Page:2020-06-09 PSI Staff Report - Threats to U.S. Communications Networks.pdf/77

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carriers than it would have otherwise."[1] Team Telecom pointed specifically to CTA's managed service provider services, as well as China Telecom's ability to access CTA's U.S. customer records.[2] Team Telecom also highlighted allegations that China Telecom hijacked data on a number of occasions dating back to 2010.[3]

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The FCC is currently considering Team Telecom's recommendation to revoke and terminate CTA's Section 214 authorizations. The FCC has ordered CTA to respond to Team Telecom's allegations and demonstrate why its Section 214 authorizations should not be revoked.[4] That order is currently pending; CTA is required to submit its response by June 8, 2020.[5]

C. China Unicom and China Unicom (Americas) Operations Limited

China United Network Communications Group Company Limited ("China Unicom") is considered the seventh largest mobile operator in the world based on number of subscribers.[6] According to its most recent 20-F filing with the SEC, China Unicom served approximately 318 million mobile subscribers worldwide as of December 31, 2019 and a reported revenue of nearly $42 billion.[7]

China Unicom's origins date back to 1994, when its predecessor company was founded by the Chinese government to compete with China Mobile, China's incumbent wireless provider.[8] In 2008, among other restructuring efforts, China. Unicom's predecessor company merged with China Network Communications


  1. Executive Branch Recommendation re CTA, supra note 56, at 41.
  2. Executive Branch Recommendation re CTA, supra note 56, at 42-43.
  3. Executive Branch Recommendation re CTA, supra note 56, at 44-50.
  4. See In the Matter of China Telecom (Americas) Corporation, DA 20-448 (Apr. 24, 2020), https://docs.fcc.gov/public/attachments/DA-20-448A1.pdf.
  5. See Letter from Denise Coca, Chief, Telecommc'ns & Analysis Div., Int'l Bureau, Fed. Commc'ns Comm'n to Andrew Lipman, Counsel to CTA, Morgan, Lewis & Bockius LLP (May 14, 2020).
  6. The ranking is based on number of subscribers as of January 2019. See Abayomi Jegede, Top 10 Largest Mobile Networks in the World by Subscribers, The Daily Records (Jan. 1, 2019), http://www.thedailyrecords.com/2018-2019-2020-2021/world-famous-top-10-list/highest-selling-brands-products-companies-reviews/best-largest-mobile-networks-world-by-subscribers-telecom-companies-revenue/12837/.
  7. China Unicom (Hong Kong) Ltd. Annual Report Pursuant to Section 13 or 15(D) of the Sec. Exch. Act of 1934 for the Fiscal Year Ended December 31, 2019 (Form 20-F), Comm. File No. 1-15028, at 2, 27 (filed Apr. 22, 2020), https://www.chinaunicom.com.hk/en/ir/reports/2019_20f.pdf [hereinafter China Unicom FY2019 Form 20-F].
  8. Briefing with China Unicom Americas (Apr. 16, 2020).

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