Confidential Treatment Request

0201-EX-ST-2018 Text Documents

UltiSat Inc.

2018-02-06ELS_204437

                          UltiSat Inc. -- Application for Experimental
                          Special Temporary Authorization (“STA”)

                              Request for Confidential Treatment

       UltiSat Inc. (“UltiSat”), pursuant to Sections 0.457 and 0.459 of the Commission's rules,
47 C.F.R. §§ 0.457 and 0.459, hereby requests that certain information in connection with its
application for special temporary authorization (“STA”) be treated as confidential and not subject
to public inspection. The designated information constitutes confidential and highly sensitive
information that, if subject to public disclosure, would cause significant commercial and
competitive harm and pose potential threats to the national security interests of the United States.
As described below, UltiSat request satisfies the standards for grant of such requests set forth in
Sections 0.457 and 0.459 of the Commission’s rules. It would also adversely affect U.S. law
enforcement and security interests generally.

        In accordance with Section 0.459(b) of the Commission’s rules and in support of this
request, UltiSat provides the following information:

1.     Identification of the specific information for which confidential treatment is sought.

       The specific information which requires confidential treatment is UltiSat’s government
customer contract and substantive project information. The technical data provided in the FCC
Form 442, as well as the information contained in the application Narrative and Technical
Appendix, can be made publicly available. This confidentiality request itself does not contain any
confidential information and, therefore, can also be made publicly available.

2.     Identification of the Commission proceeding in which the information was
       submitted or a description of the circumstances giving rise to the submission:

       The confidential information is submitted in connection with UltiSat’s application for a
six-month special temporary authorization filed with the Commission on February 6, 2018 (File
No. 0201-EX-ST-2018).

3.     Explanation of the degree to which the information is commercial or financial, or
       contains a trade secret or is privileged:

         Information relating to UltiSat’s government customer and project specifics is highly
sensitive law enforcement and security information that is not available to the public in any form.
It also includes private information concerning the applications of UltiSat’s technology, including
strategic research and development tactics. Disclosure of such information would cause
irreparable injury and substantial harm to UltiSat’s ongoing business operations and competitive
position. It would also adversely affect U.S. law enforcement and security interests generally.


4.     Explanation of the degree to which the information concerns a service that is subject
       to competition:

        The information contained herein includes information of a highly confidential and
proprietary nature relating to the development of technology for the law enforcement and U.S.
government sector. This is a highly competitive industry and the inadvertent release of any private
government contract or project information would have a severe negative impact on UltiSat’s
competitive position in the marketplace. It would also adversely affect U.S. law enforcement and
security interests generally.

5.     Explanation of how disclosure of the information could result in the substantial
       competitive harm:

       The disclosure of the substantive project scope and related government contract
information could have an extremely negative impact on UltiSat ongoing business operations and
competitive position. Certain proprietary information developed by UltiSat is used to support the
development of systems and functions for United States law enforcement and security sectors.
Moreover, due to the unique nature of UltiSat’s customer, the United States government,
confidentiality of sensitive contractual information must not be shared with competitors.

6.     Identification of any measures taken by the submitting party to prevent
       unauthorized disclosure:

        The substantive project scope and related government contract information is not currently
available to the public in any form and UltiSat takes all commercially necessary steps to prevent
this information from being disclosed to the public. UltiSat has made this information available
only to a small selection of people directly related to the project, and only on a need to know basis.

7.     Identification of whether the information is available to the public and the extent of
       any previous disclosure of the information to third parties:

         The substantive project scope and related government contract information for this project
is not currently available to the public and UltiSat takes all commercially necessary steps to prevent
the information from being disclosed to the public. Only those persons or entities directly involved
in the project, such as subcontractors and the United States government, are privy to the subject
proprietary information, and only after any such part has executed a non-disclosure agreement.

8.     Justification of the period during which the submitting party asserts that material
       should not be available for public disclosure:

       UltiSat requests that the substantive project scope and related government contract
information be kept confidential indefinitely. Such a time period is justifiable in light of the
substantial competitive concerns inherent in the defense contracting industry, as well as to protect
the law enforcement and security interests of the United States. Due to the sensitive nature of the
information, UltiSat’s requests that the information be kept confidential for an indefinite period.



Document Created: 2018-02-06 22:12:19
Document Modified: 2018-02-06 22:12:19

© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC