Incoming generated [Aug 30 2017]

0549-EX-CN-2017 Correspondence

Row 44, Inc.

2017-08-30ELS_197650

From: McLellan Simon

To: Behnam Ghaffari
Date: August 30, 2017

Subject: 0549-EX-CN-2017
----------------------------------------------------------------------------------------------------------------
Message:

While Row 44 is not unalterably opposed to some slight modification of its spectrum request, it does not
believe the proposed limitation is appropriate, both because the Commission is currently proposing to
make the entire subject band available for use by Earth stations in motion, and because other service
providers who compete with Row 44 and its parent company, Global Eagle Entertainment Inc., are
currently authorized to operate on these frequencies using larger numbers of mobile terminals on both an
experimental and permanently-licensed basis.

With respect to the first point, in its currently pending rulemaking on the use of Earth stations in motion
communicating with geostationary orbit space stations, the Commission specifically proposes to extend
the availability of spectrum for Earth Stations Aboard Aircraft and other mobile uses to include the
29.25-30.0 GHz (Earth-to-space) band. See Amendment of Parts 2 and 25 of the Commission's Rules to
Facilitate the Use of Earth Stations in Motion Communicating with Geostationary Orbit Space Stations in
Frequency Bands Allocated to the Fixed Satellite Service, FCC 17-56, slip op. at 15 (¶ 53) and
Appendix A, Proposed Rules, at § 25.202(a) (released May 19, 2017). Given this pending proposal,
it would seem that the Commission would seek affirmatively to encourage experimental testing consistent
with the proposed rule change.

Second, companies that compete with Row 44/Global Eagle are already authorized to operate using
significant numbers of mobile units across this band. See, e.g., ViaSat, Inc., Call Sign WH2XTJ, OET
File No. 0224-EX-CR-2017 (granted May 12., 2017) (permitting use of up to 75 remote mobile terminals
in CONUS in the band 28350-30000 MHz); Thales Avionics, Inc., Call Sign E170068, IBFS File No.
SES-LIC-20170217-00183 (granted July 7, 2017) (permitting operation of up to 250 remote mobile units
in the band 29300-30000 MHz using multiple points of communication, including the Jupiter 2 satellite at
97.1 W.L. requested in the Row 44 experimental license application); Speedcast Communications Inc.,
Call Sign E060157, IBFS File No. SES-MFS-20161006-00829 (granted April 18, 2017) (permitting
operation of up to 1000 remote mobile units in the band 29250-30000 MHz).

Please let us know if direct discussion of these concerns might be helpful, or if there are other issues that
may need to be addressed.

David Keir
Lerman Senter PLLC
on behalf of Row 44, Inc.

Document Created: 2017-08-30 17:53:23
Document Modified: 2017-08-30 17:53:23

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