of the copies of the brief already.

      Please let me know if you received a paper copy of the brief or if I
      should contact the Secretary in that respect. I greatly appreciate any
      information you might provide us about the status of the application.

      Sincerely,

      Hector G. Mora


      -----Original Message-----
      From: David Krech [mailto:David.Krech@fcc.gov]
      Sent: Friday, August 31, 2007 9:33 AM
      To: Hector Mora
      Cc: Imani Ellis; George Li ; lwellstein@wmr-intl-law.com
      Subject: RE: CFX -1 Cable Landing Application - File No.
      SCL-LIC-20070516-00008

      Thank you.

      Can you please e-mail us a PDF copy of the Secretary's date stamped
      version of the filing.



10/9/2007


Pending Columbus Cable Landing Application                                       Page 4 of 4
      We will review the filing and let you know if we have any questions or
      need any further information.

      David Krech

      ________________________________

      From: Hector Mora [mailto:hmora@wmr-intl -law.com]
      Sent: Thursday, August 30, 2007 7:08 PM
      To: David Krech
      Cc: Imani Ellis; George Li ; lwellstein@wmr-intl-law.com
      Subject: CFX-1 Cable Landing Application - File No.
      SCL-LIC-20070516-00008
      Dear Mr. Krech;

      On this date, we submitted to Ms. Marlene H. Dortch, Secretary of the
      Federal Communications Commission, the Applicant's brief in support of
      its request to operate the Submarine Cable System CFX-1 as a non common
      carrier. Please find enclosed a copy of the brief and cover letter as
      submitted.

      I apologize for our delay in filing the aforementioned brief, but
      additional time was needed to provide factual support of the Applicant's
      eligibility to operate the cable system as a non common carrier. We
      believe that with this brief, the Applicant has completed all requisites
      for acceptance of its application for streamline processing.

      Thank you very much for all your attention to this matter and guidance
      in getting the record complete. Please do not hesitate to contact me or
      Ms. Linda Wellstein, if additional information is needed.

      Best regards,

      Hector Mora




10/9/2007



Document Created: 2019-04-14 22:17:34
Document Modified: 2019-04-14 22:17:34

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