Attachment bond claim

bond claim

LETTER submitted by OMD,FCC

bond claim

2009-08-26

This document pretains to SAT-LOA-20040322-00236 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2004032200236_735781

                                FEDERAL COMMUNICATIONS COMMISSION
                                           Washington, D. C. 20554

OFrFicE OF
MANAGING DIRECTOR                                  August 26, 2009



             Safeco Insurance Company of America
             Safeco Plaza
             1001 4"" Avenue
             Seattle, Washington 98184

                                    Re: Bond Claim, Bond Number: 6321647


             To Whom It May Concermn:

                    This letter is to notify you that the Federal Communications Commission has issued a
         Notice of Default concerning the above referenced satellite authorization issued to ATCONTACT
         Communications, LLC (ATCONTACT). A copy of the Order canceling the authorization is
         enclosed.

                 On April 14, 2006, the International Bureau, Federal Communications Commission,
         granted ATCONTACT authority for a satellite system consisting of both non—geostationary
         satellite orbit (NGSO) and geostationary satellite orbit (GSO) space stations.‘ ATCONTACT was
         authorized to construct three NGSO satellites capable of operating in the 18.8—19.3 GHz and
         28.6—29.1 GHz frequency bands on a primary basis, in the 29.5—30.0 GHz frequency band on a
         secondary basis, and in the 19.7—20.2 GHz frequency band on a non—conforming basis.
         ATCONTACT was also authorized to construct, launch, and operate four GSO satellites in the
         28.6—29.1 GHz frequency band on a secondary basis, and in the 18.8—19.3 GHz frequency band on
         a non—conforming basis.

                   Pursuant to this authorization, ATCONTACT was required to satisfy specific
         implementation milestones, or the authorization would be rendered null and void. ATCONTACT
         did not satisfy its third milestone for its authorization, to commence physical construction of its
         first NGSO satellite, nor did it request an extension of the milestone date. Consequently, the
         satellite authorization is null and void by its own terms.

                 As a condition of its authorization, ATCONTACT posted a bond with the Commission of
         $5 million for its satellite authorization. The bond names the U.S. Treasury as beneficiary in the
         event ATCONTACT defaults by failing to meet any milestone anda milestone extension is not
         granted. ATCONTACT satisfied the first two milestones in its authorization and reduced the
         amount of the bond as is permitted under Commission rules. See Bond Riders dated July 10,



         ‘ contactMEO Communications, LLC, Order and Authorization, DA—06—864, 21 FCC Red 4035 (Int‘l Bur.
         2006)(14TCONTACT Authorization). In June 2006, the licensee notified the Commission of its name change
         from contactMEO Communications, LLC to ATCONTACT Communications, LLC. Letter to Marlene H.
         Dortch, Secretary, FCC, from James M. Talens, Counsel to ATCONTACT Communications, LLC (June 5,
         2006).


2007 and September 9, 2008. As a result of ATCONTACT‘s failure to meet its third milestone,
ATCONTACT must pay to the United States Treasury the sum of $3 million.


        Please remit funds by wire transfer using the following instructions:

        ABA Routing Number: 021030004
        Receiving Bank:     TREAS NYC
                            33 Liberty Street
                                New York, NY 10045
        BNF:   FCC/Account Number 27000001
        FRN:   0007662489              '
        RE:    ATCONTACT Cormmunications
               Bond Claim # 6321647
        Lockbox: 979093

        For further information, please contact Gail Glasser, Office of the Managing Director,
Financial Operations at (202) 418—0578.

