Glueball you are adding to the confusion or the poor pax above . as far as we have heard Brazil fllows ICAO Comm loss procedure and not the FAA ( or Hong Kong) ones. That is one of the points. ( if indeed that played a role in the collision, we are still speculating here remember )
Something else, just saw that this morning :
http://oglobo.globo.com/pais/mat/200.../286099733.asp
Overworked ATC staff ? another hole in the Reason's cheese .