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GLOBAL CONNECTICON INC. OF KIENTIPCKY cases/2007-00172/Global_Application...Siemens EWSD switch....

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GLOBAL CONNECTICON INC. OF KIENTIPCKY 3957 Pleasantdale Road, Atlanta, GA 30340 Phone: 678966.8444 / Fax: 404.458.6773 Hon Beth O’Donnell Executive Director Public Service Comnission 2 11 Sower Rlvd. P. 0. Box 615 Frank Fort, KY 40601 APR 3 0 2007 PUBLIC SERVICE COMMISSION Global Connection Inc of Kentucky,petition for Designation as an Eligible Telecoiiiniurzications Carrier in the Contnzonwealth of Kentucky Dear Ms. O’Donnell: Enclosed for filing in the above-styled case is the original and ten copies of the Petition of Global Connection Inc of America, LLC for Designation as an Eligible Telecommunications Camer in the Commonwealth of Kentucky. Thank you, and if you have any questions please call me. Sincerely, _)_c=_ Houssam Abdallah President
Transcript

GLOBAL CONNECTICON INC. OF KIENTIPCKY 3957 Pleasantdale Road, Atlanta, GA 30340 Phone: 678966.8444 / Fax: 404.458.6773

Hon Beth O’Donnell Executive Director Public Service Comnission 2 11 Sower Rlvd. P. 0. Box 615 Frank Fort, KY 40601

APR 3 0 2007 PUBLIC SERVICE

COMMISSION

Global Connection Inc of Kentucky, petition for Designation as an Eligible Telecoiiiniurzications Carrier in the Contnzonwealth of Kentucky

Dear Ms. O’Donnell:

Enclosed for filing in the above-styled case is the original and ten copies of the Petition of Global Connection Inc of America, LLC for Designation as an Eligible Telecommunications Camer in the Commonwealth of Kentucky.

Thank you, and if you have any questions please call me.

Sincerely,

_)_c=_ Houssam Abdallah President

BEFORE THE KENTIJCKY PUBLIC SERVICE COMMISION PUBLIC SERVICE

GOM M IS S IO N

Iiz the ntatter o$

GLOBAL CONNECTION INC. OF KENTUCKY PETITION FOR DESIGNATION AS

CARRIER IN THE COMMONWEALTH OF JiENTUCKY 1

)

Case No. 8 0 /7 7 AN ELIGIBLE TELECOMMUNICATIONS 1

PETITION FOR DESIGNATION AS AN ELIGIBLE TEL,ECOMMUNTCATIONS CARRIER IN THE COMMONWEALTH OF KENTUCKY

1. Global Connection Inc. of Kentucky, by counsel, and pursuant to section

214 of the Telecommunications Act of 1996 (the “Act”), hereby submits its Petition for

Designation (“Petition”) as an eligible telecommunications carrier (“ETC”) in the

Commonwealth of Kentucky.

2. Global Connection Inc. of Kentucky (Organization ID: 0479132) is a

facilities-based competitive local exchange carrier with its principal business address at

3957 Pleasantdale Road, Atlanta, GA 30340. Global Connection Inc. of Kentucky

currently provides both residential and business services to approximately 3,000 access

lines in Kentucky (Filing No. T62-1346. Global Connection Inc. of Kentucky seeks ETC

designation for the GLSGKYXADSO wire center (“Designated Area”), a wire center of

the non-rural incumbent local exchange carrier, Kentucky Alltel, AT&T, SBC and

BELLSOUTH. As demonskated herein, and certified in Exhibit A to this Petition, Global

Connection Inc. of Kentucky satisfies all of the requirements for designation as an ETC

for the Designated Area and respectfully requests that the Kentucky Public Service

Commission (the “Commission”) promptly grant its Petition.

I. GLOBAL CONNECTION INC OF KENTUCKY MEETS ALL THE

REQUIREMENTS FOR DESIGNATION AS AN ELIGIBLE

TELECOMMUNICATIONS CARRIER TO SERVE THE DESIGANTED AREA

IN THE COMMONWEALTH OF KENTUCKY.

3. Pursuant to 47 U.S.C 6 214(e)(2), the Commission, “consistent with the

public interest, convenience and necessity . . . may, in the case of an area served by a

rural telephone company, and shall, in the case of all other areas, designate more than one

common carrier as an eligible telecommunications carrier for a service area designated by

the State commission, so long as [the] requesting carrier meets the requirements of

paragraph (1)” of Section 214(e). Global Connection Inc. of Kentucky satisfies the

requirements of paragraph (1) of Section 214 (e); therefore, the commission should

designate Global Connection Inc of Kentucky as an ETC for the Designated Area.

