WPC4f 2MBVRKZ3|a7jC:,Xj\  P6G;XP"i~'^:DPddDDDdp4D48dddddddddd88pppX|pDL|pp||D8D\dDXdXdXDdd88d8ddddDL8ddddX`(`lD4l\DDD4DDDDDDDDd8XXXXXX|X|X|X|XD8D8D8D8ddddddddddXdbdddpdXXXXXlX~|X|X|X|XdddldldD8DdDDDdplld|8|P|D|D|8dvddddDDDpLpLpLpl|T|8|\ddddddl|X|X|Xd|DdpL|Dd~4ddC$CWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHxxH\dDXddddd8@d<@d<DDXXdDDxddzHxxHvppDXd<"dxtldpxxdHP LaserJet 4M (PCL) (A) rm 821-BHL4MPCAD.PRSXj\  P6G;\ QXP2/ KK3|a"i~'^ %>77n\%%%7>%7777777777%%>>>7gOIOOIDVV*7VIgOVDVO>IOOnOOI%%@7%7>0>0%7>%>\>7>>0*%>7O770,,9%9@%%%%%%%%%7%>O7O7O7O7O7nOO0I0I0I0I0))))O>V7V7V7V7O>O>O>O>O7O7O>U7V7O7O7C>O7O7O7O0O0O9O0OQI0I0I0I0V7V7V7V9V7V>V@**>*%*>Y>99V>II2I%I,IO>OO>O>V7V7mOO0O0O0>*>*>*>9I8I%I@O>O>O>O>O>O>nOO9I0I0I0O>I%O>>*I%O7P77%%WMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN(BB(:7%77777j7!%TT7!%QQ7T!%%777n&&Bn77nCTn(nBB(E\\>>n%77\n!"IIIITTenn7TnBA;7>lBBn7"i~'^5Fg\\>>>\g0>03\\\\\\\\\\>>ggg\yyyyyF\yrrygryyrr>3>g\>\\Q\Q>\g33\3g\\\FF3gQy\QF>(>g>0gg>>>0>>>>>>\>\3y\y\y\y\y\yQyQyQyQyQF3F3F3F3g\\\\ggggrQy\\\\rQ\r\y\y\y\yQyQygyQyQyQyQyQ\\\g\ggF3F\F>F\gggy\r3r_r>rFr3ggg\\yFyFyFgFgFgFggrcr3rgggggggyrgrFrFrF\r>ggFr>r\0\\=3=WddddddddddddddddddddddddddddddddddddddddNBnnB\\F\\\\\\07\7>\7>>\\\??n\\pBnnBigg>\\7"yyyy\nyc\gnn\2KaK K KB"i~'^09]SS999S]+9+/SSSSSSSSSS99]]]Sxnxxng?Snxgx]nxxxxn9/9aS9S]I]I9S]/9]/]S]]I?9]SxSSIC%CW9+Wa999+999999S9]/xSxSxSxSxSxxInInInInI>/>/>/>/x]SSSSx]x]x]x]xSxSx]SSxSxSf]xSxSxSxIxIxWxIx{nInInInISSSWS]a?/?]?9?]]WW]n/nKn9nCn/x]xx]x]SSxxIxIxI]?]?]?]WnUn9nax]x]x]x]x]x]xxWnInInIx]n9x]]?n9xSz+SS8-8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNP\  `$Times NewRoman&G\  P?&P\  `$Times NewRoman&A\  P@P\  `$Times NewRoman&G\  PA&P\  `$Times NewRoman&A\  PBP\  `$Times NewRoman&G\  PC&P\  `$Times NewRoman&A\  PDP(hH  Z 6Times New Roman RegularXN\  PEXP(hH  Z 6Times New Roman RegularXA\  PFP\  `$Times NewRoman&G\  PG&P\  `$Times NewRoman&XN\  PHXP(hH  Z 6Times New Roman RegularXA\  PIP(hH  Z 6Times New Roman RegularXN\  PJXP(hH  Z 6Times New Roman RegularXA\  PKP\  `$Times NewRoman&G\  PL&P\  `$Times NewRoman&XN\  PMXP(hH  Z 6Times New Roman RegularX&G\  PN&P\  `Times&A\  POP\  `$Times NewRomanA\  PPP\  `$Times NewRomanA\  PQP\  `$Times NewRoman&G\  PR&P\  `Times&A\  PSP\  `$Times NewRoman&G\  PT&P\  `$Times NewRoman&XN\  PUXP(hH  Z 6Times New Roman RegularX&G\  PV&P\  `Times&A\  PWP\  `$Times NewRomanA\  PXP\  `$Times NewRomanA\  PYP\  `$Times NewRoman&G\  PZ&P\  `Times&A\  P[P\  `$Times NewRoman&G\  P\&P\  `$Times NewRoman&A\  P]P(hH  Z 6Times New Roman RegularA\  P^P\  `$Times NewRomanA\  P_P(hH  Z 6Times New Roman RegularXN\  P`XP(hH  Z 6Times New Roman RegularXA\  PaP\  `$Times NewRoman&G\  Pb&P\  `$Times NewRoman&XN\  PcXP(hH  Z 6Times New Roman RegularX&G\  Pd&P\  `Times&A\  PeP\  `$Times NewRomanA\  PfP\  `$Times NewRomanA\  PgP\  `$Times NewRoman&G\  Ph&P\  `Times&A\  PiP\  `$Times NewRoman&G\  Pj&P\  `$Times NewRoman&XN\  PkXP(hH  Z 6Times New Roman RegularX&G\  Pl&P\  `Times&A\  PmP\  `$Times NewRomanA\  PnP\  `$Times NewRomanA\  PoP\  `$Times NewRoman&G\  Pp&P\  `Times&A\  PqP\  `$Times NewRoman&G\  Pr&P\  `$Times NewRoman&XN\  PsXP(hH  Z 6Times New Roman RegularX&G\  Pt&P\  `Times&A\  PuP\  `$Times NewRomanA\  PvP\  `$Times NewRomanA\  PwP\  `$Times NewRoman&G\  Px&P\  `Times&A\  PyP\  `$Times NewRoman&G\  Pz&P\  `$Times NewRoman&XN\  P{XP(hH  Z 6Times New Roman RegularX&G\  P|&P\  `Times&A\  P}P\  `$Times NewRomanA\  P~P\  `$Times NewRomanA\  PP\  `$Times NewRoman&G\  P&P\  `Times&A\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&XN\  PXP(hH  Z 6Times New Roman RegularX&G\  P&P\  `Times&A\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRoman&G\  P&P\  `Times&A\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&XN\  PXP(hH  Z 6Times New Roman RegularX&G\  P&P\  `Times&A\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRoman&G\  P&P\  `Times&A\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&A\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&XN\  PXP(hH  Z 6Times New Roman RegularXA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanXN\  PXP(hH  Z 6Times New Roman RegularXA\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&XN\  PXP(hH  Z 6Times New Roman RegularXA\  PP\  `TimesA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanA\  PP\  `Times&G\  P&P\  `Times&A\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&A\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&XN\  PXP(hH  Z 6Times New Roman RegularX&G\  P&P\  `Times&A\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRoman&G\  P&P\  `Times&XN\  PXP\  `$Times NewRomanX&G\  P&P\  `$Times NewRoman&XN\  PXP(hH  Z 6Times New Roman RegularX&G\  P&P\  `Times&A\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRoman&G\  P&P\  `Times&A\  PP(hH  Z 6Times New Roman RegularA\  PP\  `TimesA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanA\  PP\  `$Times NewRomanXN\  PXP\  `$Times NewRomanXA\  PP\  `TimesA\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&&G\  P&P\  `Times&&G\  P&P\  `$Times NewRoman&A\  PP\  `$Times NewRoman&G\  P&P\  `$Times NewRoman&XN\  PXP(hH  Z 6Times New Roman RegularX&G\  P&P\  `Times&&G\  P&P\  `$Times NewRoman&XN\  PXP\  `$Times NewRomanX&G\  P&P\  `$Times NewRoman&XN\  PXP(hH  Z 6Times New Roman RegularX"i~'^09CSS999S]+9+/SSSSSSSSSS//]]]Ixnnxg]xx9?xgxx]xn]gxxxxg9/9MS9ISISI9SS//S/SSSS9?/SSxSSIP!PZ9+ZM999+99999999S/xIxIxIxIxIlnIgIgIgIgI9/9/9/9/xSxSxSxSxSxSxSxSxSxSxIxSxRxSxSxS]SxIxIxInInInZnIxigIgIgIgIxSxSxSxZxSxZxS9/9S999Su]ZZxSg/gCg9g9g/xSbxSxSxSxSxn9n9n9]?]?]?]ZgFg/gMxSxSxSxSxSxSxxZgIgIgIxSg9xS]?g9xSi+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNI\\>>>\g0>03\\\\\\\\\\33gggQyyrg>Frgygrr>3>T\>Q\Q\Q>\\33\3\\\\>F3\\\\QX%Xc>0cT>>>0>>>>>>>>\3QQQQQwyQrQrQrQrQ>3>3>3>3\\\\\\\\\\Q\Z\\\g\QQQyQyQycyQtrQrQrQrQ\\\c\c\>3>\>>>\gcc\r3rIr>r>r3\l\\\\y>y>y>gFgFgFgcrMr3rT\\\\\\crQrQrQ\r>\gFr>\t0\\=!=WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNBnnBT\>Q\\\\\3;\7;\7>>QQ\??n\\pBnnBmgg>Q\7"yyyy\njc\gnn\"i~'^5>g\\>>>\g0>03\\\\\\\\\\>>ggg\yyrF\yrgyy>3>j\>\gQgQ>\g3>g3g\ggQF>g\\\QI(I_>0_j>>>0>>>>>>\>g3\\\\\QyQyQyQyQD3D3D3D3g\\\\gggg\\g\\\\pg\\\QQ_QyQyQyQyQ\\\_\gjF3FgF>Fgg__gy3ySy>yIy3ggg\\QQQgFgFgFg_y^y>yjgggggg_yQyQyQgy>ggFy>\0\\=2=WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNBnnBa\>\\\\\\7>\7>\7>>\\\??n\\pBnnBsgg>\\7"yyyy\nlc\gnn\2}K6f KK2"i~'^ %,77\V%%%7>%7777777777>>>0eOIIOD>OO%*ODaOO>OI>DOOgOOD%%37%07070%777V7777%*77O77055;%;3%%%%%%%%%%%7O0O0O0O0O0aHI0D0D0D0D0%%%%O7O7O7O7O7O7O7O7O7O7O0O7O6O7O7O7>7O0O0O0I0I0I;I0OED0D0D0D0O7O7O7O;O7O;O7%%7%%%7M>;;O7DD,D%D%DO7AO7O7O7O7aOI%I%I%>*>*>*>;D.DD3O7O7O7O7O7O7gOO;D0D0D0O7D%O7>*D%O7E77%%WMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN(BB(37%07777j7#TT7!#TT7T!%%007n&&Bn77lCTn(nBB(A\\>>n%07\n!"IIIITTenn7TnB@;7>lBBn7",tB^ f ^6:Nmm066m666:mmmmmmmmmm66iznmi~3Us_ssbisssn6:6\\0ifsQz~66i3~~UUUzmfm_Q\Qm4mmmmm6mmmmmm\ms6iiiiipfmsmsmsms36363636~~~~~zzzzsmij~~sm~scmcccnmnmyjcmsmsjcj~z~z~z~z~~36msmm4simmsmc,c>mm_=_3jj~j~uBuBsmu\bUu\mmrIrBmmzjzzjzsmnXn_nXmm~mmmmsmy6\\000WddddddddddddddddddddddddddddddddddddddddN\mm:ibbmmmmmmGN\\mG00GGm@@mmpp\\\~~0G\G"\i\4\==m6\mfm\6m\miwbzpNm\QQ6666fzbf\bmUpNib3,s\_ffsNiisbmmQiUsbsX~m6mssbf~~66mmmmmmmsss6i\Q=Tgnj}}ccyyTjcc;T;TXFu"i~'^5>M\\>>>\}0>03\\\\\\\\\\>>}}}\rryrr>Qygyrr\grrggF3FM\>\\Q\Q3\\33Q3\\\\FF3\QyQQFI3Ic>0cM>>>0>>>>>>\>\3r\r\r\r\r\yyQrQrQrQrQ>3>3>3>3y\\\\\\\\\gQr\\\\gQ\r\r\r\r\yQyQycyQnrQrQrQrQ\\\c\c\>3>\>>>\\ccyQg3gBg>g;g3y\jy\y\\\yrFrFrF\F\F\FccgBg3gM\\\\\\ygcgFgFgF\g>y\\Fg>g\n0\\=(=WddddddddddddddddddddddddddddddddddddddddNBnnB_\F\\\\\\3;\7;\7>>gg\??n\\pBnnBb\\>g\7"yyyy\njc\}nn\"i~'^"(22TN"""28"2222222222888,\HBBH>8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""""2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d""oaTechnical[7]Eg%Technical Document Style O g% W4I O g;&-.  . Technical[8]Eg%Technical Document Style O g% W4I O g<&/0  . MACNormal=;     X` hp x (#%'0*,.8135@8:<    #:}D4P XP#T I. A. 1. a.(1)(a) i) a)T,0*ÍÍ,*Í ., US!!!! ! #:}D4P XP#     X` hp x (#%'0*,.8135@8:<    #:}D4P XP#,0*ÍÍ,*Í ., US!!!! ! #:}D4P XP#Footnote>Íč2?i@kA~Bi|header?Ax 4 <D  #FxX  Pg9CXP# reference@;#FxX  Pg9CXP#itemizeX1A&V 8F ` hp xr#FxX  Pg9CXP#header2BI ` hp x`    #FxX  Pg9CXP# 2C^D uEFCheading 3CF` hp x #FxX  Pg9CXP# CitatorFormat Secretary's Citator Output FileDW r5-#d6X@`7Ͽ@# XX  X B r5-S  BFormat DownloadFormat Downloaded DocumentEiޛ r5- XX    \ #d6X@`7Ͽ@#HeadingChapter HeadingFJ d  ) I. ׃  2G)HId]JRight ParRight-Aligned Paragraph NumbersG>a݅@  I.   X(# SubheadingSubheadingH0\ E A.  HIGHLIGHT 1Italics and BoldldeddI+. DRAFT ONHeader A Text = DRAFT and DateJ X =8` (#FDRAFTă r  ` (#=D3 1, 43 12pt (Z)(PC-8))T2Dă  ӟ23 KL1M1 N1 DRAFT OFFTurn Draft Style offK@@    LETTER LANDLetter Landscape - 11 x 8.5L 3'3'Standard'3'3StandardLetter Portrait - 8.5 x 11 ;   LEGAL LANDLegal Landscape - 14 x 8.5Mf 3'3'Standard'A'AStandardZ K e6VE L"nu;   LETTER PORTLetter Portrait - 8.5 x 11NL 3'3'Standard3'3'StandardZ K e6VE L"nU9   2O1e Pn QRdLEGAL PORTLegal Portrait - 8.5 x 14O 3'3'StandardA'A'StandardLetter Portrait - 8.5 x 119   TITLETitle of a DocumentPK\ * ăBLOCK QUOTESmall, single-spaced, indentedQN X HIGHLIGHT 2Large and Bold LargeRB*d. 2SjTUEV-HIGHLIGHT 3Large, Italicized and UnderscoredS V -qLETTERHEADLetterhead - date/marginsTu H XX  3'3'LetterheadZ K e VE L"n3'3'LetterheadZ K e VE L"nE9    * 3'3'LetterheadZ K e VE L"n3' II"n"Tv3'StandarddZ K e VE L"nU9 Ѓ   INVOICE FEETFee Amount for Math InvoiceU ,, $0$0  MEMORANDUMMemo Page FormatVD.   ! M E M O R A N D U M ă r  y<N dddy   2W8HX8YZXYINVOICE EXPSEExpense Subtotals for Math InvoiceW:A ,p, $0$00INVOICE TOTTotals Invoice for Math MacroXz 4p, $0$00INVOICE HEADRHeading Portion of Math InvoiceY+C`*   4X 99L$0 **(  ӧ XX NORMALReturn to Normal TypestyleZ2O[[\[>][^[SMALLSmall Typestyle[FINEFine Typestyle\LARGELarge Typestyle]EXTRA LARGEExtra Large Typestyle^2W_[`aX_bVERY LARGEVery Large Typestyle_ENVELOPEStandard Business Envelope with Header`+w ,,EnvelopeZ K e VE L"n,,EnvelopeLarge, Italicized and Under;    ,, 88+  `   1adfStyle 14Swiss 8 Pt Without Marginsb$$D Co> PfQ  )a [ PfQO 2%cd)el#ft$Style 12Dutch Italics 11.5c$$F )^ `> XifQ  )a [ PfQO Style 11Initial Codes for Advanced IIdJ )a [ PfQK  dddn  #  [ X` hp x (#%'b, oT9 ! )^ `> XifQ ` Advanced Legal WordPerfect II Learning Guide   x )^ `> XifQ Advanced Legal WordPerfect II Learning Guide   j-n )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  jBX )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 3oDutch Roman 11.5 with Margins/Tabse )a [ PfQO  ddn  # c0*b, oT9 !Style 4 PSwiss 8 Point with MarginsfDq Co> PfQ  dddd  #  2'gB%h|%iJ&j&Style 1.5Dutch Roman 11.5 Fontg4h )a [ PfQO  dddn Style 2Dutch Italic 11.5h$ )^ `> XifQ Style 5Dutch Bold 18 Pointi$RH$L T~> pfQ_  )a [ PfQO Style 7Swiss 11.5j$$V )ao> PfQ ]  )a [ PfQO 2o7k'l\(mc-nj2Style 6Dutch Roman 14 Pointk$$N w [ PfQ   )a [ PfQO Style 10oInitial Codes for Advancedl U )a [ PfQK  dddn  ##  [[ b, oT9 !b, oT9 !n )^ `> XifQ ` Advanced Legal WordPerfect Learning Guide   f )^ `> XifQ Advanced Legal WordPerfect Learning Guide   Q" )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  QN~ )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 8PfInitial Codes for Beginninggmi )a [ PfQK  dddn  # X` hp x (#%'b, oT9  [ &e )^ `> XifQ ` Beginning Legal WordPerfect Learning Guide   d )^ `> XifQ Beginning Legal WordPerfect Learning Guide   jH )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  j )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 9Initial Codes for Intermediaten )a [ PfQK  dddn  # X` hp x (#%'b, oT9 Њ [ e )^ `> XifQ ` Intermediate Legal WordPerfect Learning Guide   3 )^ `> XifQ Intermediate Legal WordPerfect Learning Guide   jf )^ `> XifQ    Copyright  Portola Systems, Inc.