Attachment 1992All Pro Sports a

This document pretains to SAT-LOA-19900518-00036 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1990051800036_1060317

                             APS&E
                             ALL PRO SPORTS AND ENTERTAINMENT, INC.
                    1999 Broadway, Suite 3125 « Denver, CO » (303) 292—3212 « Fax (303) 292—4036




                                                                             _ November 9, 1992


Federal Communications Commission
1919 M Street,       NW
Washington, D.C.             20554

Attention:     Office of the Secretary

Dear Secretary:

Enclosed please find an original and nine (9) copies of comments in
support of application 44/45—DSS—AMEND—92 from ALL PRO SPORTS &
ENTERTAINMENT,       INC.                                                                          |

Sincérely,
ALL PRO      ORTS    & ENTERTAINMENT
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Ath
 Peter J/. schaff
J/Vice President
General    Counsel


                                 Before                                                  the
                   FEDERAL COMMUNICATIONS COMMISS1ON
                         Washington, D.C.                                                      20554




In the matter of




                                      Nee Nee‘ Sucs" Sue Nuue Nce Mese! Dwwaet® Nuver"
the Application of

SATELLITE CD RADIO, INC,                                                                 File Nos.   49/50—05S—P/LA—90,
                                                                                                     58/59—D0§S—AMEND 90,
For Authority to Construct, Launch                                                                   44/45—DSS—AMEND .92
and Operate Space Stations for
the Provision of Digital Audio
Radio Services


TO;         The Commission



      COMMENTS OF ALL PRO SPORTS AND ENTERTAINMENT, INC.
        IN SUPPORT OF APPLICATION 44/45—DSS—AMEND—92



      All Pro Sports and Entertainment, Inc. (APSE)                                                       is a multidisciplinary
firm which focuses on the representation of professional athletes and
entertainers.    Areas of expertise and representation include: law and
contracts, financial planning, accounting, and marketing.                                                       Clients includs

Barry Sanders of the Detroit Lions, David Tate of the Chicago Bears, and Mark
Jackson and Steve Atwater of the Denver Broncos.                                                        APSE maintains offices
in Denver, Colorado and Beverly Hills, California.                                                     APSE feels confident in

commenting on the aforementioned Application and beliéves the granting of
sald Application is in the public interest for the following reasons:


       1.)     The Satellite CD          Radio,     Inc.    (SCDR) Application proposes a
system for the dellvery of thirty channels of uninterrupted, commercial free
audio programming via satellite to automobiles and fixed locations on a per
subscriber, non—broadcast basis.                 The direct from satellite delivery of the
SCDR         programming      leaves     it   unencumbered            by   the   coverage       area
considerations of traditional terrestrial broadcasting.                    These considerations

make it Impossible for many people in the United States to receive the same
level of diversity in programming options as do those in urban areas.                           The
SCDR system is a benefit to those people who choose or are forced to live in
areas less saturated by traditional broadcast mediums.                       The SCDR system

will allow more prolific coverage of entertainment programming or sports
events than is now possible.             This will allow more people in more parts of
the country to éexperience greater opportunities to maintain contact with
their particular areas of interest and enjoyment.
      2.)       The SCDR system will promote competition for the subscribers
through the ability to incorporate additional systems into the 2310—2380
MHz frequency band.             This competition will spur developments which ars

beneficial to consumers through the competing Digital Audio Radio Systems

(DARS) attempts to achieve product differentiation. | These attempts to
product differentiate will         lead to greater market satisfaction                   and     the
satisfaction of the new demands of additional markets.                     This is necessary to
the advancement which ultimately brings out the best products.                       APSE knows
the sports and entertainment markets and believes that the SCDAR system
described      in   the    Application    will    satisfy    the     initial demands    of   these
markets       and   that    competitive       pressures       will    forever    necsessitate    the


satisfaction of these markets.                    This will provida additional outlets for
sports and entertainment prograrfiming.
      3.)         The ability of the SCDR system as proposed in the Application to
provide     additional        outlets    for     sports   and     entertainment     programming

generates opportunities for new programming origination.                          This will create
the opportunity for the creation                  of jobs from field level or stage lavel!
programming pick—up to studio manipulation to satellite transmission.                           The

abllity to create jobs in the sports and entertainment industries is not just
advantageous to those industries,                     It also has necessary corollaries in

associated industries.          The result is an increase in employment possibilities
across ao wide range of disciplines and the requisite skill transference which
follows and which creates a more highly skilled and employable work force.
     4.)      The SCDR system as proposed in the Application will deliver this
Increased level and diversity of programming to a greater number of people
with a quality of fidelity that consumers presently demand.                               Consumers
desire      the     same      level     of     fidelity   from    sports   and     entértsinment
programming as they do from digital audio recordings.                        This increase in

expectations        is   in   lock—step with        the general trend toward the             "Home
Theater" whereby consumers attempt to achieve the sensations of a live
performance through enhancements to fidelity.                         To extend this "Home
Theater" concept incorporating narrowcast and niche programming to the

automobile is desirable and demanded by consumers.


                                             CONCLUSION
     The      Application        of     SCDR        should   be    granted   by     the     Fedsral
Communications Commission.               The benefits of the SCDR system are the samse

as the expectations of consumers.                 The system will serve underserved people


by giving them the same choices available to only portions of the population.
The operation of the SCODR system has the potential to create jobs and
elevate the qualifications of some part of the work force.




November 12, 1992

                                     Gehneral Counsel
                                     All Pro Sports and Entertainment
                                     1999 Broadway
                                     Denver, CO 80202

                                     303—292—40836



Document Created: 2014-09-04 17:28:24
Document Modified: 2014-09-04 17:28:24

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