4. A common carrier designated as an eligible telecommunications carrier. . . shall be eligible to receive universal service support in accordance with section 254 of this title and shall, throughout the service area for which the designation is received-

offer the services that are supported by Federal universal service support mechanisms under section 254(c) of this title, either using its own facilities or a combination of its own facilities and resale of another carrier’s services (including the services offered by another eligible telecommunications carrier); and

advertise the availability of such services and the charges therefore using media of general distribution.

(A)

(B)

47 U.S.C. 6 214(e)(l). Pursuant to this statute, so long as a telecommunications carrier

offers the services supported by the Universal Service Fund using its own facilities or a

combination of its own facilities and those of another telecommunications carrier, and

advertises the availability of such services, “a State commission shall . . . designate [the]

common carrier . . . as an eligible telecommunications carrier for a service area

designated by the State commission.” 47 U.S.C. 8 214 (e)(2). The services supported by

the Universal Service Fund are: 1) voice grade access to the public switched network, 2)

local usage, 3) dual tone multi--frequency signaling or its functional equivalent, 4) single-

party service or its functional equivalent, 5 ) access to emergency services, 6) access to

operator services, 7) access to interexchange service, 8) access to directory assistance,

and 9) toll limitation for qualifymg low-income consumers. See 47 C.F.R. 8 54.101(a).

As demonstrated below, and as set forth in the declaration of Forrest Wilson, authorized

representative of Global Connection Inc of Kentucky, Global Connection Inc of

Kentucky will offer all of the services supported by the Universal Service Fund using a

combination of its own facilities and those of other telecommunications carriers, and

advertise the availability of those services. (See Exhibit A, Declarations of Forrest

Wilson). Accordingly, the Commission should grant Global Connection Inc of

Kentucky petition.

A. Global Connection Inc of Kentucky Provides Service Using Almost

Exclusivelv its Own Facilities.

A carrier requesting ETC designation must provide services over its own

facilities or through a combination of its own facilities and resale of another carrier’s

service. Global Connection Inc of Kentucky currently provides its services exclusively

through its own facilities. Nonetheless, Global Connection Inc of Kentucky’s agreements

with AllTel and AT&T include resale services and accordingly Global Connection Inc of

5.

K.entucky will use resale capabilities to meet its service obligations in those isolated

instances in which it might currently lack such facilities.

B Global Connection Inc of Kentuckv Offers All Required Services and

Functionalities.

Global Connection Inc of Kentucky already provides all services and

functionalities supported by the federal universal service program as set forth in 47 C.F.R

54.101 (a) and will continue to do so upon receipt of ETC designation.

6 .

(i) Voice grade access to the public switched telephone network.

7. Voice grade access to the public switched telephone

network (“PSTN”) is defined as “a functionality

that enables a user of telecommunications services

to transmit voice communications, including

signaling the network that the caller wishes to place

a call, and to receive voice communications,

including receiving a signal indicating there is an

incoming call. For the purposes of this part,

bandwidth for voice grade access should be, at a

minimum, 300 to 3,000 Hertz.” 47 C.F.R 8

54.10 1 (a)( 1). Global Connection Inc of Kentucky

meets this requirement by providing a voice grade

access to the public switched network through its

Siemens EWSD switch. Through its interconnection

arrangements with AllTel and AT&T and other

local exchange carriers, Global Connection Inc of

Kentucky customers are able to make and receive

calls on the public switched network within the

specified bandwidth. Therefore, Global Connection

Inc of Kentucky offers voice grade access to the

public switched network within the meaning of 47

C.F.R. 9 54.101(a)(l).

(ii) Local usage.

Local usage is defined as “an amount of minutes of use of exchange

service, prescribed by the Comrnission, provided free of charge to end users.” 47 C.F.R 5

54.101 (a)(2). Global Connection Inc of Kentucky provides unlimited flat rate calling

(i.e., non-metered or measured) access to its customers to local and EAS calling plans

established and tariffed by the incumbent carrier. Moreover, as a designated ETC, Global

8.

Connection Inc of Kentucky will comply with any and all minimum local usage

requirements required by applicable law.

(ii) Dual tone multi-frequency ((‘DTMF”) signaling or its

functional equivalent.

9. Section (a)(3) of 47 C.F.R 54.101 provides for supported services to

include “dual tone multi-frequency signaling or its hnctional equivalent.” Dual tone

multi-frequency (“DTMF”) is defined as “a method of signaling that facilitates the

transportation of signaling through the network, shortening call set-up time.” Id. Global

Connection Inc of Kentucky’s network is fully DTMF-compliant.

