December 19, 2019 VIA ELECTRONIC FILING Ms. Marlene

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December 19, 2019 VIA ELECTRONIC FILING Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Application for Cable Landing License for the Hong Kong-Guam Cable System, File No. SCL-LIC-20191122-00037 Dear Ms. Dortch: Through their counsel, RTI Solutions, Inc. (“RTI Solutions”), RTI HK-G Pte. Ltd. (“RTI HK-G”), and RTI Connectivity Pte. Ltd. (“RTI Connectivity”) (collectively, “RTI Applicants” or “RTI Group”) supplement the above-referenced application for the Hong Kong-Guam (“HK-G”) system that will connect Hong Kong and Guam (the “Application”). This supplement clarifies the information presented in the Application, as follows: First, the RTI Applicants update Appendix A to confirm that RTI Solutions is a California corporation with a principal place of business in California. Second, the RTI Applicants update Appendix B to clarify that RTI HK-G has a 100- percent ownership interest in Fiber Pairs 2 through 4 (rather than Segments). Third, the RTI Applicants update Appendix B to confirm the name of the Trustee for the RTI HK-G Share Trust: Ocorian Singapore Trust Company Pte Ltd. The Trustee’s role is reflected on the enclosed, updated Attachment 1 to Appendix B. Should you have any questions regarding the information provided above, please contact Kent Bressie by telephone at +1 202 730 1337 or by e-mail at [email protected]. Yours sincerely, Kent Bressie Colleen Sechrest Counsel for RTI Solutions, Inc., RTI HK-G Pte. Ltd., and RTI Connectivity Pte. Ltd. Attachment cc: David Krech Jodi Cooper Attachment 1 RTI HK-G Pte. Ltd. Ownership Structure Inflexion Supplemental Fund Inflexion Buyout Fund IV (No. 1) LP IV (No. 1) LP No other 5% or greater interest holders in (Guernsey) (Guernsey) RTI HK-G Pte. Ltd. 16% voting and economic interest 29% voting and economic interest Ocorian Limited (Bailiwick of Jersey) 100% voting and economic interest STC Group Ltd. (British Virgin Islands) 100% voting and economic interest Russell Alan Matulich Trustee: Ocorian Singapore Trust Company Pte Ltd (United States) (Singapore) 99% voting and 100% voting economic interest Japan Ministry of Finance RTI HK‐G Share Trust RTI Connectivity Pte. Ltd. (Japan) (Singapore) (Singapore) 50% voting and economic interest Control exercised by RTI 100% voting Connectivity Pte. Ltd. through interest Asset Management Agreement Fund Corporation for the Overseas Development of Japan’s ICT and Postal Services, Inc. NEC Corporation Russell Alan Matulich (Japan) (Japan) (United States) 45% economic 50% economic 2.7% economic interest interest interest RTI HK‐G Pte. Ltd. (Singapore) Asset Management Agreement.

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