Letter (May 15, 2009)

0198-EX-ST-2009 Post Grant Documents

Cisco Systems

2009-09-21ELS_101281

SIRIUS XM
        INC.       RADIO
15i;:: Eckington Place. N E
Wasrllngron. D C 20002
i e i 202-380-4000
Fax 2C;-3804500
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m    A sir~:s.com
       d         ,wxmrad~ocom




Via Hand Delivery
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554


         Re:     Cisco Systems
                 Request for Experimental STA
                 File No. 0198-EX-ST-2009

Dear Ms. Dortch:

        Sirius XM Radio Inc. ("Sirius XM") hereby comments on the above-referenced
application of Cisco Systems ("Cisco") requesting an Experimental Special Temporary Authority
("S I'A") to conduct testing in the 2.3 GHz band to test Wi-Max and cellular products in the
vicinity of Cisco campuses at Research Triangle Park, NC; San Jose, CA; Plano, TX; Collin, TX;
and Richfield, OH. Due to the need to prevent potential harmful interference to Sirius XM's
operations, Sirius XM requests that the Office of Engineering and Technology ("OET") require
Cisco to adhere to existing Part 27 limits for these experimental operations.'

        Sirius XM is the licensee of Satellite Digital Audio Radio System ("SDARS") systems in
the 2320-2332.5 MHz and 2332.5-2345 MHz bands that provide a high-quality, continuous,
multi-channel audio service throughout the United States. More than nineteen million customers
currently subscribe to the Sirius XM service.

        Cisco's application proposes to conduct testing in the bands 2310-2320 MHz and 2345-
2360 MHz bands, which are directly adjacent to Sirius XM's Iicensed bands. Sirius XM urges
OE S to require that any equipment operated in the 2.3 GHz band pursuant to this application
must satisfy the out-of-band emission limits and other technical requirements for operations in
the 2.3 GHz Wireless Communications Service band, as specified in Part 27 of the
Commission's rules. Compliance with these technical restrictions is critical to avoiding harmful


'   On May 12,1009, the Commission granted Cisco's application, Call Sign WDPXCP. Sirius XM's concerns
    rernain valid notwithstanding this grant.


Ms. Marlene [I. Dortch
May 15.2009
Page 2


interference to Sirius XM's subscribers. Cisco should also be asked to specify the characteristics
of the out-of-band emissions that will result from operations under this STA. In addition, Sirius
XM asks that OET require Cisco to provide a 24-hour contact number so that any interference
that does occur can immediately be resolved.

       If there are any questions regarding this matter. please contact the undersigned

                                                        ery truly yours,




                                                   IBk!b--
                                                       Vice President, Regulatory Counsel



cc:    James Burtle, FCC
       Ira Keltz, FCC
       David Case (davecase@cisco.com)



Document Created: 2009-09-21 08:05:13
Document Modified: 2009-09-21 08:05:13

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