10.1 That the licensee shall ensure that records of any transfer of monies between any part of the licensee's business and of the business mentioned in paragraph 11 (provision of information) are maintained. 10.2 The Commission may at its discretion request the licensee to submit other information related to the licensed business to satisfy the Commission that no cross-subsidy is taking place". ADSL and dialup are Internet access infrastructure comparable to digital leased lines. Based on an analysis of the submissions given by ISPs and TKL, it is the view of the Commission that the 'bundling' of Internet access services through 944 dialup and ADSL services has resulted in cross-subsidization between the provision of the local loop infrastructure and the provision of Internet access to end-users and has therefore distorted the Internet services market segment. Status of Jambo Telkom licence It is noted that JTL, has not operationalized its ISP licence nor paid the annual licence fees. Additionally JTL requested for an extension of ISP service commencement date to Ist July 2003. The Commission in a letter dated 10th March 2003, granted the extension up to 18th July 2003, however there has been no response from JTL since. The Commission requires that JTL remedy the following contraventions on the ISP licence to enable provision of Internet access services to end-users: 1. 2. Failure to commence of service provision within the stipulated time-frame Non-payment of outstanding annual operating fees The Commission further notes that in a letter dated 27th May 2004; the Commission notified TKL of the contraventions on the licences and required that TKL remedy the infringements in thirty (30) days. A response to this notice was communicated at meetings held between the Commission and TKL and a written response dated 19th July 2004 was received by the Commission on 20th July 2004. The response stated that TK L's position regards the provision of Internet access services to end-user utilizing ADSL and 944 dial up as being provided under the VAS licence. Provision of Internet access to end-users should be through an ISP, JTL is yet to comply with the provisions of the licence including the requirement to start operations in twelve (12) months from the effective date of the licence and hence the licence is due for termination unless the company pays its dues to the Commission and commences operations. Ruling on ADSL and 944 national dialup The Commission views the provision of Internet services directly to end-users to be separately licensable and distinct from Value Added Services.