(iii) Single-party service or its functional equivalent.

10. Single-party service is defined as “telecommunications service that

permits users to have exclusive use of a wireline subscriber loop or access line for each

call placed, or, in the case if wireless telecommunications carriers, which use spectrum

shared among users to provide service, a dedicated message path for the length of a user’s

particular transmission.” 47 C.F.R. 5 54.lOl(a)(4). Global Connection Inc of Kentucky

provides customers with single-party access for the duration of every phone call.

Accordingly, Global Connection Inc of Kentucky provides customers with single-party

service within the meaning of the Federal Communication Commission’s (“FCC’s”)

regulations.

(iv)

“Access to emergency services includes access to services, such as 91 1

and enhanced 01 1, provided by local governments or other public safety organizations.”

47 C.F.R. 5 54.101(5). Global Connection Inc of Kentucky provides access to 91 1 and

enhances E911 and is fully interconnected with the Barren County public safety

answering point (“PSAP”) that serves the areas for which the company seeks ETC

designation.

Access to 911 and E911 emergencv service.

1 1.

(vi) Access to operator services.

Access to operator services is defined as “assess to any automatic or live

assistance to a customer to arrange for billing or completion, or both, of a telephone call.”

47 C.F.R. 5 54.101(6). Global Connection Inc of Kentucky provides access to operator

12.

services to its customers under contractual arrangements with an operator services

provider.

(vii)

Access to interexchange service is defined as “the use of the loop, as well

as that portion of the switch that is paid for by the end user, or the functional equivalent

of these network elements in the case of a wireless carrier, necessary to access an

interexchange carrier’s network.” 47 C.F.R. 6 S4.101(7). In addition to its own affiliate

long distance company, Global Connection Inc of Kentucky allows consumers to

presubscribe to other interexchange carriers and complete dial around calls for those

carriers who have provisioned the appropriate facilities and support such services.

Access to interexchange service (“IXC”).

13.

(viii) Access to directory assistance.

Access to directory assistance is defined as “access to a service that

includes, but is not limited to, making available to customers, upon request, information

contained in directory listings.” 47 C.F.R. 6 54.101(8). Global Connection Inc of

Kentucky customers can access directory assistance services by dialing 41 1 or through

the service offering of their presubscribed carrier by dialing 1 +NPA+SSS+- 12 12. Global

Connection Inc of Kentucky provides through the incumbent telephone company, listing

in the white pages telephone directory published for the general area.

14.

(ix)

Toll limitation for qualifying low-income consumers is defined as “toll

blocking or toll control for eligible telecommunications carriers that are incapable of

providing both services, toll limitation, denotes both toll blocking and toll control.” 47

C.F.R. 5 S4.400(d). Toll blocking “is a service provided by carriers that lets consumers

Toll limitation for qualified low-income consumers.

IS.

elect not to allow the completion of outgoing toll calls from their telecommunications

channel.” 47 C.F.R. !$ 54.400@). “Toll control is a service provided by carriers that

allows consumers to specify a certain amount of toll usage that may be incurred on their

telecommunications channel per month or per billing cycle.” 47 C.F.R. 0 54.400(c).

16. Global Connection Inc of Kentucky already makes toll limitation services

available to its customers who request such services. Upon designation as an ETC,

Global Connection Inc of Kentucky will offer these services to consumers who meet the

qualifications for Lifeline as specified in 47 C.F.R. !$ 54.409.

C. Global Connection Inc of Kentucky Will Advertise the Availabilitv of

Supported Services.

17. Global Connection Inc of Kentucky will advertise the availability of the

supported services detailed above, as well as the charges therefore, using media of

general distribution in accordance with 47 C.F.R. 3 54.201(d)(2). The methods of

advertising utilized may include newspapers, magazines, radio, or television as well as

other methods that constitute media of general distribution in the Designated Area of

Kentucky.

11. GLOBAL CONNECTION INC. OF KENTUCKY PROVIDES SERVICES THROUGHOUT THE AREA FOR WHICH IT SEE= ETC DESIGNATION.

18. Global Connection Inc of Kentucky service area is widespread throughout

Kentucky. Kentucky rate center area now served by AllTel and AT&T. It is this

exchange for which the Company requests ETC designation. Global Connection Inc of

Kentucky has facilities in place to serve the vast majority of the exchange. Receipt of

ETC designation, however, would provide Global Connection Inc of Kentucky with the

access to funds it needs to attempt to reach previously unservable customers.

19.

111. IN ACCORDANCE WITH 47 U.S.C. § 214(e)(2), GLOBAL CONNECTION INC. OF KENTUCKY IS ENTITLED TO RE DESIGNATED AS AN ETC IN NON-RURAL WIRE CENTERS.