                                                 Sincerely,


                                                 Mark Stephens
                                                 Chief Financial Officer

Enclosure


Copy to:

Jaraes M. Talens
Counsel for ATCONTACT Communications, LLC
6017 Woodley Road
McLean, VA 22101


                                  Federal Cormmunications Commission                                                                                                                     DA 09—1850


                                               Before the
                                  Federal Communications Commission
                                          Washington, D.C. 20554




                                                                                                                                                            File Nos. SAT—LOA—19971222—00222




                                                      bedbrrttotfireaitiediiradrediredfiinatiantfiredibeatiinadfibediinadtinetiietiieatinatirenRrentiinad
                                                                                                                                                                     SAT—LOA—20040322—
                                                                                                                                                                      00234/35/36/37
In the Matter of                                                                                                                                                      SAT—MOD—20060511—
                                                                                                                                                                      00057/58/59/60
ATCONTACT Communications, LLC                                                                                                                                         SAT—AMD—20031030—00317
                                                                                                                                                                      SAT—AMD—20040719—00141
                                                                                                                                                                      SAT—AMD—20040322—00057
                                                                                                                                                                      SAT—AMD—20051118—00243
                                                                                                                                                                      SAT—MOD—20070924—00130
                                                                                                                                                                      SAT—AMD—20071215—00176
For Authority to Launch and Operate                                                                                                                                   SAT—MOD—20070924—00132
a Non—Geostationary Orbit Fixed—Satellite                                                                                                                             SAT—AMD—20080505—00100
System in the Ka—band Frequencies                                                                                                                                     SAT—AMD—20080505—00096
                                                                                                                                                                      SAT—AMD—20080505—00099
                                                                                                                                                                      SAT—MOD—20080813—00155
                                                                                                                                                                      SAT—AMD—20080930—00195
                                                                                                                                                                      SAT—AMD—20080930—00194


                                                                                                                                                            Call Signs: $2346, S2680, S2681, S2682,
                                                                                                                                                                     $2683




                                                  ORDER


Adopted: August 21, 2009                     |                                                                                                                        Released: August 21, 2009


By the Acting Chief, International Bureau:

J.      INTRODUCTION

        1.         By this Order, we deciare null and void ATCONTACT Communications, LLC‘s
(ATCONTACT) authorization for a satelilite system intended to provide Fixed—Satellite Service (FSS)
consisting of three non—geostationary satellite orbit (NGSO) satellites and four geostationary satellite orbit
(GSO) satellites, for failure to meet its milestone requirements. Specifically, ATCONTACT‘s failure to —
commence physical construction of its first NGSO satellite by the required date renders its authorization
null and void by its own tenns. As a result, ATCONTACT‘s requests to modify its NGSO/GSO system
and its associated bond waiver and milestons extension requests are rendered moot.


                                      Federal Communications Commission                                   DA 09—1850



  .       BACKGROUND

            2.     On April 14, 2006, the International Bureau granted ATCONTACT authority for an FSS
  satellite system consisting of both NGSO and GSO satellites." ATCONTACT was authorized to
  coustruct, launch and operate four GSO satellites in the 28.6—29.1 GHz frequency band on a secondary
  basis, and in the 18.8—19.3 GHz frequency band on a non—conforming basis." ATCONTACT was also
  authorized to construct three NGSO satellites capable of operating in the 18.8—19.3 GHz and 28.6—29.1
  GHz frequency bands on a primary basis, in the 29.5—30.0 GHz frequency band on a secondary basis and
  in the 19.7—20.2 GHz frequency band on a non—conforming basis. ATCONTACT was not authorized to
  launch and operate its NGSO satellites pending the development of additional information concerning its
  plans for end—of—life disposal plans of its NGSO spacecraft." Nevertheless, the Bureau addressed all
  issues relating to the proposed NGSO FSS operations and imposed conditions governing these operations,
  so it would be in a posmon to act expedmously once ATCONTACT filed its request for launch and
  operating authority.‘

