4. WRITTEN SUBMISSIONS WRITEN SUBMISSIONS FROM ETKL 4.1. On 22nd December 2009, ETKL made written submissions to the Commission in support of their allegation that the E1 link had been used fraudulently between 1st and 4th November 2009. The submission included data from AREDU, the ETKL designated roaming partner in Dubai. The submission indicated that roaming call records had been created although ETKL had not yet unlocked their out-roaming services to their subscribers, which they considered a fraudulent activity attributable to the E1 link allocated to ACL. ETKL indicated that they resolved the problem by disconnecting the E1 link on 4th November 2009 and no further call records were created after the disconnection. ETKL also indicated in the submission that their roaming partner had established records and generated charges amounting to Ksh.753,844.66 payable to AREDU, which it attributed to fraudulent activity. 4.2. On 28th December 2009, ETKL made further written submissions to the Commission indicating that ETKL lines identified as having made calls on the AREDU network in Dubai were locked into the ETKL network in Kenya and were barred from roaming. In addition, ETKL indicated that since the alleged numbers were seen in the local Visitor Location Register (VLR), the only way the roaming calls could have been made was through by-passing the ETKL systems. In addition, ETKL requested the Commission to clarify whether agreements for provision of E1 links where a mobile service provider offers a link (access) to an ISP to route traffic are classified as interconnection agreements. 4.3. On 6th January 2010, ETKL submitted additional documents to the Commission which included copies of their roaming agreement and a GSM invoice for roaming traffic from AREDU. WRITTEN SUBMISSIONS FROM ACL Page 4 of 11