20. Pursuant to 47 U.S.C. 0 214(e) and 47 C.F.R. 6 54.201(c), Global

Connection Inc of Kentucky is entitled to be granted ETC status by the Commission in

the GLSGKYXADSO wire center. “A State commission shall upon its own motion or

upon request designate a common carrier that meets the requirements of paragraph (1)

as an eligible telecommunications carrier for a service area designated by the State

commission.” 47 U.S.C. 0 214(e)(2). Given Global Connection Inc of Kentucky satisfies

the requirements of paragraph (1) of 47 U.S.C. 0 214(e) as described above, the

Commission should grant Global Connection Inc of Kentucky petition for ETC status in

the GLSGKYXADSO wire center.

IV. DESIGNATION OF GLOBAL CONNECTION AS AN ETC FOR THE DESIGNATED AREA WOIJLD SERVCE THE PUBLIC INTEREST.

21. The FCC has determined that “[d]esignation of competitive ETCs

promotes competition and benefits consumers in rural and high-cost areas by increasing

customer choice, innovative services, and new technologies.” Designation of Global

Connection Inc of Kentucky as an ETC would promote competition and facilitate the

provision of advanced communications services to residents of Kentucky. Consumers

would reap the benefits of local exchange service.

22. Unlike the majority of providers, Global Connection Inc of Kentucky

offers service on a land-line (non-CMRS) basis. Accordingly, it is uniquely qualified to

deliver high quality reliable services without the CPE or contract restrictions or other

providers. The continued growth of the company in its target market clearly points to a

demand fiom the subscribers of Kentucky for an alternative solution to available

providers in the Kentucky area.

As an ETC, Global Connection will continue its effort to provide high 23.

quality competitively priced telecommunication services that aides the economic

development of the Kentucky area as only a locally owned and run business can provide.

In addition, by expanding the company’s ability to provide a true Lifeline service, Global

Connection Inc of Kentucky will bring the benefits of competition to a market segment

too fiequently overlooked by other providers.

24. When granted ETC status, Global Connection Inc of Kentucky will

provide the Lifeline discount against qualifying residential services selected by the

subscriber. Similar discounting will be applied for qualifying installation fees for new

service establishment with Global Connection Inc of Kentucky.

25. Global Connection Inc of Kentucky believes that the grant of this request

is for the public interest because ETC status will allow Global Connection Inc of

Kentucky to continue to expand the range of competitive choices available to customers

in Kentucky.

V. GLOBAL CONNECTION MEETS THE ADDITIONAL, REQUIREMENTS ADOPTED BY THE FCC.

26. In its February 28, 2005 press release, the FCC adopted additional

requirements for ETC proceedings as summarized below:

(1) Eligibilitv Requirements - In satisfying its burden of proof necessary to obtain ETC designation, an ETC applicant must now: 1) provide a five- year plan demonstrating how high-cost universal service support will be used to improve its coverage, service quality or capacity throughout the service area for which it seeks designation; 2) demonstrate its ability to remain functional in emergency situations; 3) demonstrate that it will satisfy consumer protection and service quality standards; 4) offer local usage plans comparable to those offered by the incumbent local exchange carrier (LEC) in the areas for which it seeks designation; and 5) acknowledge that it may be required to provide equal access if all other ETCs in the designated service area relinquish their designations. In addition, these requirements are made applicable on a prospective basis to all ETCs previously designated by the Commission, and such ETCs are required to submit evidence demonstrating how they comply with this new ETC designation framework by October 1 , 2006.

27. Global Connection Inc of Kentucky has undertaken considerable financial

risk to overbuild the exchange in which it now seeks ETC designation. Absent access to

funds, it is unlikely that the company will be able to continue its aggressive plan of

providing high quality services to the community it serves. Its five-year plan upon

receipt of ETC designation is to improve its coverage in the few areas it now lacks

facilities; improve redundancy within its network; offer Lifeline Services to eligible

subscribers; expand local calling options; and upgrade its network to new technologies

arrive.

28. Global Connection Inc of Kentucky network is alternately powered by an

emergency generator and battery back up in the event of a power failure. Whenever

feasible, the company has diversely routed facilities between its network and the public

switched network. In addition, the company participates in t he disaster recovery and

operations plan adopted by its parent company, Global Connection Inc of Kentucky Rural

Telephone Cooperative, in the event of a disaster. Included in this plan is a provision that

allows for the loan of a switch by the company’s switch vendor to provide dial tone

functionality as quickly as possible following an extended outage.