`+ >Page  jX )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 2O>o7p}<q4=r=UpdateInitial Codes for Update Moduleo )a [ PfQK  dddn  #  [ X` hp x (#%'b, oT9 !n )^ `> XifQ ` Legal WordPerfect 5.0 Update Class Learning Guide   f )^ `> XifQ Legal WordPerfect 5.0 Update Class Learning Guide   Q" )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`7 CPage  jN~ )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 a1Paragraph+%X,1. a. i. (1) (a) (i) 1) a)%8=(%  H*%Fp$ a2Paragraph+%X,1. a. i. (1) (a) (i) 1) a)%8=(%  H*%Fq/ a3Paragraph+%X,1. a. i. (1) (a) (i) 1) a)%8=(%  H*%Fr: 2;As>t?u?v|@a4Paragraph+%X,1. a. i. (1) (a) (i) 1) a)%8=(%  H*%FsE a5Paragraph+%X,1. a. i. (1) (a) (i) 1) a)%8=(%  H*%FtP   a6Paragraph+%X,1. a. i. (1) (a) (i) 1) a)%8=(%  H*%Fu[   a7Paragraph+%X,1. a. i. (1) (a) (i) 1) a)%8=(%  H*%Fvf  2FwmAxl7ByBzDa8Paragraph+%X,1. a. i. (1) (a) (i) 1) a)%8=(%  H*%Fwq Default Paragraph FoDefault Paragraph Fontx toc 1toc 1y` hp x (#!(#B!(#B` hp x (#toc 2toc 2z` hp x (#` !(#B` !(#B` hp x (#2O{G|/I}MK~kMtoc 3toc 3{` hp x (#` !(# ` !(# ` hp x (#toc 4toc 4|` hp x (# !(#  !(# ` hp x (#toc 5toc 5}` hp x (#h!(# h!(# ` hp x (#toc 6toc 6~` hp x (#!(#!(#` hp x (#2VvO1PORmTtoc 7toc 7 toc 8toc 8` hp x (#!(#!(#` hp x (#toc 9toc 9` hp x (#!(#B!(#B` hp x (#index 1index 1` hp x (#` !(# ` !(# ` hp x (#2[VXvZlo[index 2index 2` hp x (#` !(#B` !(#B` hp x (#toatoa` hp x (#!(# !(# ` hp x (#captioncaption _Equation Caption_Equation Caption 2fd \iqcdme7jC:,9Xj\  P6G;XP <~9nnn,ln6X@`7&@%y.X80,X\  P6G;P2a=5,&a\  P6G;&P2e=5,&e4  pG;&L,t=6,-lC&tA P-7&P\#0_=5,;&_*f9 xr G;&X&H5!,i,5\  P6G;,P$P:% ,J:\  P6G;JPW!@(#,h@\  P6G;hP7nC:,|Xn4  pG;X\5hC:,;2Xh*f9 xr G;XX 6jC:,RXj9 xOG;X@|ND,5|\  P6G;P\=yND,;"y*f9 xr G;X?|ND,Rؼ|9 xOG;\'{,W80,;0W*f9 xr G;Xy.\80,T\4  pG;(1a=5,Rt&a9 xOG;&P=% ,4IJ=4  pG;JXX` `  ` @ WPCg 2MBVRKZ3|j7jC:,9Xj\  P6G;XPWPCi 2MBVRKZ3|j7jC:,9Xj\  P6G;XP22f X- I. A. 1. a.(1)(a) i) a) 1. 1. a. i.(a)(i) 1) a)ٲX0Í ÍX8Í Í  5) DA 961130  X-(##Xj\  P6G;9XP#U  X-J+ Before the  X-[  FEDERAL COMMUNICATIONS COMMISSION  X-Washington, D.C. 20554 ĐlU  XH-In the Matter of hh,V)  X1- hh,V)  S -#&G\  P&P#TELEGLOBE USA INC.hh,V)#&G\  P&P# ` `  hh,V) ` `  hh,V)  S -#&G\  P&P#Application for Authority Pursuant to Section 214)ppFile No. ITC95466  Sz -of the Communications Act of 1934, as Amended, )  SR -to Resell Private Lines Not Interconnected into )  S*-the Public Switched Network between the V)  S-United States and International Pointshh,V) ` `  hh,V)  S-Application for Authority Pursuant to Section 214 )ppFile No. ITC95467  S-of the Communications Act of 1934, as Amended,)  Sb-to Provide International Services from the V)  S:-United States to International Points Through V)  S-Resale of International Switched ServicesV) ` `  hh,V)  S-Application for Authority Pursuant to Section 214)ppFile No. ITC95468  S-of the Communications Act of 1934, as Amended, )  Sr-to Resell Private Lines Interconnected with the )  SJ-Public Switched Network at One or Both Ends for )  S"-Provision of Switched Services between the United )  S-States and the United Kingdomhh,V) ` `  hh,V)  S-Application for Authority Pursuant to Section 214)ppFile No. ITC96074  S-of the Communications Act of 1934, as Amended, )  SZ-to Resell Interconnected Private Lines Between the)  S2-United States and Sweden for the Provision of )  S -Switched Services hh,V)   S!-  ORDER, AUTHORIZATION AND CERTIFICATE l  SB#-lUAdopted: July 15, 1996hh,VReleased: July 15 @ , 1996  S%- By the Acting Chief, International Bureau:  S&-  Sz'-1.` ` In this Order, Authorization and Certificate (Order) we grant authority to Teleglobe USA Inc. (Teleglobe USA) to resell switched and noninterconnected private line services of unaffiliated U.S. international carriers for the provision of authorized international services. We also",)0*0*0*0*" grant Teleglobe USA authority to resell interconnected private lines between the United States and the United Kingdom, and between the United States and Sweden, for the provision of switched services.  S-  S-? I. Background lU  S8- 2.` ` Teleglobe USA is a Delaware corporation which is, ultimately, a whollyowned  S-subsidiary of Teleglobe Inc. (TGI),Xy yOx- l#X\  P6G;P#эXTGI is owned, on an undiluted basis, by Telesystems Telecom Ltd. (19.89%), BCE Inc. (21.96%), and  Caisse de depot et placement du Quebec (16.34%), with the remaining shareholders holding less than 10%. On a fully diluted basis, no single shareholder owns more than 25% of TGIs equity. (#Ƣ a Canadian telecommunications holding company. Among TGIs  S-holdings is Teleglobe Canada Inc. (TGC), the monopoly provider of overseas telecommunications services in Canada. However, TGC does not provide international services to the United States, which  S-are provided on a competitive basis by a number of facilitiesbased and resale carriers.y yO -  #X\  P6G;P#эXTransborder services in Canada are provided by, among others, Stentor Canadian Network Management, Unitel, and Sprint Canada.(# Teleglobe USA is also affiliated with ORBCOMM Canada, which holds a license to provide data communications service using the ORBCOMM narrowband (nonvoice) mobile satellite system. TGI also owns Teleglobe International (UK) Ltd. (TGUK), which holds a license to provide international services in the United Kingdom through resale of international private lines (IPLs) interconnected with the public switched network (PSN).  S -3.` ` On August 5, 1995, Teleglobe USA filed three applications pursuant to Section 214 of  SX-the Communications Act of 1934, as amended (the Act),sX@y yO8-#X\  P6G;P#эX47 U.S.C.  214.(#s to commence operations as an international resale carrier. Teleglobe USA requests authority to resell: (1) (IPLs not interconnected into the PSN  S-to 69 countries, among them the United Kingdom (ITC95466) (IPL Application); (2) international  S-switched services of U.S. carriers to all countries set forth in their tariffs (ITC95467) (Switched  S-Resale Application); and (3) international private lines between the United States and the United Kingdom, interconnected into the PSN on one or both ends, for the provision of switched services (I Sn-TC95468) (UK Application). In each instance, Teleglobe USA proposes to acquire service for resale from unaffiliated U.S. international carriers. We placed the applications on public notice on  S -August 18, 1995, and received petitions to deny from AT&T Corporation (AT&T Petition) and MCI  S-Telecommunications Corporation (MCI Petition), an opposition to these petitions from Teleglobe USA  S-(Teleglobe USA Opposition), and a reply from AT&T (AT&T Reply).  