            3.    Consistent with the Cormmission‘s rules, the Bureau imposed imilestone schedules on
  ATCONTACT‘s authorization. Because ATCONTACT‘s system included both NGSO and GSO
  components, it was required to comply with the NGSO and GSO milestones in the Commission‘s rules."
  For its NGSO satellites, ATCONTACT had to satisfy five milestones: 1) enter into a binding non—
  contingent construction contract for the satellites within one year of licensing; 2) complete critical design
  review of the licensed system within two years of licensing; 3) begin construction of the first satellite
  within two years, six months of licensing; 4) launch and operate the first satellite within three years, six
* months; and 5) bring all ofthe satellites into operations within six years of licensing. For its GSO
  satellites, ATCONTACT was required to meet four milestones: 1) enter into a binding non—contingent
  construction contract for the satellites within one year of licensing; 2) complete critical design review
  within two years of licensing; 3) begin construction of the satellites within three years of licensing; and 4)
  launch and operate the satellites within five years of licensing. These milestones were incorporated as a

  ‘ contactMEO Communications, LLC, Order and Authorization, 21 FCC Red 4035 (Int‘l Bur. 2006)(4TCONTACT
 Authorization). In June 2006, the licensee notified the Cormmission of its name change from contactMEO
 Communications, LLC to ATCONTACT Communications, LLC. Letter to Marlene H. Dortch, Secretary, FCC,
 from James M. Talens, Counsel to ATCONTACT Communications, LLC (June 5, 2006).
 * Space stations operating in primary services are protected against interference from stations of secondary services.
 Stations operating in a secondary service cannot cause harmful interference to or claim protection from harmful
 interference from stations of a primary service. See 47 C.E.R. §§ 2.104(d) and 2.105(c). Non—conforming services
 may be provided only on a non—harmful interference basis to any authorized service and may not cause interference
 protection from those services.

 > ATCONTACT‘s authorization was conditioned on its filing a modification application in May 2008 detailing its
 end—of—life disposal plans for its NGSO satellites, ATCONTACT filed for extension of time to file its plan. While
 the extension request was pending, ATCONTACT filed a modification application changing its end—of—life plans
 from controlled re—entry to a disposal orbit. See File No. SAT—MOD—20080813—00155. Upon review, the Satellite
 Division (Division) determined that it needed greater detail before it could address ATCONTACT‘s revised end—of—
 life disposal plan. The Division stated it would defer action on ATCONTACT‘s modification application and asked
 ATCONTACT to file the additional information before April 30, 2009. See Letter to James M. Talens, Counsel for
 ATCONTACT Communications, LLC from Robert G. Nelson, Chief, Satellite Division (January 9, 2009) (Division
 Letter). ATCONTACT did not respond to this request but noted that it "would now appear to be moot" in light of
 subsequent changes to its NGSO authorization. See Letter to Marlene H. Dortch, Secretary, FCC, from James M.
 Talens, Counsel for ATCONTACT Communications LLC (February 6, 2009) at 2, n.3. (4TCONTACT February
 Letter).
 * ATCONTACTAuthorization, 21 ECC Red at 4035.
 547 CFR. § 25.164(a), (b).


                                    Federal Communications Commission                            DA 09—1850



condition of ATCONTACT‘s license, which also provided that failurs to coraply with a milestone would
result in automatic cancellation of ATCONTACT‘s authorization."            In addition, ATCONTACT was
required to file a bond for $5 million within 30 days of grant.

