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"We hired Jonathan to represent our telecommunications licensing needs. At the time we were a start-up company with only a small amount of investment revenue. Attorney costs could have been enough to rethink the business plan. Jonathan worked with us on a payment plan basis which allowed us to focus on getting customers while he worked on getting us our licenses. He provided introductions to companies we eventually hired to assist us with tax issues and other FCC requirements. When we were interested in selling our company Jonathan made introductions to other telecom companies that were in the market for our type of company. He managed the contract process at every level through the acquisition. The best recommendation I can give is that when I go to do this again I will hire Jonathan."
"Jonathan is well-versed in a broad range of telecom regulatory matters. He uses his expertise to arrive at innovative, real-world business solutions while maintaining a high degree of professionalism."
"Jonathan is extremely knowledgeable in his field. He has provided invaluable telecom expertise to us and our subsidiary company on countless occasions. We would be lost without him. I highly recommend Jonathan!"
"Jonathan['s firm] was able to provide our ISP association with fresh responses to the RBOC FCC petitions as opposed to the boilerplate comments most law firms offered. Jonathan has a good understanding of the industry and how things work at the FCC."
—COO of a leading virtual
system company
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unit of foreign PTT
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nationwide Hosted
VoIP provider
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of US operating unit
of international multi-media
conglomerate
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regional CLEC
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international communications carrier
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provider of long distance,
wireless, point-of-sale and
carrier services
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regional CLEC
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leading provider of
long distance, wireless,
point-of-sale and carrier
services
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conferencing solutions
provider
—Member, Federation of
Internet Solutions Providers
of the Americas
Contact Information

Marashlian & Donahue, LLC

The CommLaw Group
1420 Spring Hill Road
Suite 401
McLean, Virginia 22102

Telephone: (703) 714-1300
Facsimile: (703) 714-1330

E-mail: mail@commlawgroup.com
FCC International Traffic Report due July 31st
07/06/2010

The deadline to file International Traffic Reports with the Federal Communications Commission ("FCC") is July 31st.

All carriers providing international telecommunications services between any U.S. point and any non U.S. point - i.e. clients required to possess an FCC Section 214 License - must file an International Traffic Report with the FCC in accordance with Section 43.61(a) of the Commission's rules. This includes foreign carriers that serve a U.S. point, as well as private carriers and carriers that provide non-tariffed international communications services.

Both facilities-based carriers and resellers must file the International Traffic Report. The Report must include, among other things, actual traffic and revenue data for each service provided, divided among services billed in the United States, outside the United States, and services transiting the United States. However, carriers providing exclusively resold international telecommunications services can file a simplified report. Carriers providing both facilities-based and resold services must file separate reports.

REPORTING DETAILS:

All carriers possessing a FCC Section 214 License and who provided international telecommunications services during the previous year must file an International Traffic Report with the FCC. This report must include, among other things:

  • The number of calls to specific international destinations;
  • The number of minutes for calls to international destinations;
  • Revenue derived from international minutes of use; and
  • The specific countries or international points to which your company terminated international minutes of use.

The International Traffic Report must include a Certification, signed by an officer of the company under penalty of perjury, attesting to the accuracy of the reported data.

CLIENT ACTION ITEMS:

Clients subscribed to Compliance & Reporting Services ("C&R Services") will be contacted by Meghan Ruwet regarding the timely submission of revenue and other required data.  Clients not currently subscribed to the firm's C&R Services, but who require assistance preparing and filing the International Traffic Report, should contact us promptly to ensure timely filing.

C&R Services Subscribers: Clients currently subscribed to C&R Services through our firm's regulatory consulting affiliate, The Commpliance Group, should remit required data to Meghan Ruwet at mruwet@commpliancegroup.com no later than July 20th.

Non-Subscribers: Clients not currently subscribed to C&R Services through The Commpliance Group, but who require assistance with the preparation and filing of the International Traffic Report may contact Meghan Ruwet, at mruwet@commpliancegroup.com, to make appropriate arrangements and ensure timely filing.

If you have already sent us data for the International Traffic Report, you may disregard this notice.

ADDITIONAL INFORMATION:

FCC Enforcement

The FCC imposes steep fines against entities that fail to comply with its "reporting" regulations. These FCC fines frequently exceed one hundred thousand dollars ($100,000.00) for a single offense. Examples of recent enforcement actions are available on the FCC's website: http://www.fcc.gov/eb/usfc/. Thus, clients should provide us with the required reporting information as soon as possible to avoid a delinquent filing.