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Comment Sought on Domestic 214 Transfer of RightLink USA to Min-su Kang

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Released: November 30, 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 12-1931

Released: November 30, 2012




WC Docket No. 12-258

Comments Due: December 14, 2012
Reply Comments Due: December 21, 2012

On September 14, 2012, Michael Ukwendu and Min-Su Kang (together, Applicants) filed an
amended application pursuant to section 63.03 of the Commission's rules1 requesting approval for
approval to transfer control of RightLink USA, Inc. (RightLink) from Michael Ukwendu to Min-Su Kang
(the Transaction). In the spring of 2012, Applicants consummated the transfer of control without prior
authorization from the Commission.2
RightLink, a Florida corporation, holds blanket domestic Section 214 authority to provide
telecommunications services. RightLink is currently authorized to provide competitive local exchange
service in Florida to residential and business customers. Prior to consummation of the transaction,
RightLink was wholly owned by Michael Ukwendu.
Min-Su Kang, a U.S. citizen, holds investments in telecommunications and debt resolution. Mr.
Kang wholly owns Capital Communications Consultants, Inc., a provider of competitive local exchange
and interexchange services in Alabama, Georgia, Kentucky, Louisiana and South Carolina. CapCom also
holds authority to provide these same services in North Carolina, but does not yet provide services in that
state. Mr. Kan recently received authority to acquire ownership of Four Star Marketing, LLC d/b/a Mid-
South Home Phone (Mid-South), which provides competitive local exchange and interexchange services
in Mississippi and Tennessee.3 Mid-South also holds authorizations in Kentucky and Louisiana, but does
not yet provide services in those states.

1 47 C.F.R 63.03; see 47 U.S.C. 214.
2 Applicants also filed a request for special temporary authority (STA) with the Wireline Competition Bureau to
allow RightLink to continue to provide service to customers while its section 214 application is pending. On
November 6, 2012, the Wireline Competition Bureau granted the STA for the domestic authorization for a period of
60 days. On November 16, 2012, Applicants filed an amended application. A grant of the application will be
without prejudice to any enforcement action by the Commission for non-compliance with the Communications Act
of 1934, as amended, or the Commission's rules.
3 Notice of Domestic Section 214 Granted, WC Docket No. 12-300, Public Notice, DA 12-1897 (WCB 2012).

Pursuant to the terms of a stock purchase agreement, Min-Su Kang purchased all of the equity
interests of RightLink. Although the transaction resulted in a change in the control of RightLink, no
assignment of authorizations, assets, or customers will occur as a consequence of the proposed
transaction. Applicants state that the proposed transaction is entitled to presumptive streamlined
treatment under section 63.03(b)(2)(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 RightLink USA,
Inc. to Min-Su Kang, WC Docket No. 12-258 (filed Sept. 6, 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 December 14, 2012, and reply comments on
or before December 21, 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) Tracey Wilson, 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).
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

4 47 C.F.R. 63.03(b)(2)(i).
5 Such authorization is conditioned upon receipt of any other necessary approvals from the Commission in
connection with the proposed transaction.
6 47 C.F.R. 1.1200 et seq.

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 Tracey Wilson at
(202) 418-1394.

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