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Comment Sought on Domestic 214 Transfer of Four Star Marketing, LLC

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Released: October 25, 2012


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 12-1723

Released: October 25, 2012





WC Docket No. 12-300

Comments Due: November 8, 2012
Reply Comments Due: November 15, 2012

On October 05, 2012, Pittco Capital Partners IV, LP (Pittco), Ben Bryant, Ronald Brent Ragin,
and Kennith White, MSK Communications, LLC (MSK), and Four Star Marketing, LLC d/b/a Mid-South
Home Phone (Four Star) (collectively, the Applicants) filed an application pursuant to section 63.03 of
the Commission’s rules1 requesting approval for the transfer of control of Four Star to MSK.
Four Star, a Tennessee limited liability company, provides competitive local exchange services
and interexchange services in Mississippi and Tennessee. Four Star also holds authorizations in
Kentucky and Louisianan, but does not provide services in those states. Applicants state that Four Star
does not have any affiliates that provide telecommunications services. Pittco, Ben Bryant, Ronald Brent
Ragin, and Kennith White, are investors that hold a collective 82.28 percent in ownership interests of
Four Star. The remaining owners are individuals who each hold less than a ten percent interest in Four
MSK, a Tennessee limited liability company, is wholly owned by Mr. Min-su Kang. MSK was
created for the purpose of holding the interest of Four Star. Mr. Kang, a U.S. citizen, has investments in
telecommunications and debt resolution businesses. Mr. Kang controls RightLink USA, Inc. (RightLink),
a competitive local exchange carrier providing local and long distance services in Florida.2 Mr. Kang also
applied for authority to acquire a one hundred percent interest in called Capital Communications

1 47 C.F.R § 63.03; see 47 U.S.C. § 214. Any action on this domestic 214 application is without prejudice to
Commission action on other related applications.
2 Mr. Kang controls RightLink as a result of an unauthorized transfer of control that consummated in the spring of
2012. Applicants state that RightLink will file a request for Special Temporary Authority and will refile an
amended application for the transfer of control of RightLink. See Application for the Transfer of Control of
RightLink USA, Inc., WC Docket 12-258 (filed Sept. 12, 2012).

Consultants, Inc. (CapCom).3 CapCom provides local exchange and interexchange services in Alabama,
Georgia, Kentucky, Louisiana, and South Carolina; it holds local and interexchange authority in North
Carolina but does not yet provide services in that state.
Applicants seek to transfer all of the ownership interest in Four Star to MSK. Accordingly, upon
consummation of the proposed transaction, Mr. Kang will indirectly hold all of the interest in Four Star.
Upon closing of the transaction, Applicants state that the proposed transaction is entitled to presumptive
streamlined treatment under section 63.03(b)(1)(i) of the Commission’s rules4 and that a grant of the
application will serve the public interest, convenience, and necessity.
Domestic Section 214 Application Filed for the Transfer of Control of Four Star
Marketing, LLC d/b/a Mid-South Home Phone to MSK Communications, LLC, WC
Docket No. 12-300 (filed Oct. 05, 2012).


The transfer of control identified herein has been found, upon initial review, to be acceptable for
filing as a streamlined application. The Commission reserves the right to return any transfer application
if, upon further examination, it is determined to be defective and not in conformance with the
Commission’s rules and policies. Pursuant to section 63.03(a) of the Commission’s rules, 47 CFR §
63.03(a), interested parties may file comments on or before November 8, 2012, and reply comments on
or before November 15, 2012.
Pursuant to section 63.52 of the Commission’s rules, 47 C.F.R. § 63.52,
commenters must serve a copy of comments on the Applicants no later than the above comment filing
date. Unless otherwise notified by the Commission, the Applicants may transfer control on the 31st day
after the date of this notice.5
Pursuant to section 63.03 of the Commission’s rules, 47 CFR § 63.03, parties to this proceeding
should file any documents in this proceeding using the Commission’s Electronic Comment Filing System

In addition, e-mail one copy of each pleading to each of the following

1) Dennis Johnson, Competition Policy Division, Wireline Competition Bureau,;
2) Myrva Charles, Competition Policy Division, Wireline Competition Bureau,;
3) David Krech, Policy Division, International Bureau,; and
4) Jim Bird, Office of General Counsel,
People with Disabilities: To request materials in accessible formats for people with disabilities
(braille, large print, electronic files, audio format), send an e-mail to or call the
Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (tty).

3 Domestic Section 214 Application Filed for the Transfer of Control of Capital Communications Consultants, Inc.,
WC Docket 12-244, Public Notice, DA 12-1425 (rel. Sept. 6, 2012).
4 47 C.F.R. § 63.03(b)(1)(i).
5 Such authorization is conditioned upon receipt of any other necessary approvals from the Commission in
connection with the proposed transaction.

The proceeding in this Notice shall be treated as a “permit-but-disclose” proceeding in
accordance with the Commission’s ex parte rules.6 Persons making ex parte presentations must file a
copy of any written presentation or a memorandum summarizing any oral presentation within two
business days after the presentation (unless a different deadline applicable to the Sunshine period applies).
Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation
must (1) list all persons attending or otherwise participating in the meeting at which the ex parte
presentation was made, and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be
found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission
staff during ex parte meetings are deemed to be written ex parte presentations and must be filed
consistent with rule 1.1206(b), 47 C.F.R. § 1.1206(b). Participants in this proceeding should familiarize
themselves with the Commission’s ex parte rules.
For further information, please contact at Dennis Johnson (202) 418-0809 or Myrva Charles at
(202) 418-1506.

6 47 C.F.R. §§ 1.1200 et seq.

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