Federal Communications Commission Washington, D.C. 20554 June 28, 2023 DA 23-554 Content Guru Inc. 900 E. Hamilton Avenue, Suite 510 Campbell, CA 95008 ComplianceManager@redwoodtech.com John Kabealo Kabealo PLLC 1629 K Street, NW, Suite 300 Washington, DC 20006 ComplianceManager@redwoodtech.com Via Certified First-Class Mail – Return Receipt Requested and E-mail Re: Response Required – Potential Dismissal of International Section 214 Application Filed by Content Guru Inc., File No. ITC-214-20220714-00082 Dear Mr. Kabealo: On June 14, 2022, Content Guru Inc. (Content Guru) filed the above referenced application with the Federal Communications Commission (Commission) to obtain an international section 214 authorization.1 On August 29, 2022, the Committee for the Assessment of Foreign Participation in the United States Telecommunications Service Sector (Committee) notified the Commission that it was reviewing Content Guru’s application for any national security or law enforcement concerns.2 On June 7, 2023, the Committee returned the application to the Commission, recommending the application be dismissed without prejudice.3 The Committee states that Content Guru has failed to respond to a request for information. According to the Committee, it granted Content Guru three extensions to provide the information and warned Content Guru that no further extension would be granted if Content Guru failed to meet its last deadline of June 6, 2023.4 The Committee states that the 1 Application of Content Guru Inc. for International Section 214 Authorization, File No. ITC-214-20220714-00082 (filed June 14, 2022). 2 Non Streamlined International Applications/Petitions Accepted for Filing, Public Notice, Report No. TEL- 02213NS at 1 (IB Sept. 1, 2022). 3 See Letter from Christine M. Quinn, Attorney Advisor, Foreign Investment Review Section, National Security Division, U.S. Department of Justice, to Marlene H. Dortch, Federal Communications Commission at 1 (June 7, 2023) (on file in ITC-214-20220714-00082) (June 7, 2023 DoJ Letter). 4 Id at n.1. The Committee notified the Commission of these three extensions of the 120-day period by letters dated May 9, 2023, May 24, 2023, and May 31, 2023. See Letter from Christine M. Quinn, Attorney Advisor, Foreign Investment Review Section, National Security Division U.S. Department of Justice, to Marlene H. Dortch, Federal Communications Commission at 1 (May 9, 2023) (on file at ITC-214-20220714-00082) (May 9, 2023 DoJ Letter); Letter from Christine M. Quinn, Attorney Advisor, Foreign Investment Review Section, National Security Division, applicant missed the June 6, 2023, deadline.5 According to the Committee, it cannot complete its review of the application and has returned the application to the Commission with a recommendation it be dismissed without prejudice.6 The Committee’s recommendation regarding the national security and law enforcement concerns with an application with foreign ownership is an important consideration in the Commission’s determination of whether the grant of an application is in the public interest.7 If the Committee is unable to make a recommendation because the applicant does not provide the required information to the Committee, the Commission will not have the information it needs to find that the grant of the application is in the public interest. Content Guru must respond to this letter by July 28, 2023. In your letter, state whether you intend to pursue the application and if so, indicate when you will provide the Committee with the information it has requested. If you do not respond to this letter, the above referenced application will be dismissed without prejudice pursuant to the Commission’s rules.8 Should you need further assistance, please contact Svantje Swider at (202) 418-0772 or svantje.swider@fcc.gov. Sincerely, /s/Francis Gutierrez Francis Gutierrez, Deputy Chief Telecommunications & Analysis Division Office of International Affairs Enclosures: June 7, 2023 DoJ Letter May 31, 2023 DoJ Letter May 24, 2023 DoJ Letter May 9, 2023 DoJ Letter U.S. Department of Justice, to Marlene H. Dortch, Federal Communications Commission at 1 (May 24, 2023) (on file at ITC-214-20220714-00082) (May 24, 2023 DoJ Letter); Letter from Christine M. Quinn, Attorney Advisor, Foreign Investment Review Section, National Security Division, U.S. Department of Justice, to Marlene H. Dortch, Federal Communications Commission at 1 (May 31, 2023) (on file at ITC-214-20220714-00082) (May 31, 2023 DoJ Letter). 