29. Global Connection provides unlimited flat rate local calling to the same

calling scope standard as the incumbent telephone company, AllTel. In addition,

subscribers have the option for expanded calling for an additional fee.

30. Applicant acknowledges that it may be required to provide equal access if

all other ETCs in the designated service area relinquish their designations.

31. Global Connection Inc of Kentucky proposes its ETC designation will

apply for the entire Kentucky exchange. That exchange is a non-rural designation and

the company has already shown a willingness and ability to meet the needs of the

exchange. Accordingly, there is no risk of “cream-skimming” and grant of its ETC

request is in the public interest.

VI. ANNUAL CERTIFICATIONS

33. Global Connection Inc of Kentucky is fully capable of meeting additional

reporting and certification requirements contained in the FCC’s February press release as

summarized below.

(3) Annual Certification and Reporting Requirements - Each ETC designated by the Commission, including those designated prior to this decision, must submit on an annual basis: 1) progress updates on its five-year service quality improvement plan; 2) detailed information on outages in the ETC’s network; 3) how many requests for service from potential customer ere unfulfilled for the past year and the number of complaints per 1,000 handsets or lines; and 4) certifications that the ETC is complying with applicable service quality standards and consumer protection rules, is able to hnction in emergency situations, is offering a local usage plan comparable to that offered by the incumbent LEC in the relevant service areas, and acknowledge that the Commission may require it to provide equal access to long distance carriers.

VI. HIGH-COST CERTIFICATION

34. Under FCC Rules 54.313 and 54.314, carriers wishing to obtain high-cost

support must either be certified by the appropriate state commission or, where the state

Commission does not exercise jurisdiction, self-certify with the FCC and the Universal

Service Administrative Corporation (“USAC”) their compliance with Section 254(e) of

the Federal Telecommunication Act of 1996. Global Connection Inc of Kentucky

attaches its high-cost certification declaration as Exhibit C hereto. Global Connection Inc

of Kentucky respecthlly requests that the Commission issue a finding that Global

Connection Inc of Kentucky has met the high-cost certification requirement and that

Global Connection Inc of Kentucky is, therefore, entitled to begin receiving high-cost

support as of the date it receives a grant of IETC status in order that funding will not be

delayed.

VII. ANTI-DRUG ABUSE CERTIFICATION

35. No party to this Petition is subject to denial of federal benefits pursuant to

Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 3 862.13.

IX. CONCLUSION.

36. For the foregoing reasons, and in accordance with the Act and the

FCC’s regulations, Global Connection Inc of Kentucky respectfully

requests that the Commission promptly grant its petition for designation as

an eligible telecommunications carrier.

Houssam Abdallah Owner, Global Connection Inc. of Kentucky

April 24,2007

Exhibit A

G. Lifeline

1. Applicability:

a. Lifeline discounts are applicable to local exchange services provided to eligible residential Applicants.

2. Territory:

a. Within the base rate areas of all BellSouth, Sprint, and Verizon exchanges as shown and defined in the Incumbent LEC’s current and effective Tariffs on file with the Commission.

3. Discounts:

a. Lifeline is provided as a reduction of the subscriber’s access line rate for local service in amounts equal to the sum of the state and/or federal approves and supported credits.

4. Terms and Conditions:

a. Lifeline is provided only to the customer’s principle residence b. One low-income credit is available per household and applicable to the primary residential connection only. The names subscriber must be a current recipient of any of the low-income assistance programs identified in 5 following. c. Proof of eligibility in any of the qualifylng low- income assistance programs should be provided to the Company at the time of application for service. The Lifeline credit will not be established until the Company has received proof of eligibility. d. When, for any reason, a customer is determined to be ineligible the Company will contact the customer. If the customer cannot provide eligibility documentation, the Lifeline account will be disconnected. e. Certification of eligibility in any of the qualifying low-income assistance programs will be required for any account that has been disconnected prior to the

reestablishment of the service.

5. Eligible low-income assistance programs:

a. The eligible low-income assistance programs are the same as those defined in the Incumbent LEC’s current and effective Tariffs on file with the Commission..

H. L,ink-Up

1 .Link-Up is a connection assistance programs, which provides for the reduction of applicable charges associated with connection of telephone service.

2. The applicant must meet the requirements for qualification for Lifeline Telephone Service.

EXHIBIT B

MANAGEMENT and TECHNICALTEAM

Houssam Abdallah established Global Connection Inc. of America in June 1998. He serves as its President/CEO and is involved in ensuring regulatory compliance. He has an lndiistrial Engineering degree. He maintains continuing communications with BellSouth, as well as other I.L.E.C.s that the Company utilizes in providing services. Global Connection Inc. of America, a Georgia corporation is engaged in the delivery of prepaid telecommunication services, primarily in the state of Georgia and also has authority to operate in the states of Alabama, Arkansas, Florida, Illinois, Indiana, Kentucky, Michigan, Mississippi, North Carolina, South Carolina and Tennessee. Global Connection Inc. of America has current subscription of approximately 13,000 lines and monthly revenues of over $600,000.

