08-17-10 115 License

LETTER submitted by c/o Pegasus Development DBS Corporation

Letter Requesting Prompt Action

2010-08-17

This document pretains to SAT-AMD-20080114-00023 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2008011400023_835132

Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW | Washington, DC 20037-1122 | tel 202.663.8000 | fax 202.663.8007 Tony Lin tel 202.663.8452 tony.lin@pillsburylaw.com August 17, 2010 Via Electronic Filing (IBFS) Mindel De La Torre Bureau Chief, International Bureau Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: 115 License Subsidiary, LLC Call Sign 2700 Request for Prompt Action on Milestone Compliance Determination Dear Ms. De La Torre: 115 License Subsidiary, LLC (the “Company”), by its counsel, hereby requests that the International Bureau (“Bureau”) take prompt action in reviewing the Company’s compliance with its requirement to execute a binding, non-contingent satellite construction contract for a 17/24 GHz Broadcasting-Satellite Service satellite at the 115°W.L. orbital location. The Company provided a complete copy of its satellite construction contract to the Bureau in December of last year. Over four months ago, the Company submitted a letter from the satellite manufacturer, Space Systems/Loral, Inc., providing further evidence that the Company timely met its initial milestone requirement. Further, over two months ago, the Company requested the Bureau to take prompt action regarding this same issue. However, the Bureau still has not taken any action. The Bureau’s delay is inexplicable. A survey of the time it has taken the Bureau to review other satellite contracts shows that since 2006 the International Bureau has taken on average only 5.6 months to make a milestone compliance determination. It has now been over eight months, and the Company’s inquiries to the Bureau regarding the status of its contract review suggest that it is not near completion. www.pillsburylaw.com 402227236v1

August 17, 2010 Page 2 The Company urges the Bureau to remedy this administrative delay promptly. The delay is not without real world repercussions. The Bureau’s protracted milestone compliance assessment creates regulatory uncertainty. Additionally, such delay creates unnecessary costs to the Company and ties up funds that could be used for satellite construction or other business purposes. While the Company appreciates the Bureau’s need for time to make informed milestone determinations, that need must be balanced against the licensee’s business interests. For these reasons, the Company respectively urges the Bureau to take prompt action in reviewing the Company’s compliance with its requirement to execute a binding, non-contingent satellite construction contract. Please direct any questions regarding this matter to the undersigned. Respectfully submitted, /s/ Bruce D. Jacobs Tony Lin Counsel to 115 License Subsidiary, LLC cc: Robert Nelson Andrea Kelly www.pillsburylaw.com 402227236v1


Document Created: 2010-08-17 11:36:25
Document Modified: 2010-08-17 11:36:25
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