ViaSat 79 Supplement

SUPPLEMENT submitted by ViaSat, Inc.

Supplemental Letter

2013-11-22

This document pretains to SAT-LOI-20130315-00031 for Letter of Intent on a Satellite Space Stations filing.

IBFS_SATLOI2013031500031_1028687

                                                                  555 Eleventh Street, N.W., Suite 1000
                                                                  Washington, D.C. 20004-1304
                                                                  Tel: +1.202.637.2200 Fax: +1.202.637.2201
                                                                  www.lw.com

                                                                  FIRM / AFFILIATE OFFICES
                                                                  Abu Dhabi       Milan
                                                                  Barcelona       Moscow
                                                                  Beijing         Munich
                                                                  Boston          New Jersey
                                                                  Brussels        New York
                                                                  Chicago         Orange County
                                                                  Doha            Paris
November 22, 2013                                                 Dubai           Riyadh
                                                                  Düsseldorf      Rome
                                                                  Frankfurt       San Diego
VIA ELECTRONIC FILING                                             Hamburg         San Francisco
                                                                  Hong Kong       Shanghai
                                                                  Houston         Silicon Valley
                                                                  London          Singapore
Ms. Marlene H. Dortch                                             Los Angeles     Tokyo
Secretary                                                         Madrid          Washington, D.C.

Federal Communications Commission
445 12th Street, SW
Washington, DC 20554


                Re:       Supplemental Submission; Letter of Intent Application of ViaSat, Inc.,
                          IBFS File No. SAT-LOI-20130315-00031, Call Sign S2894

Dear Ms. Dortch:

        ViaSat, Inc. (“ViaSat”) is writing to provide additional information regarding the legal
authority under which the launch and physical operation of the ViaSat-3 satellite will occur. As
explained in ViaSat’s June 6, 2013 response to the Commission’s request on that issue, sufficient
contacts with the United Kingdom will exist to provide the UK Space Agency with jurisdiction
over such matters.

        ViaSat intends that its wholly-owned United Kingdom subsidiary, ViaSat UK, a company
formed under the laws of England and Wales and based in Wareham, Dorset, England, will
procure the launch, and also will have control over the tracking, telemetry, and command
(“TT&C”) functions, of the ViaSat-3 satellite. Thus, the U.K. Outer Space Act of 1986 will
apply to ViaSat UK’s “launching or procuring the launch of a space object” and “operating a
space object.” 1 The Act applies to these activities “whether carried on in the United Kingdom or
elsewhere” by U.K. nationals, such as ViaSat UK. 2

       Furthermore, ViaSat UK is an integral part of ViaSat’s global enterprise and is directly
involved in the delivery and marketing of ViaSat’s satellite services in the U.K. and through
Europe. Among other things, ViaSat UK markets and delivers to the U.K. government and
business interests a variety of satellite communications solutions, including mobile, transportable



1
        See Outer Space Act, 1986 c. 38, § 1(a), (b) (U.K.).
2
        Id. at §§ 1, 2.


DC\2912960.1


Ms. Marlene H. Dortch
November 22, 2013
Page 2




and fixed broadband solutions at Ka band. Moreover, ViaSat UK’s management has a
significant overlap with that of ViaSat, Inc.

       If you have any questions regarding this submission, please feel free to contact the
undersigned.



                                             Respectfully submitted,

                                                     /s/

                                             John P. Janka
                                             Elizabeth R. Park

cc:       Jose Albuquerque
          Cassandra Thomas
          Fern Jarmulnek
          Karl Kensinger
          Andrea Kelly
          Kathyrn Medley
          Chip Fleming
          Kal Krautkramer
          Alyssa Roberts




DC\2912960.1



Document Created: 2013-11-22 16:03:10
Document Modified: 2013-11-22 16:03:10

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