What it does The agreement requires Gridiron Fiber and its subsidiaries, Trailblazer, Gridiron Holdco, and T-Mobile to maintain U.S.-based law-enforcement and security points of contact; screen personnel with access; protect U.S. Records, domestic communications, network infrastructure, and lawful U.S. process; and obtain Committee, DOJ, DHS, or DoD review or non-objection for specified foreign access, countries of access, principal equipment, service providers, storage locations, and network-operations-center changes. It requires prompt reporting of security incidents, generally within 72 hours, updated cybersecurity and network-security plans, annual compliance reports, site visits, and possible third-party audits. This LOA supersedes the parties’ cited 2023, 2017, and 2020 mitigation agreements upon FCC approval.

Who it affects The obligations primarily bind the Licensees and their affiliates, Trailblazer, Gridiron Holdco, and T-Mobile, while giving the Committee and DOJ, DHS, and DoD monitoring and objection rights.

Why it matters The agreement makes approval of the telecommunications-control transfer contingent on continuing controls over sensitive U.S. customer data, lawful-intercept capability, foreign personnel and vendors, network equipment, and supply-chain risks. Breach or unresolved risks may support FCC license modification, conditioning, revocation, or other enforcement.

Key dates and numbers

• Executed February 13–14, 2025; effective as to the superseded LOAs on the Date of FCC Approval.
• Initial LEPOC and Security Officer nominations are generally due within 15 days after FCC approval; screening policies, plans, equipment, and service-provider submissions have 30- or 60-day deadlines.
• Security incidents must generally be reported within 72 hours; annual reports are due one year after FCC approval and annually thereafter.
• The related proceedings are FCC File Nos. ITC-ASG-20240515-00086 and ITC-T/C-20240515-00085, and WC Docket No. 24-151 (TT 24-029 to -031).