     4.    On July 6, 2007, the Bureau‘s Satellite Division (Division) determined that
ATCONTACT had met the contract execution milestone by submitting a copy of its satellite construction
contract with Space Systems/Loral, Inc. (Loral), its spacecraft manufacturer for both its NGSO and GSO
satellites.‘ On September 5, 2008, the Bureau determined that ATCONTACT had met the Critical Design
Review milestone requirement for its NGSO and GSO satellites." ATCONTACT‘s next milestone, to
commence physical construction of its first NGSO satellite, was October 15, 2008. On that date,
ATCONTACT filed informationthat it claimed demonstrated that if had satisfied this milestone.‘ The
information included a certification from David M. Drucker, Manager of ATCONTACT, stating that
ATCONTACT had commenced construction of its first NGSO satellite to the "best of my knowledge,
information, and belief." ATCONTACT also included an asset sales agreement it had entered into with a
third party (not its satellite manufacturer) for the purchase of traveling wave tube amplifiers (TWTAs).
The first payment under the sales agreeraent was due January 15, 2009 and the first delivery due around
February 15, 2009. In January 2009, the Division sent ATCONTACT a letter stating that the showing did
not demmonstrate compliance with the beginning construction milestone and requested additional
information regarding construction of the satellite, including details regarding production, payment and
photographs of production."
         5.          In a February 6, 2009 response to the Bureau‘s letter, ATCONTACT maintained that its
showing was sufficient. It also submitted several unlabeled photographs of TWTAs in boxes."
ATCONTACT further indicated that it no longer intended to proceed with its NGSO satellites and two of
its GSO satellites, requested a three year extension of the remaining milestones for the two remaining
GSO satellites and asked the Bureauto act expeditiously on several pending modification applications
relating to the remmaining GSO space stations. ATCONTACT also requested the release of its bond.
ATCONTACT maintained that these revisions are necessitated by its inability to obtain financing for its
system as a result of the current economic climate." ATCONTACT‘s response did not address the
Division‘s other information requests.

        6.      On May 1, 2009, Intelsat North America LLC (Intelsat) filed a letter stating that granting
such a broad waiver of the bond and milestone requirements could undermine the purpose of these
obligations. Intelsat contends that ATCONTACT failed to provide specific factual information to support
a waiver, and disagrees with ATCONTACT‘s claim that current economic conditions justify a waiver,"
In response, ATCONTACT maintains that Intelsat‘®s submission should be rejected because Intelsat has


6 ATCONTACTAuthorization, 21 FCC Red at 4053.                          ,
? Policy Branch Information, Public Notice, 22 FCC Red 11961(2007).
* Policy Branch Information, Public Notice, 23 FCC Red 13293 (2008).
° Letter to Marlene H. Dortch, Secretary, FCC, from James M. Talens, Counsel for ATCONTACT Communications,
LLC (October 15, 2008) (4TCONTACT Milestone Filing).

4 Pivision Letter.

4 Letter to Mariene H. Dortch, Secretary, FCC, from James M. Talens, Counsel for ATCONTACT
Communications LLC (February 6, 2009) (4TCONTACT February Letter).
* ATCONTACT February Letter, at 3.
" Letter to Marlene H. Dortch, Secretary, FCC, from Kalpak S. Gude, Vice President and Deputy General Counsel,
Intelsat North America LLC (May 1, 2009).


                                     Federal Communications Commission                                   DA 09—1850



no standing in this matter. ATCONTACT also states that it previously provided "explanation, precedent,
and justification" to the Commission to support its request. 14

III      DISCUSSION

         7.       In the 2003 Space Station Reform Order, the Commission adopted a first—come, first—
served licensing process for space station applications." As part of the new framework, the Commission
adopted a package of market—driven safeguards designed to discourage speculative applications. Those
safeguards also help to ensure that licensees remain committed and able to proceed with timely
implementation of hcensed space stations, which generally cost several hundred million dollars each to
Iaunch and operate."" The safeguards include: (1) a requirement that licensees post a bond with the
Commission within 30 days of license grant; and (2) a requirement to construct and launch the satellite(s)
consistent with the milestone schedule specified in Section 25.164 of the Commission‘s rules." The
milestones track the three—to—five year period needed to construct and launch a satellite. The amount of
the bond may be reduced as milestones are met."" If the licensee fails to meet a milestone, and an
extension is not granted for good cause shown, the license becomes null and void and the outstanding
balance of the bond is paid to the U.S. Treasury."

      8.      Before we consider the pending modifications to ATCONTACT‘s authorization for three
NGSO and four GSO space stations, we must first determine whether ATCONTACT has met the October
15, 2008 milestone for beginning physical construction of its first NGSO satellite. If it has not, the
authorization for its hybrid NGSO/GSO satellite system is, by its own terms, null and void."

