Letter Supplement -

SUPPLEMENT submitted by Silkwave Africa, LLC

Letter Supplement

2016-11-23

This document pretains to SAT-ASG-20161025-00101 for Assignment on a Satellite Space Stations filing.

IBFS_SATASG2016102500101_1159480

November 23, 2016

VIA ELECTRONIC FILING


Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
Room TW-A325
Washington, DC 20554


Re:    SAT-ASG-20161025-00101
       Application for Assignment of Authorizations for AfriStar-1 and AfriStar-2 (call
       signs S2367 and S2666) from Yazmi USA, LLC (“Yazmi”) to Silkwave Africa,
       LLC (“Silkwave”).



Dear Ms. Dortch:

        At the request of FCC staff, we are submitting this letter in the docket for the
above-named application (the “Application”) to supplement statements made in the
Public Interest Statement of that Application.

         The Public Interest Statement explained that the AfriStar-1 satellite will be
initially controlled by Intelsat pursuant to an agreement between Intelsat, Silkwave, and
an affiliate of Silkwave. The affiliate of Silkwave referred to is New York Broadband
LLC, a U.S. limited liability company (“NYBB”). NYBB is affiliated with Silkwave
because Chi Capital, which owns 100% of Silkwave, also has a minority ownership
interest in NYBB. NYBB owns an Australian-licensed satellite, AsiaStar, which is
operated by Intelsat pursuant to an agreement between NYBB and Intelsat (the “NYBB
Agreement”). The AsiaStar satellite was also acquired from Yazmi pursuant to a series
of earlier transactions not requiring FCC approval.

        The AfriStar-1 satellite is currently being operated by Intelsat pursuant to a
separate agreement between Yazmi and Intelsat (the “Yazmi Agreement”). The parties
intend that, following the transfer of the AfriStar-1 license to Silkwave, Intelsat will
continue to operate the AfriStar-1 satellite on Silkwave’s behalf, either through an
amended Yazmi Agreement, or more likely through an amended NYBB Agreement that
includes the AfriStar-1 satellite and adds Silkwave as a party.

         The Public Interest Statement indicated that this agreement will “initially” govern
the operation of the Afristar-1 satellite only to leave open the possibility that a separate
agreement will be entered into between Silkwave and Intelsat or another U.S.-based
satellite operator. The applicants seek flexibility for changes in the form of the
agreement with Intelsat or the identity of the U.S. entity operating the AfriStar-1 satellite.


                                                                                          2


If Silkwave were in the future to opt to engage a non-U.S. entity to operate the AfriStar-1
satellite, Silkwave would seek FCC approval before doing so.

       Please let us know if you need any additional information.

                                             Respectfully submitted,


       /s/ Patrick S. Campbell                       /s/ Tedros A. Lemma
       Patrick S. Campbell                           Yazmi USA, LLC
       Paul, Weiss, Rifkind, Wharton                 8515 Georgia Ave.
       & Garrison LLP                                Silver Spring, MD 20910
       2001 K Street, N.W.                           (202) 803-5740
       Washington, DC 20006                          tlemma@yazmi.com
       (202) 223-7300                                Counsel to Yazmi USA, LLC
       pcampbell@paulweiss.com
       Counsel to Silkwave Africa, LLC

cc:    Karl Kensinger, Deputy Division Chief, Satellite Division, International Bureau



Document Created: 2016-11-23 10:15:32
Document Modified: 2016-11-23 10:15:32

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