S-4.` ` On January 18, 1996, we received an application from Teleglobe USA to resell IPLs between the United States and Sweden, interconnected into the PSN on one or both ends, for the  S6-provision of switched services (ITC96074) (Sweden Application). Teleglobe USA again proposes to acquire service for resale from unaffiliated U.S. international carriers. We placed this application  S-on public notice on February 6, 1996,"y {OX%- k#X\  P6G;P#эXThe Sweden Application was initially granted under the streamlined procedures set forth in Section 63.12  Mof the Commission's Rules, 47 C.F.R.  63.12. However, we set aside the streamlined grant under section  l1.113(a) of the Rules, 47. C.F.R.  1.113(a), in order to consider further the public interest aspects of"'0*(( '"  {OX- zTeleglobe USA's proposed operations in the United States, including not only the Sweden Application but  {O"- the other Section 214 applications for international service that it had submitted. See Letter from Diane J.  Cornell, Chief, Telecommunications Division to Philip M. Walker, Esq. and Charles A. Tievsky, Esq.,  {O-Teleglobe USA Inc., dated March 26, 1996.(# and received no responses."~0*((."Ԍ S-ԙH II. The Applications   S-\5.` ` International Private Line Resale Application. Teleglobe USA proposes to resell non S-interconnected IPLs to 69 countries~y {O -#X\  P6G;P#эXThese countries are listed in Appendix A to this Order.(#Ɲ and initially requests varying numbers of circuits to each destination. While Teleglobe USA does not seek authority to resell IPLs to Canada, it requests  S:-authority to establish a route to the United Kingdom, where it is affiliated with TGUK, as noted above.  S-x6.` ` Switched Resale Application. Teleglobe USA proposes to provide international voice, data, facsimile and other switched services from the United States to international points through resale of the international switched services of unaffiliated U.S. international carriers. Teleglobe USA seeks to offer service on all routes available in its underlying carriers tariffs, including p  to p  Canada.  S -7.` ` UK and Sweden Applications. Teleglobe USA proposes to acquire IPLs between the United States and United Kingdom, and between the United States and Sweden, and to interconnect these IPLs into the PSN at one or both ends for the provision of switched basic services.  S^-8.` ` AT&T & MCI Petitions to Deny. AT&T and MCI oppose grant of the Teleglobe USA  S8-applications.8y {O-#X\  P6G;P#эXAs noted supra, these petitions to deny refer to all Teleglobe USA applications except the Sweden  {O-Application.(# The basic underpinning of the petitions is that Canada does not offer "effective market  S-access"l y yO-#X\  P6G;P#эXInitially, the Commission proposed an "effective market access" standard as an important element of our  {O-public interest analysis under Section 214 of the Act. Market Entry and Regulation of Foreign {O-Affiliated Entities, Notice of Proposed Rulemaking, 10 FCC Rcd 4844, 4845 (1995). Subsequently, we adopted the effective competitive opportunities test as part of our public interest analysis, and indicated  {O@-that this test was similar to the effective market access standard. Market Entry and Regulation of  {O -ForeignAffiliated Entities, Report and Order, 11 FCC Rcd 3873, 3881 (1995) (Foreign Carrier Entry  {O-Order). See also infra at  12 (discussion of Foreign Carrier Entry Order).(#Ə to the Canadian international services market for U.S. carriers, and any resale authorization  S-granted Teleglobe USA would permit it to obtain asymmetric market access to the United States.y {O>"-#X\  P6G;P#эXAT&T Petition at 2; MCI Petition at 23.(#Ɣ Resale entry in the United States, according to AT&T and MCI, is unmatched in the Canadian market for three reasons: (1) T p GC p 's exclusive monopoly on Canadaoverseas facilitiesbased services through at least March 1997; (2) Canadian law promoting the "maximum use" of Canadian facilities for Canadaoriginating and terminating traffic (which limits the ability of U.S. carriers to route Canadian traffic over U.S. facilities); and (3) Canadian law limiting foreign ownership of voting stock in Canadian carriers (other than T p GC p ) to 20% and prohibiting nonCanadian telecommunications"H0*(("  S-common carriers from owning any equity in TGC. y {Oh-#X\  P6G;P#эXAT&T Petition at 11; MCI Petition at 34.(#ƕ AT&T and MCI declare that the public interest benefits of allowing Teleglobe USA entry are outweighed by the diminishment in competition in the provision of international services to U.S. customers that would ensue from Teleglobe USA's entry  S-into the U.S. resale market. Zy {O-#X\  P6G;P#эXAT&T Petition at 2224; MCI Petition at 5.(#Ɩ AT&T and MCI both conclude that Teleglobe USA's applications should be denied until these policies are changed to allow U.S. carriers effective access to the  S8-Canadian international services market. 8y {O -#X\  P6G;P#эXAT&T Petition at 11; MCI Petition at 56. Furthermore, AT&T explicitly argues that an essential element of effective market access is the opportunity to offer facilitiesbased basic international services in nonU.S. markets. It argues that the practical reality is that foreign carriers in important markets (including Canada) do not provide to resellers the technical functionality required in underlying services  {O -for U.S. carriers to deliver the global services U.S. customers desire. AT&T Petition at 1213.(#ƈ  S-x9.` ` Teleglobe USA Opposition. Teleglobe USA responds that in a context unrelated to the  S-present proceeding the Commission concluded that Canada affords equivalent resale opportunities.y ^y {O-#X\  P6G;P#эXTeleglobe USA Opposition at 11 (citing fONOROLA Corporation/EMI Communications Corporation,  {O-Memorandum Opinion, Order and Certificate, 7 FCC Rcd 7312 (1992), Order on Reconsideration 9  {O-FCC Rcd 4066 (1994) (fONOROLA)).