Federal Communications Commission Washington, D.C. 20554 November 12, 2021 DA 21-1427 Andrew D. Lipman Counsel to China Telecom (Americas) Corporation Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Andrew.Lipman@morganlewis.com VIA E-MAIL Re: China Telecom (Americas) Corporation, GN Docket No. 20-109; ITC-214-20010613-00346; ITC-214-20020716-00371; ITC-T/C-20070725-00285 Dear Mr. Lipman: This letter confirms our receipt of your October 27, 2021, letter concerning the Commission’s adoption of an Order that revoked China Telecom (Americas) Corporation’s (CTA) domestic authority and revoked and terminated its international authority pursuant to section 214 of the Communications Act of 1934.1 CTA notes that, in the news release, the Commission stated it would issue a consumer guide after the release of the Order.2 Specifically, CTA requests that the Commission “refrain from making any statements to consumers that may imply that their service will be disconnected or stop working unless they take some immediate action to select a new provider.”3 In support of this request, CTA states that it “has ongoing active discussions with other service providers who may be able to assume the provision of service to CTA’s customer base (after compliance with all applicable regulatory requirements), without disruption of service and without any need for those customers to take any affirmative action.”4 CTA states, “it is likely to take at least a few days to reach an agreement with another provider and to begin the steps to implement such an agreement.”5 CTA adds that it “understands that some customers may choose to seek a new provider even if they are not required 1 See Letter from Andrew D. Lipman, Partner, Morgan, Lewis & Bockius LLP to Patrick Webre, Chief, FCC Consumer and Governmental Affairs Bureau (Oct. 27, 2021) (on file in GN Docket No. 20-109) (CTA Oct. 27, 2021 Letter); China Telecom (Americas) Corporation, GN Docket No. 20-109, File Nos. ITC-214-20010613-00346, ITC- 214-20020716-00371, ITC-T/C-20070725-00285, Order on Revocation and Termination, FCC 21-114 (adopted Oct. 26, 2021 and released Nov. 2, 2021) (Order on Revocation and Termination). 2 CTA Oct. 27, 2021 Letter at 1. 3 Id. 4 Id. 5 Id. to do so, but it would be misleading and disruptive to suggest that customers have no choice but to act immediately to find a new service provider.”6 The Order on Revocation and Termination requires “CTA to discontinue any domestic or international services that it provides pursuant to its section 214 authority no later than sixty (60) days” from the release of the Order.7 The Order on Revocation and Termination was released on November 2, 2021 and, accordingly, CTA must stop all such services no later than January 3, 2022.8 Given this impending discontinuance date, we disagree with CTA that releasing a consumer guide would be misleading or disruptive to customers. CTA’s U.S. customers must switch providers promptly or understand that their service will end on January 3, 2022. To assist them with transitioning to other domestic and international mobile services, the Commission expects to issue a consumer guide shortly that explains the Commission’s action and what options consumers might consider for mobile services. We also note that the release of the consumer guide does not preclude CTA from issuing its own communications to its customers. Rather, the Order on Revocation and Termination requires CTA “to provide all affected customers with thirty (30) days’ notice of service discontinuance.”9 In response to the discussions you reference with other service providers,10 we remind you that any measures under discussion must comply with relevant Commission rules, including sections 63.03, 63.04, 63.24(b), and 64.1120(a), (c), and (e).11 We are available to answer any further questions you may have. Sincerely, /s/ Patrick Webre Patrick Webre Chief Consumer and Governmental Affairs Bureau /s/ Thomas Sullivan Thomas Sullivan Chief International Bureau /s/ Kris Monteith Kris Monteith Chief Wireline Competition Bureau 6 Id. 7 Order on Revocation and Termination, FCC 21-114 at para. 2. 8 Id.; see 47 CFR § 1.4 (detailing the method for computing the amount of time within which persons or entities must act in response to deadlines established by the Commission). 9 Order on Revocation and Termination, FCC 21-114 at para. 152. 10 CTA Oct. 27, 2021 Letter at 1. 11 47 CFR §§ 63.03; 63.04; 63.24(b); 64.1120(a), (c), (e). 2