Prior to such, he created and continues to operate Southeast Dental Care, Inc, ("S.E,D.C.") a regional Dental / Optical / Chiropractic Plan which is primarily directed to income groups not utilizing conventional insurance coverage. S.E.D.C. was founded in 1994 and has expanded to multi-state operations. Mr, Abdallah has extensive experience in the management of sales personnel and identification of market potential.

Bassam Abdallah, Vice President and the Director of Management Information Systems, has extensive experience in the field of technology platforms for administration of commercial operations. Mr. Abdallah has a B.S. degree in Computer Science and over 20 years experience in the set up and design of technical infrastructure. Mr. Abdallah is presently interacting with software engineers to develop the back office technology platform which will allow Global to interface with primary carriers, payment centers and customers on a virtual basis to allow for efficiency in the management of service and account maintenance.

Maxine Alagar is the Director of Center Operations. She came to Global after thirty-four and a half years Telephony experience with BellSouth Telecommunications, Inc. (BellSouth), Her extensive background and knowledge gained is indicated throughout her positions held in both Louisiana and Alabama during pre and post divestiture of South Central Bell and AT&T. Maxine began her career with technical experience as an Operator in Operator Services, a Frame Attendant in Central Offices for Step-by-step, Cross Bar, and #5 ESS Switching Services and as a Customer Service Representative in Interconnection Customer Service Center (ICSC). She next advanced to an Assistant Manager in the ICSC Provisioning Center; then an Assistant Manager for Wide Area Telephone Service VATS) Billing in New Orleans, La.; then a Special Access Staff Manager in Alabama, Maxine later held positions as an Assistant Manager Billing and Collections, Collections Director and at the time she had retired, Maxine was the Operations Director of Billing and Collections for BellSouth Accounts Receivables Management in Birmingham, Alabama, As the Operations Director of Billing and Collections she had seven managers and more than seventy Service Representatives which reported directly to her in addition to overseeing the day-to day operations which included escalated disputes for resolution and the collection of Access, Local Interconnection, Collocation, Resale, and Unbundled Network Element Platform (UNE-P) services across BellSouth's nine state region. Maxine also worked closely with BellSouth's General Counsel and BellSouth Regulatory to resolve Competitive Local Exchange Carrier (CLEC) contractual and bankruptcy issues, Her vast knowledge of services contributed to the successful resolution of Public Service Commission and related customer disputed issues.

Onali Momin is the Technical Support Manager, Mr. Momin has a Bachelor of Commerce degree and Diplomas in Computer Science and Computer Programming & Applications. He has also obtained certification in various aspects of programming and technology including: languages, RDBMS, report tools, components, web technologies, tools, operating systems and hardware. Mr. Momin 's ongoing responsibilities are to design, develop and deploy the client/server application for customer service, as well as the accounting department.

Exhibit C

1. Certification:

I HOUSSAM ABDALLAH certify that I am the company officer/employee responsible for this request and that I have examinedfonnulated the foregoing request. To the best of my knowledge, information and belief, all statements of fact contained in said request are correct statements of the business and affairs of the requesting carrier with respect to each and every matter set forth.

Dated: April 24rd, 2007

Telephone Number: 678-966-8555

Signature v

Subscribed and sworn to before me, a notary public in and for the State of GEORGIA

above named, this 24rd day of April, 2007.

n 1

Global Connection Inc. of America

TABLE OF CONTENTS

ACCOUNTANTS' REVIEW REPORT P. 1

BALANCE SHEETS P 2

STATEMENT OF INCOME AND RETAINEDEARNINGS- - --

STATEMENT OF CASH FLOWS P.4

NOTES TO FINANCIAL STATEMENTS P.5

- - P.3 ____ ____

SCHEDULE A OPERATING EXPENSES P. 7

GLOBAL CONNECTION, INC. of AMERICA. BALANCE SHEET

DECEMBER 31,2006 ASSETS

CURRENT ASSETS

Cash $930,752 Accounts Receivable Net of Allowances 931,942 Investments Receivable (Note 5) 4,016,595 - -