(#y Teleglobe USA also points out that, while conditions in Canada's international facilities market are irrelevant to its pending resale applications, T p GC p 's exclusive Canadaoverseas mandate, the Canadian maximum use policy, and Canadian law limiting foreign ownership of Canadian common carriers are  S" -all under review by the Canadian government. " y {O-#X\  P6G;P#эXTeleglobe USA Opposition at 1213.(#ƈ  S - 10.` ` AT&T Reply. AT&T submits that the Commission's general policy in favor of open entry for resale has always been balanced by a casebycase assessment of relevant public interest  S -factors, which include the openness of a foreign carrier's market.@ X y {O|-#X\  P6G;P#эXAT&T Reply at 3 (citing Regulation of International Accounting Rates, First Report and Order, 7 FCC  {OF-Rcd 559 (1991); BT North America, Inc., Order and Certificate, 9 FCC Rcd 6851 (1994)).(#@ Here, AT&T contends that balance  S\-tips in favor of denial.v\y {O-#X\  P6G;P#эXAT&T Reply at 4.(#v  S -Y III. Discussion Đ S-\  S- 11.` ` Foreign Carrier Entry Order. On November 30, 1995, after the close of the pleading  S-cycle in this proceeding, the Commission issued the Foreign Carrier Entry Order in a rulemaking proceeding which commenced several months before the Teleglobe USA filings. In that decision, the  SH-Commission adopted standards for regulating the entry of foreign carriers into the U.S. international"HF0*(("  S-telecommunications services market. In the Sprint Declaratory Rulingy {Oh-#X\  P6G;P#эXxSprint Corporation, Declaratory Ruling and Order, 11 FCC Rcd 1850, 1855 (1996) (Sprint Declaratory  {O2-Ruling).(# we reaffirmed the Commission's wellestablished policy to apply newly adopted rules to applications filed during the  S-pendency of a rulemaking proceeding, and applied the Foreign Carrier Entry Order standards to the Sprint proceeding. We do likewise here.  S<- 12.` ` In the Foreign Carrier Entry Order, the Commission announced that, as part of the its overall public interest analysis under Section 214 of the Act, it will examine whether effective competitive opportunities exist for U.S. carriers in the destination markets of foreign carriers seeking  S-to enter the U.S. international services market through affiliation with a new or existing carrier.|$y {O -#X\  P6G;P#эXxForeign Carrier Entry Order, 11 FCC Rcd at 38843888. We explained that the factors of the effective competitive opportunities test are: the legal ability to provide the relevant service in the destination country where the applicant possesses market power; and any practical barriers to entry, including the existence of reasonable and nondiscriminatory charges, terms and conditions for interconnection, competitive safeguards to protect against anticompetitive and discriminatory practices, and an effective regulatory framework (including fair and transparent regulatory procedures and separation between the  {O<-regulator and operator). Id., 11 FCC Rcd at 3925, 3929.(# The Commission stated that it would only apply this examination to applications from foreign carriers that  Sv-have market power, or are affiliated with such carriers, in the destination markets they seek to serve.^vh y {O~-#X\  P6G;P#эXxId., 11 FCC Rcd at 3912. We defined affiliation to include an ownership interest of greater than 25  {OH-percent, or a controlling interest at any level, in a U.S. carrier by a foreign carrier. Id., 11 FCC Rcd at  {O-39003906, codified at 47 C.F.R.  63.01(r)(1)(i).(#ơ  SN -The Foreign Carrier Entry Order defines market power as "the ability of the carrier to act anticompetitively against unaffiliated U.S. carriers through the control of bottleneck services or  S -facilities on the foreign end."n\ y {O.-#X\  P6G;P#эXxForeign Carrier Entry Order, 11 FCC Rcd at 3917. Bottleneck services or facilities are "those that are necessary for the provision of international services, including intercity or local access facilities on the  {O-foreign end." Id.(#n The Commission stated there was no need to apply an effective competitive opportunities analysis when a foreign carrier seeks to serve countries where it does not own or control bottleneck facilities that give it a dominant market position and the ability to  S -discriminate against unaffiliated U.S. carriers.i y {O-#X\  P6G;P#эXxId.(#i  S8-x 13.` ` International Private Line and Switched Resale Applications. In its applications, Teleglobe USA certified that it is affiliated with TGC and TGUK, and that all three carriers are  S-whollyowned subsidiaries of TGI.Dy {O#-#X\  P6G;P#эXxSwitched Resale Application at 67.(#Ɖ TGC is the monopoly provider of Canadaoverseas traffic. However, TGC does not provide transborder services between the United States and Canada. TGUK is licensed to provide international simple resale (ISR) services from the United Kingdom to authorized points, including the United States, Sweden, Australia and Canada. Teleglobe USA has stated that TGUK is one of numerous ISR licensees in the United Kingdom, and neither owns nor"J0*((r"  S-controls international telecommunications facilities in the United Kingdom,y {Oh-#X\  P6G;P#эXxU.K. Application at 6; Sweden Application at 7.(#ƛ which AT&T and MCI do not dispute.  S-x 14.` ` We conclude that an effective competitive opportunities analysis is not required for either application. Although TGC is the monopoly provider of Canadaoverseas telecommunications  S8-facilities in Canada, the relevant market for our analysis of Teleglobe's Switched Resale Application is  S-the one for services and facilities on the U.S./Canada route.Zy yO -#X\  P6G;P#эXxWhile Teleglobe USA seeks to offer resold switched services to Canada, it does not request authority in the instant applications to resell IPLs to Canada.(# As TGC does not provide services, or own or control any facilities on this route, Teleglobe USA's affiliate lacks the ability to act anticompetitively against unaffiliated U.S. carriers competing for traffic on this route. Accordingly, we conclude Teleglobe USA does not possess market power in the relevant market under our analysis. Further, because TGUK does not control bottleneck facilities or services in the United Kingdom, Teleglobe USA's affiliate does not possess market power in the United Kingdom as well.  