Case No. CU-77778

Date issued: Sep. 29 2009

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TURBOFAC Commentary (181 words)

Notes:

1) This letter generally restates 515.542(b) and (c), as they were in September of 2009 (see https://www.govinfo.gov/content/pkg/CFR-2010-title31-vol3/xml/CFR-2010-title31-vol3-part515.xml). The provisions have been amended slightly since 9/8/2010.

Further information about this particular applicant and its roaming-related agreements with the Cuban government can be found at https://www.fcc.gov/document/iconnect-wholesale-inc-dba-telecuba.

Note that the letter refers specifically to "roaming services in Cuba for U.S. cellular telephones". At the time the letter was issued, the GL authorized "...the provision of telecommunications services between the United States and Cuba..." Would that have covered a U.S. cellular phone user in Cuba receiving a call from a third country? The provision was later amended to refer to "telecommunications services related to the transmission or the receipt of telecommunications involving Cuba," thereby mooting the interpretive question, but there is...