Narrative Statement

0006-EX-PN-2019 Text Documents

T-Mobile License LLC

2019-02-01ELS_222421

Exhibit By this application, T-Mobile License, LLC seeks a program experimental license so that it and its affiliate, T-Mobile, USA, Inc. (“T-Mobile”), may conduct experiments related to its network and to devices that it may incorporate into that network. Section 5.302 of the rules provides that research laboratories and manufacturers that integrate radio frequency equipment into their end products may obtain program experimental licenses. The rule requires that applicants must ensure that: (1) the radiofrequency experimentation will be conducted in a defined geographic area under the applicant’s control; (2) the applicant has institutional processes to monitor and effectively manage a wide variety of research and projects; and (3) the applicant has demonstrated expertise in radio spectrum management or partner with another entity with such expertise. T-Mobile satisfies these requirements. Eligibility As indicated in the attached application, T-Mobile is both a research laboratory and manufacturer that integrates radio frequency equipment into end products. T-Mobile constantly performs research, through facilities at and around its Bellevue campus headquarters. That research focuses on, among other things, evaluation of spectrum capabilities, technologies, device performance, network management techniques and other components of the service it provides to the public. The research is intended to ensure that T-Mobile offers customers the best available products and services on the fastest network. T-Mobile is not only a nationwide wireless provider, it is also a retailer of devices that operate on its network. Some of these devices are sold under T-Mobile’s own brand. While it works with other entities to perform the majority of the manufacturing work, T-Mobile often finalizes the production of its devices, adding radiofrequency-affected software and firmware as appropriate. Satisfaction of Requirements As T-Mobile has certified in the attached application, it satisfies the requirements of Section 5.302(a), (b) and (c). The research conducted pursuant to the Program Experimental License will occur in environments in and around T-Mobile’s facilities in Bellevue, Washington that it controls. As noted above, T-Mobile already conducts experiments (and has secured approval as appropriate) to evaluate components of the service it provides to the public. It makes information about this research available to internal company stakeholders as appropriate. It therefore already has institutional processes to monitor and effectively manage future projects and will supplement current practices to facilitate the submission of the reports required by Section 5.309(d) of the rules. Finally, T-Mobile is the holder of over 10,000 Commission licenses.1/ As the third largest wireless carrier in the U.S., it is among the world’s leaders in radio spectrum management. It employs hundreds of highly-trained engineers who are experts in their fields. 1/ See FCC Universal Licensing System.

Contact Information Note The contact email address for this application is Chris.Wieczorek@T-Mobile.com. The application lists the e-mail address of counsel to T-Mobile, Russell Fox, because the e-mail address for Chris Wieczorek, the contact person for this application, was rejected by the application website for formatting reasons.


Document Created: 2019-02-01 12:28:00
Document Modified: 2019-02-01 12:28:00
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