S -x15.` ` The effective competitive opportunities analysis is one component of our public interest mandate under Section 214 of the Act. Additional public interest considerations include: the general significance of the proposed entry to the promotion of competition in the U.S. communications market; any national security, law enforcement, foreign policy, or trade concerns raised by the  SZ-Executive Branch; and the presence of cost-based accounting rates.Zy {O-#X\  P6G;P#эXxForeign Carrier Entry Order, 11 FCC Rcd at 3892.(#Ɩ We conclude that the public interest argues in favor of granting Teleglobe USA's switched resale and IPL applications. New resale entrants will improve competition in the U.S. international services market by providing additional choice for consumers leading to heightened price and service competition. AT&T and MCI's concerns about TGC's Canadaoverseas monopoly and the Canadian foreign ownership restrictions on facilities are not directly relevant in our consideration of these resale applications. We reiterate that TGC does not own or control facilities or provide service on the U.S.Canada route. Moreover, as Canada places no foreign ownership restrictions on resellers, AT&T and MCI's arguments on this point are not  S-relevant to the concerns expressed by the Commission in the Foreign Carrier Entry Order.  S-16.` ` Although we generally share AT&T's and MCI's concerns about Canada's maximum use policy, we also do not find this policy a bar to granting these resale applications. As we noted in  S|-fONOROLA,|Dy {O` -#X\  P6G;P#эXxfONOROLA, 9 FCC Rcd at 4070.(#Ƃ Canada's regulatory policy requires that all Canadian traffic, including intraCanadian as well as Canadaoverseas traffic, be routed to the maximum extent possible over Canadian facilities. However, the fact that all Canadian carriers route their Canadaoverseas traffic via TGC's facilities results directly from TGC's monopoly, not from Canada's maximum use policy. Moreover, we have previously declined to use as a basis for denying a Section 214 resale authorization to any Canadianbased carrier the fact that Canadian carriers must use Canadian facilities to the maximum extent"0*(("  S-possible for intraCanada traffic.Gy {Oh-#X\  P6G;P#эXxSee, e.g., fONOROLA (granting authority to fONOROLA, a Canadianbased carrier, to resell, inter alia, international private lines between the United States and Canada for the provision of switched services).(#G We see no reason now to deviate from this position.  S-17.` ` Our main concern in this proceeding is the potential ability of Teleglobe USA to act anticompetitively and leverage any market power it might have in Canada to the detriment of unaffiliated U.S. carriers. We do not believe that our decision to grant Teleglobe USA's applications here will result in such anticompetitive behavior. However, we emphasize that our decision should not be interpreted as condoning the TGC exclusive mandate or the maximum use policy. We share the concerns of AT&T and MCI that these policies could hinder the competitive status of U.S.based  S-carriers in other contexts."y {O -#X\  P6G;P#эXxSee generally Optel Communications Corporation, Order on Reconsideration, 11 FCC Rcd 1878 (1995) (expressing concern about the TGC exclusive mandate and the maximum use policy, but concluding that these concerns were more properly addressed in the context of individual carrier's Section 214  {O -applications); fONOROLA, 9 FCC Rcd at 4071 (describing routing inefficiencies that could result from the TGC exclusive mandate and the maximum use policy; imposing a general condition that resold private lines between the United States and Canada carry U.S.Canada traffic only).(#ƻ We will continue to monitor Canada's pending review of the TGC exclusive mandate and the maximum use policy, as well as the foreign ownership limitations. Further, we will consider these issues, where appropriate, in the context of our Section 214 review of other  SH -Teleglobe USA applications.SXH y yO-#X\  P6G;P#эXxWe note that the Commission has received Teleglobe USA's application to acquire and operate facilities for the provision of international services between the United States and international points, exclusive of Canada (File No. ITC96020).(#S  S -18.` ` In addition, as a specific condition of Teleglobe USA's switched resale authorization (which includes service to Canada), we will require that Teleglobe USA file with the Commission all agreements between Teleglobe USA and TGC (including oral agreements) related to routing U.S. traffic through TGC's facilities, and that Teleglobe USA take TGC services at published rates. In  SX-general, these agreements will be available for public inspection.X y {O-#X\  P6G;P#эXxCf. Rules for the Filing of International Circuit Status Reports, Report and Order, 10 FCC Rcd 8605, 8607 (1995) (concluding that annual circuit status reports should not be held confidential in order, among other things, to allow the public to review circuit additions made by carriers, but specifically noting that carriers are free to file properly supported requests for confidentiality under the Freedom of Information Act).(# Due to TGC's exclusive mandate, any carrier handling Canadaoverseas traffic must use TGC's facilities. Thus, the possibility exists that TGC may engage in discriminatory treatment to the benefit of its affiliate, Teleglobe USA, and to the detriment of other carriers, including U.S.based carriers, in the routing of U.S. traffic to overseas points via Canada. Our objective in conditioning switched resale authorization on the filing of routing agreements between TGC and Teleglobe USA, and on taking at published rates, is to ensure that such discriminatory treatment does not occur.  S-x19.` ` Regarding the other public interest factors, the Executive Branch has not brought any"p0*((5"  S-concerns about Teleglobe USA's applications to the Commission's attention.