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Cuban Assets Control Regulations License No. CU-76280
LICENSE
(Granted under the authority of 50 U.S.C. App. 5(b), 22 U.S.C. 2370(a), 22 U.S.C,6001-10, Proclamation 3447, and 31 CFR Parts 501 and 515)
To: LD Telecommunications Inc. (the "Licensee")
5757 Blue Lagoon Dr., Suite 190
Miami, FL 33126
Attn: Juan Carlos Canto, CFO
1. Pursuant to your letter dated October 4, 2006 (the "Application"), the following transactions are hereby licensed:
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2. This license is granted upon the statements and representations made in your application, or, otherwise filed with or made to the Treasury Department as a supplement to your application, and is subject to the conditions, among others, that you comply in all respects with all regulations, rulings, orders and instructions issued by...
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This license issued payments in connection with an authorization that provided as follows:
"all transactions incident to the use of cables, satellite channels, radio signals, or other means of telecommunications for the provision of telecommunications services between Cuba and the United States, including telephone, telegraph and similar services, and the transmission of radio and television broadcasts and news wire feeds between Cuba and the United States, are authorized".
See https://www.govinfo.gov/content/pkg/CFR-2005-title31-vol3/xml/CFR-2005-title31-vol3-part515.xml
Note that the license presupposes that "services between Cuba and the United States" included services through third countries (see references to "funds paid to third parties for telecommunications transmissions routed from the United States through third countries under transit, refile or other alternate routing agreements"). This is a notable interpretation of the phrase "between Cuba and the United States". Currently, the telecommunications GL in the