August 2, 2022 VIA EMAIL: Jessica.Rosenworcel@fcc.gov The Honorable Jessica Rosenworcel Chairwoman Federal Communications Commission 45 L Street, N.E. Washington, D.C. 20554 Dear Chairwoman Rosenworcel: Thank you for your July 19, 2022 letter inquiry regarding subscriber geolocation data. I appreciate your attention to this issue and agree with you that the manner in which such information is collected, stored and used can have important public safety and privacy implications. H2O Wireless operates as a mobile virtual network operator. As such, H2O Wireless does not collect, store, use or share any geolocation data which we understand to mean real-time location information or other form of information regarding a consumer’s precise physical location when using our services. While H2O does not collect geolocation data, we note that certain information the company receives in call detail records (CDRs) from our underlying provider includes some broader geographic information about a consumer’s location when using our services. We do not view this information as geolocation information because it does not provide information as to a subscriber’s precise physical location. We do not disclose any CDR information except under legal or regulatory compulsion. I hope that you find this letter, albeit brief, to be fully responsive to yours. Should you have any questions about our response, please feel free to reach out to me directly. Sincerely, Jack Woo President, Locus Telecommunications, a division of Telrite Holdings LOCUS TELECOMMUNICATIONS, LLC 2200 Fletcher Avenue 6th Floor Main: 201-585-3600 Fort Lee, New Jersey 07024 Fax: 201-947-6108