         9.      To satisfy the commencement of physical construction milestone, licensees imust provide
sufficient information to demmonstrate toa reasonable person that they have commenced physical
construction of the 1icensedspacecraft The Commission emphasized that the burden of proof for this
showing is on the licensee." Showings that have been found sufficient to meet this milestone have
included photographs of various satellite components that have been delivered to or made by the
manufacturer, and are clearly identified for use with the licensed satellite. In addition to photographs,
licensees typically provide evidence that they have made milestone payments under the manufacturing


" Letter to Marlene H. Dortch, Secretary, FCC, from James M. Talens, Counsel for ATCONTACT
Communications, LLC (May 8, 2009)(4TCONTACT Response Letter) at 2.
* Amendment of the Commission‘s Space Station Licensing Rules and Policies, Mitigation of Orbital Debris, Firsf
Report and Order and Further Notice ofProposed Rulemaking in IB Docket No. 02—34, and First Report and Order
in IB Docket No. 02—54, 18 FCC Red 10760 (2003) (Space Station Licensing Reform Order).
! Space Station Licensing Reform Order, 18 ECC Roed at 10823; NetSat 28 Company, LLC, Memorandum Opinion
and Order, 19 ECC Roed 17722 (Int‘l Bur. 2004).

‘? The required bond is $3 million for a geostationary—orbit (GSO) satellite and $5 million for a constellation of non—
geostationary—orbit (NGSO) satellites. Because ATCONTACT‘s GSO space stations were to operate in the sams
frequency bands as its NGSO space stations, Commission rules require ATCONTACT to post only one $5 million
bond. See 47 C.FR. § 25.165(a)(3).
447 C.RR§25.165(d).
947 C.F.R. §25.165(c), and Space Station Licensing Reform Order, 18 FCC Red at 10824.
* See New ICO Satellite Services, GP, Memorandum Opinion and Order, 21 ECC Red 14612, 14615 (Int‘l Bur.
2006). In addition, we note that ATCONTACT failed to file a modification application for an extension of its
remaining imilestones, as required by Section 25.117(c) of the Commission‘s rules, 47 C.F.R. § 25.117(c).
* Space Station Licensing Reform Order, 18 FCC Red at 10834.
* Space Station Licensing Reform Order, 18 FCC Red at 10833

                                                           4


                                      Federal Communications Commission                                 DA 09—1850



contracts that are associated with the construction and delivery of these components." Based on our
expertience in reviewing milestone compliance, at this point in the construction process licensees have
generally paid 25—50 percent of the total price in the manufacturing contract due to the cost of procuring
parts.

         10.      As evidence that ATCONTACT met its October 15, 2008 milestons for beginning
construction, it submitted an asset sales agreement with a third party dated October 14, 2008. The
agreement involves the purchase of TWTAs, with ATCONTACT‘s first payment due January 15, 2009 —
three months after the beginning construction milestone — and the first delivery of TWTAs due around
February 15, 2009. Ordering "long lead" items needed to begin physical construction of a space station,
such as TWTAs, does not provide evidence that a licensee has met the beginning construction milestone.
Rather, ordering such iterms provides evidence that a licensee has met the critical design review (CDR)
milestone."* The CDR milestone occurs one full year before the beginning construction milestone.

          11.    Further, there is no documentation in the asset sales agreement that links the TWTAs to
the manufacturing contract with Loral. It is highly unusual for a licensee to enter into individual purchase
contracts for TWTAs outside of the satellite manufacturing contract, unless this fact is specifically
referenced in the construction contract. In meeting its contract execution milestone for its NGSO
satellites, ATCONTACT submitted a satellite construction contract entered into with Loral on April 12,
2007."" The contract with Loral is for "all design, manufacture, test, and delivery" of its NGSO satellites.
The technical characteristics of TWTAs have a direct impact on the satellite manufacturer‘s ability to
build the satellite to the technical specifications in the contract. Nothing in the Loral manufacturing
contract, however, indicates that TWTAs were to be a "purchaser—furnished" item. ATCONTACT does
not explain why it subsequently contracted with a third party for the purchase of TWTAs for its satellites,
whether the third party was an approved subcontractor and whether Loral had approved or was even
aware of the purchase.                                         ‘

