-----Original Message-----
From: Joe Stewart [mailto:jstewart@ifoneinc.com]
Sent: Friday, July 16, 2004 9:14 AM
To: grichena@telcordia.com; Walker, Anne; cath.hsu@fcc.gov
Subject: Re: Request for HNI

Garry,

To summarize our case: IFONE has a unique situation that requires special consideration. On one hand we are contracted to provide a private network to the US Military in deployed areas worldwide, the first such area being Afghanistan. On the other hand that network must be interconnected to the worldwide PSTN through a roaming agreement T-mobile, which makes us a public network. As a later phase, IFONE plans interconnect agreements with other carriers (SBC for example).

IFONE was awarded a contract by the United States Army to provide a private GSM network on US Army bases in Afghanistan. Unlike commercial networks, our network is interconnected to the Department of Defense DSN (defense switched network). This allows our armed forces to use our GSM network as a last mile to access their worldwide DSN network. The DSN is a network that connects all of our military installations would-wide is operated by the Department of Defense. IFONE's GSM infrastructure is been successfully assessed for interoperability on the DSN by the JITC (Joint Interoperability Test Command) and contains certain features that allow it to support a special NSA approved level of encryption that allows our users to discuss classified information over our network. Our virtual private network also offers network security for our users.

IFONE needs the HNI assignment that comprises the IMSI number for 2 reasons:

1. In order establish a roaming agreement with T-mobile and to interconnect our MSC (mobile switching center) to one of T-Mobile's POPs over an SS7 link.

2. In order for our network to operate properly. The network is now operational and when our users turn on their phones, the phone will not affiliate with our network because our network has no IMSI number. We are running the network only on 125 test SIMS with 0s in place of the IMSI number. We are unable to manufacture further SIMS without the IMSI number.

IFONE believes that only the US can issue it the HNI code that will comprise IFONE's IMSI number for the following reasons:

1. Our operating authority emanates from the US Military through out contract as opposed to a "license" from the host country.

2. Our frequencies are assigned by the US Military.

3. IFONE has no agreement with the host country (in this case Afghanistan). Therefore, IFONE has no basis to request an HNI code from Afghanistan nor any other country into which we will extend this network.

4. All of IFONE's operations are on US Government installations oversees.

We at IFONE appreciate Telecordia's efforts on our behalf and very much look forward to you finding a way to assign us an HNI code.

Very truly yours,

Joseph S. Stewart III

CEO

IFONE, Inc.

Cell 305-606-4744