__ - __ I _ _ _LnL!ntOry_---. - - __ I_ - ----- - - - - -- 147,793 - TOTAL CURRENT ASSETS $6,027,082

PLANT AND EQUIPMENT

Furniture, Fixtures and Equipment ( Note 2) Accumulated Depreciation

NET PLANT AND EQUIPMENT

OTHERASSETS Long Term Investments ( Note 3) Deposits TOTAL OTHER ASSETS

TOTAL ASSETS

LIABIL.ITIES AND SHAREHOLDERS EQlJlTY

CURRENT LIABILITIES Accounts Payable Notes Payable (Note 4) TOTAL CURRENT LIABILITIES

LONG TERM LIABILITIES

Contracts and Deferred Taxes Payable Notes Payable Shareholders and Related Parties Note 3)

Total Long Term Liabilities TOTAL LIABILITIES

STOCKHOLDERS EQUITY Common Stock Additional Paid in Capital Shareholder K-I Distributions Retained Earnings TOTAL STOCKHOLDERS EQUITY

TOTAL LIABILITIES AND STOCKHOLDERS EQUITY

$503,755 /381,906) $121,849

$1 05,742 96,383

202,125

$6,351,056

$1,831,888 22,370

$1,854,258

224,021 741,999

$966,020 2,820,278

$5,000 $185,931

($475,750) 3,815,597

$3,530.778

$6,351,056

"SEE ACCOUNTANTS' REVIEW REPORT AND NOTES TO FINANCIAL STATEMENTS

GLOBAL CONNECTION, INC. of AMERICA STATEMENT OF INCOME AND RETAINED EARNINGS

FOR THE YEAR ENDED DECEMBER 31,2006

Income -Net Sales

Cost of Sales

Gross Profit

Operating Expense

INCOME FROM OPERATIONS

Retained Earnings- Beginning

Interest Income

Retained Earnings- Ending

_ _ _ _ _ _ _ ___I___ - - - - - _ _

$21,681,590

12,683,797

5,560,029

3,437,764

219,904

157,929

$3,815,597

"SEE ACCOUNTANTS' REVIEW REPORT AND NOTES TO FINANCIAL STATEMENTS" -3-

GLOBAL COMMUNICATION INC., of AMERICA STATEMENT OF CASH FLOWS

FOR THE YEAR ENDED DECEMBER 31,2006

Cash flows from operating activities Net Earnings $3,8 15,597 Adjustments to reconcile changes in net cash used in operating activities. Non cash item^ Depreciation 44,783 -

Other changes I nCreaSe inaEountsTeceiiable- (1 9,057) Decrease in Deposits 4,016 Increase in inventory (147,793) Decrease in accounts payable &123,571)

I____ - - __ __ - - -- - - - - -

Net cash used in operating activities 573,975

Cash flows from financing activities Decrease in notes payable Increase in notes payable related party Increase in Deferred Taxes and Contracts Payable

(52,623) 36,513

209,961

Net cash provided by financing activities 193,851

Cash flows from investing activities Increase in investments receivable Increses in Long Term Investments Increase in K-I distributions Increase in plant and equipment net of dispositions

(858,188) (28,742) (76,000) /9,539)

Net cash provided by investing activities (972,469)

Net increase (decrease) in cash and cash equivalents 1204,6431

Cash and cash equivalents at beginning of year 1,231,778

Cash and cash equivalents at year end 1,027,135

Additional Information Interest Expenses for the year 4,517

SEE ACCOUNTANTS' REVIEW REPORT AND NOTES TO FINANCIAL STATEMENTS -4-

GLOBAL CONNECTION, INC. of AMERICA NOTES TO FINANCIAL STATEMENTS

FOR The YEAR ENDED DECEMBER 31,2006

NOTE I- SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Company's Activities and Operating Cycle Global Connection, Inc. of America is a Sub Chapter S type Corporation with a single shareholder. The Company is licensed by th Georgia Public Service Commission as a reseller of telecommunications services in the State of Georgia. The Company is also licensed in Kentucky, Texas, Alabama, North Carolina, Arkansas, Indiana, Florida, Michigan Mississippi, South Carolina, Tennessee, Wisconsin, Illinois, Kansas and Ohio. The Company began its operations inMay of 1988. The Company provldes credit- iTtIiGior<mal c i i r x o f b u s r n ~ s s o - ~ c u s ~ s a n d e ~ r m s ongoing credit evaluations of those customers. It maintains allowances for doubtful accounts based on factors surrounding the credit risk of specific customers, historical trends, and other information.

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Income taxes. The corporation is organized as a subchapter S type corporation. As a subchapter the corporation makes no provision for either Federal or State Federal or State income taxes. Deferred taxes are composed of communication taxes.

Cash and Cash Equivalents. For purposes of reporting cash flows, cash is defined as cash on hand, deposits, and amounts held at financial institutions.