|y yOh- v #X\  P6G;P#эXWe note, however, that the Office of the United States Trade Representative (USTR) has informed us that  v \Teleglobe USA's licenses would be subject to Section 301(c)(2) of the Trade Act of 1974, as amended, 19  v U.S.C.  2411(c)(2), which gives the USTR authority to restrict or deny any services sector authorizations,  {O- v should the USTR determine that such action is warranted.  Letter to Scott Blake Harris, Chief, International  {O- v MBureau, from Ira S. Shapiro, Senior Counsel and Negotiator, USTR, dated May 9, 1996. This letter was  v issued in the context of the USTR's review of Country Music Television's efforts to regain access to the Canadian market from the Government of Canada.(#Ɨ Further, carriers in Canada and the United Kingdom have been cooperating in bringing already low accounting rates with the United States down towards the cost of providing service. Therefore, because it will serve the public interest, the Bureau grants Teleglobe USA's applications for noninterconnected IPL and switched resale services.  S-20.` ` UK and Sweden Applications. In the Foreign Carrier Entry Order, the Commission restated the equivalency test for applications for switched service over resold private lines in terms of  S-the effective competitive opportunities test. y {On-#X\  P6G;P#эXForeign Carrier Entry Order, 11 FCC Rcd at 3925.(#Ɩ The Commission required that such applications include a demonstration that the foreign country at the other end of the private line provided U.S. carriers with: (1) the legal right to resell international private lines, interconnected at both ends, for the  SJ -provision of switched services; (2) nondiscriminatory charges, terms and conditions for interconnection to foreign domestic carrier facilities for termination and origination of international services, with adequate means of enforcement; (3) competitive safeguards to protect against anticompetitive and discriminatory practices affecting private line resale; and (4) fair and transparent regulatory procedures,  S -including separation between the regulator and operator of international facilitiesbased services. y {O-#X\  P6G;P#эXId.; see also 47 C.F.R.  63.01(k)(5)(ii) (codifying these factors).(#Ƴ  S -Notably, the Commission declared that this restatement of the equivalency standard did not represent a substantive change, and that a finding of "equivalent resale opportunities" was a finding of "effective  S2-competitive opportunities" to resell international private lines for the provision of switched services.!Z20 y {O- v #X\  P6G;P#эXForeign Carrier Entry Order, 11 FCC Rcd at 392526; see also 47 C.F.R.  63.01(k)(5)(i) (permitting  v applicants to state whether the Commission has previously determined that equivalent resale opportunities exist in lieu of a demonstration that the four restated equivalency criteria have been satisfied).(#  S-21.` ` As Teleglobe USA notes in its applications,"R y {O-#X\  P6G;P#эXUK Application at 4; Sweden Application at 1.(#ƙ the Commission has previously determined that equivalent resale opportunities exist between the United States and the United  S-Kingdom,#y {O#- v #X\  P6G;P#эXACC Global Corporation/Alanna Inc., Memorandum Opinion,Order and Certificate, 9 FCC Rcd 6240 (1994).(# and between the United States and Sweden.$>y {Op%-#X\  P6G;P#эXCable & Wireless Inc., et. al., Memorandum Opinion, Order, and Certification, 11 FCC Rcd 1766 (1996).(# Furthermore, for the same reasons identified  Sj-supra, we find that the public interest supports grant of these applications. Therefore, we also grant Teleglobe USA's request to resell interconnected private lines for the provision of switched services"D$0*((r" between the United States and the United Kingdom, and between the United States and Sweden.  S-  S-22.` ` Request for Nondominant Carrier Regulation. Teleglobe USA requests that it be classified as nondominant on all routes on which it seeks to resell switched and noninterconnected  Sb-IPLs.%by {O-#X\  P6G;P#эXSwitched Resale Application at 34; IPL Application at 4.(#ƥ Section 63.10(a)(1) of the Commission's Rules{&bZy yO\-#X\  P6G;P#эX47 C.F.R.  63.10(a)(1).(#{ states that U.S. carriers unaffiliated with carriers in the destination country shall be presumptively nondominant. Section 63.10(a)(3) of the  S-Rules{'y yO -#X\  P6G;P#эX47 C.F.R  63.10(a)(3).(#{ provides that a U.S. carriers affiliated with foreign carrier that is not a monopoly in the destination country and that seeks to be regulated as nondominant has the burden of showing that the foreign affiliate lacks the ability to discriminate via control of bottleneck services or facilities.  S-Finally, Section 63.10(a)(4) of the Rules{(zy yO-#X\  P6G;P#эX47 C.F.R.  63.10(a)(4).(#{ states that carriers serving a destination route solely through the resale of switched services of unaffiliated U.S international carriers will be deemed presumptively nondominant.  S -23.` ` Teleglobe USA seeks to resell IPLs to 68 countries in which it does not have an affiliate and to one country (the United Kingdom) where its affiliate does not have the ability to discriminate through control of bottleneck facilities and services. We see nothing in the record to rebut the presumption of nondominance for noninterconnected IPL as well as for switched resale.  SZ-Therefore, under Sections 63.10(a)(1), 63.10(a)(3), and 63.10(a)(4) of the Rules, we grant nondominant status to Teleglobe USA with respect to these services.  S-x24.` ` Teleglobe USA also seeks nondominant status in its applications to resell  S-interconnected IPLs for the provision of switched services to the United Kingdom and to Sweden.) y {Od-#X\  P6G;P#эXU.K. Application at 6; Sweden Application at 3.(#ƛ As Teleglobe USA is unaffiliated with a carrier in Sweden, and because its affiliate in the United Kingdom lacks the ability to discriminate via control of bottleneck services and facilities, the presumption of nondominance applies under Sections 63.10(a)(1) and 63.10(a)(3), respectively, of the Rules. Again, there is nothing in the record to rebut the presumption of nondominance in either instance. Therefore, we also grant nondominant status with respect to Teleglobe USA's application  S-for interconnected IPL resale to the United Kingdom and to Sweden.