2022 5 23 Peerless TT 214 LOA
The Letter of Agreement establishes national-security and law-enforcement commitments connected to the proposed transfer of control of Peerless Network’s domestic and international Section 214 authority to Infobip.
What it does The agreement requires the PNI Companies—Peerless Network, Inc., Airus, Inc., and WaveNation, LLC—and Infobip Ltd. and Infobip Inc. to maintain U.S.-based law-enforcement and security contacts, support lawful U.S. process and CALEA compliance, protect U.S. Records and domestic communications infrastructure, and restrict foreign access or disclosure absent USDOJ consent or a U.S. court order. It also imposes security-plan, incident-reporting, equipment, vendor, network-operations-center, outsourcing, ownership-change, annual-reporting, and site-visit requirements.
Who it affects The commitments apply principally to the PNI Companies and Infobip, including relevant employees, foreign personnel, vendors, contractors, outsourced or offshored service providers, and network-equipment suppliers. USDOJ, including the FBI, reviews or objects to numerous proposed personnel, systems, locations, providers, and plans.
Why it matters The LOA conditions the proposed telecommunications ownership transfer on continuing controls over sensitive customer and network information, lawful interception, foreign-government requests, cybersecurity, and supply-chain risk. Breach or unresolved national-security concerns could support FCC action affecting the relevant authorization.
Key dates and numbers
- Dated May 23, 2022; concerns the transfer application identified as ITC-T/C-20211108-00165 and WC 21-434.
- The PNI Companies must generally report security incidents or breaches within 72 hours of knowledge; CPNI incidents also trigger reporting within seven business days under the cited rule.
- Many post-approval submissions are due within 15, 30, or 60 days; annual reports begin one year after FCC approval.
- The existing international authorization is FCC File No. ITC-214-20080304-00146.