Gigsky, Inc. — Letter of Agreement (Team Telecom, Docket ISP-PDR-20160415-00008)
The Letter of Agreement requires GigSky and GigSky Mobile to implement national-security, law-enforcement, and public-safety safeguards as a condition of DOJ’s no-objection notification to the FCC’s consent to GigSky’s foreign-ownership application.
What it does The agreement governs GigSky’s U.S. telecommunications operations and requires the company to maintain its headquarters in the United States, screen personnel with unescorted access to domestic communications infrastructure, provide advance notice of ownership, business, service, vendor, and network changes, comply with CALEA and lawful U.S. process, and establish DOJ-approved points of contact and a Network and Systems Security Plan. It restricts disclosure of U.S. records and domestic communications in response to non-U.S. government requests, requires U.S. storage of U.S. records, and establishes equipment inventories, DOJ objection rights, audits, site visits, and annual compliance reporting.
Who it affects The commitments bind GigSky, GigSky Mobile, and their successors, assigns, subsidiaries, and affiliates. They cover personnel, contractors, outsourced providers, vendors, principal network equipment, U.S. customer records, domestic communications, and foreign telecommunications relationships. DOJ administers the agreement, while the FCC’s relevant licenses and authorization are exposed to remedies for breach.
Why it matters The LOA illustrates Team Telecom mitigation of foreign-ownership and communications-security concerns through continuing oversight rather than a one-time approval. It centralizes U.S. lawful-process handling, limits foreign access to protected data and infrastructure, and gives DOJ a role in reviewing corporate, operational, storage, and equipment changes. A breach may lead DOJ to request that the FCC modify, condition, revoke, cancel, terminate, or void a relevant authorization.
Key dates and numbers
- October 20, 2017: date on the letter.
- 30 days: advance notice generally required for specified ownership, business, service, storage, and vendor changes.
- 60 days: deadline for the Network and Systems Security Plan and initial books and records.
- 180 days: deadline for the principal network equipment inventory.
- November 1, 2018: beginning of annual reports, books-and-records submissions, and related reporting cycle.
- Licenses WQJZ324 and WQJZ325; FCC docket ISP-PDR-20160415-00008 and TT Number 16-35.