Attachment ViaSat - Commission

ViaSat - Commission

REQUEST submitted by IB,FCC

May 9 2013 letter

2013-05-09

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

IBFS_SATLOI2013031500031_997202

                              Federal Communications Commission
                                       Washington, D.C. 20554


                                                May 9, 2013



John P. Janka, Esq.
Latham & Watkins LLP
555 Eleventh Street, NW, Suite 1000
Washington, D.C. 20004

                                                   Re: ViaSat, Inc.
                                                   IBEFS File No. SAT—LOI—20130315—00031
                                                   (Call Sign $2894)

Dear Mr. Janka:

        This letter requests additional information regarding the above referenced Letter of Intent filed by
ViaSat, Inc. In its application, ViaSat seeks U.S. market access using a planned geostationary orbit
satellite, ViaSat—3, which it proposes to operate at the 79.3° W.L. orbital location under the authority of
the United Kingdom. ViaSat states that the United Kingdom authorization for this space station "is held
by ViaSat Satellite Holdings Ltd., a direct, wholly owned subsidiary of ViaSat.""
        Section 25.137(c) of the Commission‘s rules requires operators of non—U.S.—licensed
geostationary orbit—like satellite systems seeking market access to demonstrate that the satellite is in—orbit
and operating, or that the system has a license from another administration, or that the system has been
submitted for coordination to the International Telecommunication Union (ITU).

         ViaSat‘s application fails to include specific information with respect to the authorization held by
its subsidiary, nor does it indicate whether the United Kingdom has submitted filings on its behalf to the
ITU. Accordingly, ViaSat must address in greater detail the status of its U.K. authorization for the
ViaSat—3 space station. In particular, please state whether ViaSat has obtained launch and space
operations licenses for ViaSat—3 under the U.K. Outer Space Act. If not, ViaSat should provide a
statement detailing the status of the application process for the license and an assessment of whether, by
virtue of its wholly owned subsidiary and any other factors considered relevant under the U.K. Outer
Space Act, it has sufficient ties to the United Kingdom to provide the basis for issuing such
authorizations. In providing this assessment, ViaSat should identify the specific provisions of the U.K.
Outer Space Act and the Space Agency‘s implementing guidance on which it is relying. ViaSat should
also indicate whether filings have been submitted to the ITU on its behalf for the space station and
provide documentation from an appropriate U.K. official regarding any such filings.




‘ ViaSat, Inc., IBFS File No. SAT—LOI—20130315—00031, at 8.


         Please file the requested information within 30 days of the date of this letter, with a courtesy copy
to Alyssa Roberts of my staff. Failure to respond by this date may result in dismissal of the Letter of
Intent pursuant to Sections 25.112(c) and 25.152(b) of the Commission‘s rules."



                                                   Sincerely,



                                                   Fern J. Jae‘mu nek
                                                   Acting Chief, Satellite Division
                                                   International Bureau




247 C.F.R. §§ 25.112(c) and 25.152 (b).



Document Created: 2013-05-09 15:24:04
Document Modified: 2013-05-09 15:24:04

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