Estimated in Financial Statements. The preparation of financial statements in conformity with generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent liabilities at the date the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.

NOTE-2 PLANT AND EQUIPMENT The Company depreciates its assets utilizing the straightline half year convention. Furniture, Fixtures, and Equipment: Office Furniture and Office Equipment

Computers and Software 189,646 Accumlated Depreciation (381,908)

$131,131 Vehicles 182,980

Net Plant and Equipment $121 ,a49

NOTE -3 RELATED PARTY TRANSACTIONS The Company has a note payable to a corporation wholly owned by its sole shareholder. The note carries no fixed interest rate or repayment period. The company also has outstanding investments with related parties in stocks and other investments with no fixed return on investment dates.

NOTE 4 NOTES PAYABLE The company has a line of credit with Wachovia at prime plus one.. The balance due on December 31,2006 was $22,370.

-5-

GLOBAL CONNECTION, INC. of AMERICA NOTES TO FINANCIAL STATEMENTS Continued

FOR The YEAR ENDED DECEMBER 31,2006

NOTE 5 INVESTMENTS RECEIVABLE The Company invests what it determines to be excess cash balances at the end of each month with financial institutions. The investments are returned to the company at the beginning of the nex month, usually within a three day period.

NOTE 6 CONCENTRATION OF CREDIT RISK The Company maintains several accounts at banking institutions. Accounts at these institutions are insured by the Federal Depository Insurance Corporation (FDIC) for up to $100,000 Cash at financial institutions exceeded this limit by $288,432- - - -- - --- - - - _-_-

See Accountants Review Report

I Company ALLTEL COMMUNICATIONSl INC. - GA ALLTEL COMMUNICATIONS, INC. - GA ALLTEL. COMMUNICATIONS, INC. - GA ALLTEL COMMUNICATIONS, INC. - GA ALLTEL COMMUNICATIONS, INC. - GA ALLTEL COMMUNICATIONS, INC. - GA ALLTEL COMMUNICATIONS, INC. - GA

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-- IDELGAXARSO--------- _- - - --

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-- MDSNGAMA34E _ _ -- --

BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOlJTH PELECOMM INC DBA SOUTHERN BELL TEL & PEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL. BELLSOUTH PELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL. BELLSOUTH TELECOMM INC DBA SOUTHERN BELL PEL. & TEL

BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL- BELLSOUTH TELECOMM INC DBA SOlJTHERN BELL PEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC RBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL. BELLSOUTH TELECOMM INC DBA SOLJTHERN BELL TEL & T‘EL. BELLSOlJTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BEL-LSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELL.SOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BEL.L TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL PEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & PEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUPHERN BELL TEL & PEL. BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL PEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & PEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & PEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL. BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOlJTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & PEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL R TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOlJTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & PEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL

BEL LSO U1HJ-E-L-ECOM M_ IN C- RB A S 0 UT H ER N BE LLT E L &-TE L-- -

DLTHGAHS47C BRMNGAES53A CRTNGAMA83C R PVLGAMA85 C SMY RGAMADS 1 LULAGAMA86C B RVI GAMA35A AIVLGAMA77A SNMTGALRDSI GNGRGAMA49C CMNGGAMA88C - - - - NRCRGAMA84A DNWDGAMA67A M RTTGAMA42 G LTVLGACS RS 1 WDSTGACR92 E CNYRGAMA48F LLBNGAMADSI TUKRGAMADS2 PW S PGAAS94A B U FRGABH 94A HMPNGA J W94A ASTLGAMA94F DGVLGAMA94F MCDNGAGS95A FLBRGAMADSI MR RW GAMA96 F FRBNGAEB96A ACWOGAMA97E MRTTGAEA97F CLMTGAMA98C SNLVGAMA97F CHMBGAMADSO PAN LGAMA98 F LRVLGAOSDSI RVDLGAMA99A RSWLGAMADSI SMYRGAPF95C WYCRGAMA28C LMCY GAMA36C BXLY GAES36A HZLHGAMA37C BLCSGAES44C LYNSGAMA52E VDALGAMARS 1 BRWKGAMA26C JHCRGAESRSI J ESPGAES42A SVNHGAS159E JKISGAMA63C SSISGAESRSI SVNHGADE35C

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BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOLJTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL BELLSOUTH TELECOMM INC DBA SOUTHERN BELL TEL & TEL

CXTNGAMA73A POLRGAMA74E TBISGAMA78C SVNHGABS65A SVNHGAWIBSA ALLSWITCHES SVNHGABS23A SVNHGAWB92C SVNHGAGC96A _- --

_I

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