5 June 7, 2023 DoJ Letter at 1. 6 Id. 7 See Process Reform for Executive Branch Review of Certain FCC Applications and Petitions Involving Foreign Ownership, IB Docket 16-155, Report and Order, 35 FCC Rcd 10927 (2020). 8 47 CFR §§ 1.748(a) and 1.10014(b). Any filing must be filed in ICFS using the ICFS Pleadings and Comments module. 2 Enclosures 3 ________/s/____________________ U.S. Department of Justice National Security Division Foreign Investment Review Section Washington, DC. 20530 June 7, 2023 By E-File Ms. Marlene H. Dortch Federal Communications Commission 45 L St. N.E. Washington, D.C. 20554 Re: Content Guru Inc.; ITC-214-20220714-00082 (TT 22-042) Dear Ms. Dortch: The Commission is notified that the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (“Committee”) recommends that the above-referenced application be dismissed without prejudice.’ The Committee makes this recommendation under subsection 5(d) of Executive Order 13913 (Apr. 4, 2020) (“E.O. 13913”) because of Content Guru’s failure to respond to a request for information. The Committee previously granted Content Guru three extensions to provide this information under subsection 5(d) of E.O. 139132 and warned Content Guru that no further extension would be granted if Content Guru failed to meet its last deadline of June 6, 2023. Content Guru missed that deadline and has not to date provided the requested information. Accordingly, the Committee cannot complete its review and is returning this application to the FCC with a recommendation it be dismissed without prejudice. Thank you for your consideration, Sincerely, Christine M. Quinn Attorney Advisor Foreign Investment Review Section National Security Division U.S. Department of Justice See attached notification of the Chair. 2 The Commission was notified of these three extensions of the 120-day period by letters filed by the Committee on May 9, 2023, May 24, 2023, and May 31, 2023. cc: FCC-TTe1ecom(fcc.gov David Krech (via e-mail at David.Krech(fcc.gov) Adrienne McNeil (via e-mail at Adrienne.McNeihfcc.gov) Applications.TT@usdoj.gov osd.pentagon.ousd-a-s .list.team-telecom@mail.mil dhsteamte1ecomhg.dhs gov U.S. Department of Justice National Security Division Foreign Investment Review Section Washington, DC. 20530 Content Guru Inc.; ITC-214-20220714-00082 (TT 22-042) Pursuant to Executive Order 13913 (Apr. 4, 2020), the Chair of the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (“Committee”) is making a notification that the Committee recommends that the above- referenced application be dismissed without prejudice. Devin A. DeBacker Chief Foreign Investment Review Section National Security Division U.S. Department of Justice ________/s/______________________ U.S. Department of Justice National Security Division Foreign Investment Review Section aslungton. D.C. 20530 May 31. 2023 By E-File Ms. Marlene H. Dortch Federal Communications Commission 45 L St. N.E. Washington, D.C. 20554 Re: Content Guru Inc.; ITC-214-20220714-00082 (TT 22-042) Dear Ms. Dortch: The Commission is notified that the applicant for the above-referenced application has requested and received an extension of time to provide complete responses to questions posed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector.’ The 120-day review period now ends on July 28. 2023. Thank you for your consideration. Sincerely, Christine M. Quinn Attorney Advisor Foreign Investment Review Section National Security Division U.S. Department of Justice cc: FCC-TTelecornIfcc.tzov David Krech (via e-mail at david.krechifcc.gov) Adrienne McNeil (via e-mail at Adrienne.McNeilfcc.gov) Applications.TT1usdoj .zov P-FCC(IHQ.DF1S.GOV I osd.pentagon .ousd-a-s.Iist.team-telecomi.rnail.rnil See attached notification of the Chair. U.S. Department of Justice National Security Division Foreign Investment Review Section ii ashington. DC. 20530 Content Guru Inc.; ITC-214-20220714-00082 (TT 22-042) Pursuant to Executive Order 13913 (Apr. 4. 