Letter to Doug Young (Dec 13, 2002)

0411-EX-ST-2002 Correspondence

Mobile Satellite Ventures Subsidiary LLC

2002-12-13ELS_59303

ShawPittman ur
A Limited Liability Partnership Including Professional Corporations




                                                                      December 13, 2002

   Via Electronic Filing
   Mr. Doug Young
   Experimental Licensing Branch
   Office of Engineering and Technology
   Federal Communications Commission
   445 12th St. S.W.
   Washington DC 20554

                 RE:          Mobile Satellite Ventures Subsidiary LLC
                              Reference Number: 2330
                              Call Sign WBIXQG
                              File No. 0150—EX—ST—2002 (Request for Experimental STA)
                              File No. 0411—EX—ST—2002 (Request for Extension of Experimental STA)
                              File No. 0277—EX—PL—2002 (Request for Experimental License)

   Dear Mr. Young:

           On November 20, 2002, you inquired as to the above—captioned request of Mobile
   Satellite Ventures Subsidiary LLC ("MSV") for extension of an experimental special temporary
   authority ("STA") granted on May 15, 2002 to test and demonstrate mobile terminals ("MTs") at
   four locations that will operate with MSV‘s licensed L—band satellite, MSAT—2. You inquired as
   to the equipment approval status for these MT‘s and also noted in reference to MSV‘s above—
   captioned request for an experimental license that the Experimental Licensing Branch "does not
   routinely grant licenses for demonstration of unapproved equipment without explanation of
   where the project is headed in the long term and when the equipment will be approved for
   regular use."

          As an initial matter, MSV notes that it has demonstrated and seeks to continue to
   demonstrate a limited number of MT‘s that are not authorized under MSVs existing Title III
   blanket MT licenses, thus requiring MSV to seek experimental authority to test and demonstrate
   these MTs. These demonstrations will take place at four locations, as specified in the above—
   captioned STA request.

           MSV‘s application for an experimental STA was granted in May 2002. Preparation for
   the planned demonstrations took longer than expected. As a result, the initial demonstrations
   pursuant to this STA took place in late October 2002, a few weeks prior to expiration of the STA
   on November 15, 2002. Thus, MSV did not demonstrate these MT‘s during the majority of the
   six—month period of the STA and was unable to complete its intended demonstrations. MSV
   filed for an extension of this STA to enable continued demonstrations during the six months
   following expiration of the original STA. Regarding MSV‘s application for a two—year
                                                                                                                                 _   Washington, DC
                                                                                                                                     Northern Virginia
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2300 N Street, NW Washington, DC 20037—1128                           202.663.8000 Fax: 202.663.8007       www.shawpittman.com   |   London
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ShawPittman ur
 Mr. Doug Young, Experimental Licensing Branch
 December 13, 2002
 Page 2

experimental license, Section 5.61 of the Commission‘s rules provides that an experim
                                                                                        ental STA
will be extended only if "an application for a regular experimental license has been
                                                                                     filed at least
15 days prior to the expiration of the licensee‘s temporary authority." 47 C.F.R. § 5.61.
                                                                                           Thus,
MSV filed for an experimental license in order to enable continued demonstrations
                                                                                     pursuant to
its original experimental STA.

          Should these demonstrations prove successful and indicate consumer demand for these
MTs, MSV will seek a modification of its Title III blanket MT license in order
                                                                               to obtain
permanent authority to operate these MT‘s and will seek equipment certification, as
                                                                                    needed.
          Please contact the undersigned at (202) 663—8432 with any questions or concerns.

                                                      Very truly yours,


                                                   E>A 4_
                                                     David S. Konczal

                                                     Counsel for MSV


Document #: 1293955 v.1



Document Created: 2019-02-14 12:11:09
Document Modified: 2019-02-14 12:11:09

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