        12.    As a result, the Division informed ATCONTACT, by letter, that the asset sales agreement
was inadequate to demonstrate it had met the beginning construction milestone. In the letter, the Division
requested ATCONTACT to "describe with specificity" the types of hardware in production, a description
of the production that had taken place to date and photographic evidence of the current production of
hardware."" The Division also asked ATCONTACT to explain what payments had been made under the
payment plan provided in the Loral construction contract — the contract that ATCONTACT subraitted as
certification that it had met its contract execution milestone.

       13.     In its February 2009 response, ATCONTACT did not provide a description of the
manufactured hardware or the production activities that had taken place, as the Division requested.

* See, eg., Policy Brauch Information, Public Notice, Report No. 07—00476, 22 FCC Red 18392 (2007) (finding
that Loral Skynet Corporation has commenced physical construction based on declarations from the spacecraft
manufacturer summarizing the status of satellite construction, certifying that the manufacturing contract remains in
effect, that payments due to date have been made, and that 70 percent of the flight equipment is constructed, and
providing electronic photographs showing propulsion equipment integrated with the satellite structure); and Policy
Branch Information, Public Notice, Report No. SAT—07—00469, 22 FCC Red 16284 (2007) (finding compliance with
commencement of physical constraction milestone based on declarations from Star One SA‘s Director of
Engineering with knowledge of construction that 80 percent of payments due under the contract have been made,
and photographs clearly showing the satellite payload integrated into the satellite bus}.
* Space Station Licensing Reform Order, 18 FCC Red at 10833. In addition to TWTAs, long lead items typically
include power systeros (including solar panels and batteries) and propulsion systems.
* Contract between ATCONTACT Communications, LLC, and Space Systems/Loral for NGSO satellites, filed
April 13, 2007 (confidential treatment requested).
* Division Letter (emphasis added).


                                    Federal Communications Commission                                 DA 09—1850



 Rather, ATCONTACT stated that the sales agreement for the TWTAs was a sufficient showing to
 demonstrate that it had met its construction milestone obligation. In addition, ATCONTACT did not
 respond to the Division‘s request to provide evidence of payments made to Loral under the construction
 contract. ATCONTACT made only the unsupported assertion that it had expended "millions of dollars
 on long lead items such as [TWTAs}" and submitted four photographs that purport to be the TWTAs
 purchasedin the third—party asset agreement.* Without evidence such as cancelled checks, paid invoices
 or purchase orders or an affidavit from the satellite manufacturer stating that all payments due under the
 contract have been made, there is no basis for the Bureau to conclude that ATCONTACT has made any
 scheduled payments to Loral or that it has, in fact, made any progress toward constructing its licensed
 satellite. Thus, we cannot conclude that ATCONTACT‘s undocumented claim that it has expended
 "millions of dollars" supports its assertion that it has met the milestone for beginning construction of its
 first NGSO space station.

          14.      Further, the four photographs submitted do not support ATCONTACT‘s assertion that it
 satisfied the milestone. Three of the four photographs show TWTAs in plastic cartons. The TWTAs are
 stamped with the word "Astrolink." We note that Astrolink was a GSO satellite licensee that relinquished
 its license in 2003. ATCONTACT states the TWTAs were designed for GSO satellites but were
 "adaptable for use" with its NGSO satellites. ATCONTACT does not, however, describe the link
 between the Astrolink TWTAs and the ATCONTACT licensed space station in the Loral construction
 contract."" The fourth photograph depicts several stacked cardboard boxes with old tape marks and worn
 labels that are illegible. ATCONTACT does not explaiu the contents of these boxes or link thein in any
 way to the Loral construction contract. Without further evidence that the photographs reflect components
 being integrated into the licensed NGSO space station being built by Loral, including evidence that Loral
 had approved the purchase of these integral components from a third—party, we cannot conclude that the
 photographs provide evidence that ATCONTACT has begun constructing its first NGSO space station.