2020), the Chair of the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (“Committee”) is making a notification that the Committee has granted a request by the applicant(s) in the above-referenced application for an extension of time to submit responses to the Committee’s questions. Digitally signed by DEVIN j(7’y DEBACKER T_ Date 20230531 09 34 04 -0400 Dcv in A. DeBacker Chief Foreign Investment Review Section National Security Division U.S. Department of Justice ________/s/______________________ U.S. Department of Justice National Security Division Füre,gn Invesnie Review Secuon Washington. D.C. 21)530 May’ 24, 2023 By E-File Ms. Marlene H. Dortch Federal Communications Commission 45 L St. N.E. Washington, D.C. 20554 Re: Content Guru Inc.; ITC-214-20220714-00082 (TT 22-042) Dear Ms. Dortch: The Commission is notified that the applicant for the above-referenced application has requested and received an extension of time to provide complete responses to questions posed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector.’ The 120-day review period now ends on July 17, 2023. Thank you for your consideration. Sincerely, Christine M. Quinn Attorney Advisor Foreign Investment Review Section National Security Division U.S. Department of Justice cc: FCC-TTelecon’i7t’cc.gov David Krech (via e-mail at david.krechifcc.gov) Adrienne McNeil (via e-mail at Adrienne.McNeilfcc.gov) AppI ications.TTZiiisdoj .gov lPECCti;HQ.DH5.GQV osd.pentagon.ousd-a-s.list.team-telecornmail.miI See attached notification of the Chair, U.S. Department of Justice National Security Division Foreign Investment Review Section Washington. D.C. 20530 Content Guru Inc.; ITC-214-20220714-00082 (TT 22-042) Pursuant to Executive Order 13913 (Apr. 4,2020), the Chair of the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (Committee”) is making a notification that the Committee has granted a request by the applicant(s) in the above-referenced application for an extension of time to submit responses to the Committee’s questions. DgitaIIy signed by DEVIN DEBACKER Date 202305 24 ‘Y 14 51:02 -0400 Dcv in A. DeBacker Chief Foreign Investment Review Section National Security Division U.S. Department of Justice ________/s/ U.S. Department of Justice National Security Division Foreign Investment Review Section Washington. D.C. 20530 May 9, 2023 By E-File Ms. Marlene H. Dortch Federal Communications Commission 45 L St. N.E. Washington, D.C. 20554 Re: Content Guru Inc.; ITC-214-20220714-00082 (TT 22-042) Dear Ms. Dortch: The Commission is notified that the applicant for the above-referenced application has requested and received an extension of time to provide complete responses to questions posed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector.1 The 120-day review period now ends on July 14, 2023. Thank you for your consideration. Sincerely, Christine M. Quinn Attorney Advisor Foreign Investment Review Section National Security Division U.S. Department of Justice cc: FCC-TTelecorrifcc.gov David Krech (via e-mail at david.krech(fcc.gov) Adrienne McNeil (via e-mail at Adrienne.McNeilfcc.gov) AppI ications.TT(i.iisdoj .gov IP-FCC(l HO. DFIS .GO V osd.pentagon.ousd-a-s.list.team-teleconi(4mail.mil See attached notification of the Chair. U.S. Department of Justice National Security Division Foreign investment Revieit Section Washington. DC. 20530 Content Guru Inc.; ITC-214-20220714-00082 (TT 22-042) Pursuant to Executive Order 13913 (Apr. 4, 2020), the Chair of the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (‘Committee”) is making a notification that the Committee has granted a request by the applicant(s) in the above-referenced application for an extension of time to submit responses to the Committees questions. Digitally signed by DEVIN j’y2 DEBACKER j.A 1’ Date 2023 0509 17:12:47 -0400’ Devin A. DeBacker Chief Foreign Investment Review Section National Security Division U.S. Department of Justice