* y yO!- v #X\  P6G;P#эXWe note that in its applications Teleglobe USA has also proposed the number of circuits it seeks to acquire  v [on each of its private line routes, both interconnected and noninterconnected. In light of its nondominant  v status, Teleglobe USA will be permitted to acquire additional capacity on these routes without prior Commission approval.(#  Sz-${ IV. Conclusion ĐTP  S*-x25.` ` We conclude the public interest supports granting Teleglobe USA authority to resell switched services of unaffiliated U.S. international carriers, and to resell noninterconnected IPL" *0*((k"  S-service to those countries listed in Appendix A to this Order. We also grant Teleglobe USA authority to resell interconnected IPLs between the United States and the United Kingdom, and between the United States and Sweden, for the provision of switched services.  Sb- V. Ordering Clauses T  S-TPx26.` ` Accordingly, it is CERTIFIED that the present and future public convenience and necessity require grant of these applications, and it is hereby ORDERED that application File Nos. ITC95466, ITC95467, ITC95468, and ITC96074 are GRANTED. Teleglobe USA Inc. is authorized to resell the services of unaffiliated U.S. international carriers to provide: (1) private lines not interconnected into the public switched network to the destinations set forth in Appendix A to this  SJ -Order; (2) international switched services to destinations set forth in the tariffs of its underlying carriers, subject to the conditions expressed below; (3) international private lines for the provision of switched services between the United States and the United Kingdom; and (4) international private lines for the provision of switched services between the United States and Sweden.  S -x27.` ` It is FURTHER ORDERED that Teleglobe USA Inc.'s authorization to provide switched resale services is subject to the following conditions: (a) Teleglobe USA must file with the Commission all agreements between it and Teleglobe Canada Inc., including all oral agreements, related to routing U.S. traffic through Teleglobe Canada's facilities; and (b) Teleglobe USA must take Teleglobe Canada's services at published rates.  S-x28.` ` It is FURTHER ORDERED that Teleglobe USA Inc.'s authorization to resell noninterconnected international private line service is limited to the provision of such service only to the  SD-destination countries listed in Appendix A to this Order, that is, private lines that originate in the United States and terminate in one of the listed destination countries. In addition, Teleglobe USA may not and Teleglobe USA's tariffs must state that its customers may not connect private lines provided over these facilities to the public switched network at either the U.S. or foreign end or both, for the provision of international switched basic services, unless authorized to do so by the Commission upon a finding that the foreign administration affords resale opportunities equivalent to  SV-those available under U.S. law, in accordance with the Foreign Carrier Entry Order, 11 FCC Rcd 3873, 39243925 (1995).  S-x29.` ` It is FURTHER ORDERED that Teleglobe USA Inc.'s authorization to resell international private lines for the provision of switched services between the United States and the United Kingdom, and between the United States and Sweden, is limited to the provision of such services between these countries only, that is, private lines which carry traffic that originates in the United States and terminates in the United Kingdom or viceversa, or traffic that originates in the United States and terminates in Sweden or viceversa. This restriction is subject to the following exceptions: (a) Teleglobe USA may engage in "switched hubbing" through the United Kingdom and  S!-through Sweden consistent with the rules adopted in Foreign Carrier Entry Order, 11 FCC Rcd at 39383939; and (b) Teleglobe USA may provide U.S.inbound or outbound switched basic service by connecting its authorized private lines between the United States, Sweden, and the United Kingdom.  S*%-x30.` ` It is FURTHER ORDERED that the Petitions to Deny filed by AT&T Corporation and MCI Telecommunications Corporation are DENIED. "& *0*((n("Ԍ S-x31.` ` It is FURTHER ORDERED that Teleglobe USA Inc. shall comply with Sections 63.21 and 63.15(b) of the Commission's Rules.  S-x32.` ` This Order is issued under Section 0.261 of the Commission's Rules and is effective upon adoption. Petitions for reconsideration under Section 1.106 of the Rules, or applications for  S:-review under Section 1.115 of the Rules, may be filed within 30 days of the public notice of this  S-Order (see Section 1.4(b)(2) of the Rules). x` `  hhFEDERAL COMMUNICATIONS COMMISSION  SL - x` `  hhDonald H. Gips x` `  hhActing Chief, International Bureau " *0*((/ "  S-, APPENDIX A T  S-  Noninterconnected Private Line DestinationsTP  S`-  S-(#҇Argentina   S-Australia` `  S-Austria   S-Bahamas` ` Bangladesh  SH -Belarus   S -Belgium  Bermuda  S -Boliviax  S -Brazil   S -Bulgaria   SX-Chile   S0-China  Colombia  S-Costa Rica` ` Czech Republic Denmark Dominican Republic  S@-Ecuador   S-Egypt   S-El Salvador` `  S-Finland   S-Francex  Sx-Germany` `  SP-Greece ` `  S(-Haiti ` `  S-Honduras` ` Hong Kong  S-Hungary   S-India   S`-Indonesia   S8-Ireland   S -Israel  Italy  S!-Jamaica   S"-Japan   Sp#-Lithuania  Luxembourg  S %-Malaysia   S%-Mexico   S&-Monaco` ` "& *0*((n("Ԍ S-Netherlands  New Zealand  S-Nicaragua  S-Norway     Sp-Pakistan     SH -Panama  S -Paraguay  S -Peru     S -Philippines     S -Poland     S -Portugal     SX-Romania    Russia Saudi Arabia  S-Singapore     S-South Africa    South Korea  Sh-Spain     S@-Sweden Switzerland  S-Taiwan     S-Thailand     S-Turkey     Sx-Ukraine   xx  SP-United Kingdom    S(-Uruguay Venezuela  S-Vietnam