EXTRANCHECK: PRE-LICENSE CHECK: BHARTI AIRTEL

UNCLAS NEW DELHI 004149

SIPDIS

SIPDIS

USDOC FOR 532/OEA/M. NICKSON-D/JAY HATFIELD
USDOC FOR 3131/USFCS/OIO/ANESA/KREISSL
USDOC FOR 4530/MAC/ANESA/OSA
ICE HQ FOR STRATEGIC INVESTIGATIONS
STATE FOR EB/ESP

E.O. 12958: N/A
TAGS: ETTC ETRD BEXP IN
SUBJECT: EXTRANCHECK: PRE-LICENSE CHECK: BHARTI AIRTEL
LTD., NEW DELHI, LICENSE NO. D380688

REF: USDOC 07247


1. Unauthorized disclosure of the information provided
below is prohibited by Section 12(c) of the Export
Administration Act.


2. Export Control Officer (ECO) Paul Cushman and BIS FSN
Prem Narayan conducted a Pre-license Check (PLC) at Bharti
Airtel Ltd. (BAL),New Delhi, on August 13, 2007.


3. BIS requested a PLC at BAL, a private sector company
located at 234 Okhla Industrial Estate III, New Delhi
110020, Tel: 91-11-4161-5050, Fax: 91-11-4171-1050, Email:
jp.singh@bharti.com, website: www.airtelworld.com. BAL was
listed as the ultimate consignee for one Time Cesium 4400
clock controlled under ECCN 3A002. The license applicant
was Symmetricom, Inc. (Symmetricom),San Jose, CA.


3. ECO and FSN Narayan met with J.P. Singh (Singh),
Purchase Head, BAL.


4. Singh explained that BAL had previously purchased a DCD
Cesium Clock from Symmetricom which was installed at its
Chennai facility. The cesium tube in the unit
malfunctioned twice. On both occasions, the cesium unit
was sent to Symmetricom for repair. The cesium tube
malfunctioned a third time and was again sent to
Symmetricom. On this occasion, it was determined the
device could not be repaired. Singh stated that the cesium
tubes are generally considered rugged and come with a 10-
year warranty. As the cesium clock was still under
warranty, Symmetricom agreed to replace it. However, they
no longer manufacture this particular cesium clock. So,
BAL agreed to accept Symmetricom?s newest model and cover
the difference in cost between the original and the
replacement.


5. To support the proposed transaction, BAL provided copies
of correspondence between BAL and Symmetricom, BAL purchase
order for the cost difference, BAL End User Statement, and
Form BXA-711. The documentation supplied to BIS indicated
the part and serial number of the older cesium clock as
9904310004 and 53536 respectively. Singh stated that
Symmetricom would destroy the original clock.


6. Singh stated that the cesium clock would be used to
synchronize all of BAL?s telecom networking equipment.
BAL?s brand name is Airtel which is the largest cellular
network in India. The clock will generate the accurate
reference signal for distribution to the network. He
stated that using a reference clock with a high degree of
accuracy minimizes the jitter and increases the efficiency
of a telecom network. Currently, the BAL Chennai facility
is piggybacking on the cesium clock operating at its Mumbai
facility.


7. All BAL purchases are processed through the BAL Delhi
office. Singh stated that the equipment will be shipped to
the BAL Delhi office and then forwarded to its Chennai
facility.


8. BAL, established in 2001, is an associate company of
Bharti Enterprises, a leading telecom services provider in
India. BAL is the only operator to provide mobile services
in all 23 geographic circles in India with an aggregate of
14.42 million clients. BAL also provides fixed-line
telephone services and Internet access over DSL in 14 out
of 23 circles. BAL complements its mobile, broadband and
telephone services with national and international long
distance services. BAL also has a submarine cable landing
station at Chennai, which connects to Singapore. BAL
provides end-to-end data and enterprise services to
corporate clients by leveraging its nation-wide fiber optic
backbone, last mile connectivity in fixed-line and mobile
circles, VSATs, ISP and international bandwidth access
through gateways and landing stations. BAL?s clients
include the Indian public, GOI agencies, as well as public
and private sector companies. The BAL Chennai facility
employs approximately 1,000 personnel.


9. Recommendation: All indications are that the listed
commodity will used in accordance with the terms of the
export license and that Bharti Airtel Ltd. appears to be a
reliable recipient of the Symmetricom sensitive U.S.-origin
technology for this transaction.


MULFORD