 IV.      CcoNCLUSION
           15.     Based on the lack of evidence provided by ATCONTACT, including its failure to
 respond to the Division‘s request for specific additional information, we find that ATCONTACT has
 failed to meet its burden of proof that it has satisfied its third milestons, to commence physical
 construction of its first NGSO satellite. Therefore, by its terms, ATCONTACT‘s satellite authorization is
 null and void. As a result, we need not address ATCONTACT‘s request to "revise" its authorization by
 reducing the number of satellites in its system, extending the milestones for its remaining satellites and
 releasing the bond."" Further, for the same reason, ATCONTACT‘s pending modification applications
 relating to two GSO satellites are dismissed as moot, Consequently, the outstanding balance on the bond,
 $3 million, is now due to the U.S. Treasury.




 * ATCONTACT February Letter, at 2. Further, assuming that ATCONTACT is referring to the TWTAs referenced
 in its October Asset Sales Agreement, the first payment due in January does not represent "millions of dollars."
 ATCONTACT fails to state what other, if any, long lead items it had purchased. In any case, by the October 2008
 beginning construction inilestone, ATCONTACT‘s payments under the terims of the Loral contract would have
 likely totaled several hundreds of millions of dollars.

 * 4TCONTACT February Letter, at 2, n.2.
 * Because ATCONTACT‘s authorization is null and void for failure to meet its inilestone requirements, we do not
\ address ATCONTACT‘s failure to submit its modification request in accordance with Section 25.117 of the
 Corpmission‘s mules. 47 C.F.R. § 25.117.


                                 Federal Communications Commission                             DA 09—1850



v.      ORDERING CLAUSES

        16.      Accordingly, IT IS ORDERED that ATCONTACT Communications, LLC‘s
authorization to operate a NGSO/GSO Ka—band system, File Nos. SAT—LOA—19971222—00222,
SAT—LOA—20040322—00234/35/36/37, SAT—AMD—20051118—00243, SAT—AMD—20040719—00141, SAT—
AMD—20040322—00057, SAT—AMD—20031030—00317, and SAT—MOD—200605 11—000577/58/59/60 (Call
Signs: $2346, $2680, $2881, $2682, and $2683) is null and void.

        17.     IT IS FURTHER ORDERED that ATCONTACT Communications, LLC‘s pending
modification applications to relocate a GSO satellite from the §3° W.L. orbital location to 87.2° W.L., and
to add GSO Ka—band frequencies for use at 87.2° W.L. (Call Sign $2680), IBFS File Nos. SAT—MOD—
20070924—00130, SAT—AMD—20071215—00176, SAT—AMD—20080505—00100, SAT—AMD—20080505—
00096; and SAT—AMD—20080930—00195, are DISMISSED as moot.
        18.     IT IS FURTHER ORDERED that ATCONTACT Communications, LLC‘s pending
modification applications to relocate a GSO satellite from the 34° E.L. orbital location to 77.2° W.L. (Call
Sign: $2682), IBFS File Nos. SAT—MOD—20070924—00132, SAT—AMD—20080930—00194, and SAT—
AMD—20080505—00099, are DISMISSED as moot.
        19.     IT IS FURTHER ORDERED that ATCONTACT Communications, LLC‘s bond is now
due and payable to the U.S. Treasury.
        20.     IT IS FURTHER ORDERED that ATCONTACT Communications, LLC‘s pending
modification application specifying the end—of—life disposal plans for its NGSO constellation (Call Sign:
$2346), IBFS File No. SAT—MOD—20080813—00155, is DISMISSED as moot.


                                                  FEDERAL COMMUNICATIONS COMMISSION




                                          f
                                                  P
                                                  o ol
                                                  Acting Chief
                                                  International Bureau



Document Created: 2019-04-09 18:23:41
Document Modified: 2019-04-09 18:23:41

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