Attachment reply

This document pretains to SAT-MOD-20031118-00333 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2003111800333_412649

Received RECEIVED s 208 inelert 86. JAN —5 2005 AN 0 6 "Whoerat, COMMUNICATIONS COMMISSION Wasimwaton, D.C. 20554 Fadena Commnicaton Comniaron oifcef Secniy w °0 _ ) File Nos. SAT—MOD—20031118—00333 Applications of ) SAT—AMD—20031118—00332 Mobile Satellite Ventures Subsidiary LLC ) SES—MOD—20031118—01879 RerLy Inmarsat has asked the Commission to review the Bureau‘s grant of an ATC license to MSV which, ifnot reversed:() will cause harmfulinterference into Inmarsat spacecraft by authorizing a 402 increase in the number of ATC mobile terminals,(i) will "endanger" Inmarsatsafety services, and "seriously degrade and obstruct" other Inmarsat services,‘ by allowing a 6x increase in ATC base station power and thereby disrupting MSS service around tens of thousands ofATC base stations, and (ii) shifls the burden to MSS, the primary service, to resolve interference from ATC, the secondary service. In its Opposition, MSV confirms that its licensed ATC system will iferfere with nearby Inmarsatterminals," and admits ts intention to deploy an ATC system capable ofserving fens of" millions ofterrestrial users (MSV Opp. at S,15—16). MSV admitted in a meeting yesterday with DOD and the FCC that it plans to deploy ATC transmitters on existing cellular and PCS tower sites. MSV‘s confirmation about the expected scale ofits terrestril network makes even more critical the Bureau‘s failure to enforee the requirement that ATC terminals constrain intererence into MSS spacecraft by substantially reducing power when operating outdoors. MSV grossly mischaracterizes the Inmarsat—4 program and Inmarsat‘s BGAN service, by falsely equating the transitional RBGAN service with theforthcoming BGAN service . Regional ! See 47 CFR 2.1 (definition of"harmful nterference") * Inmarsat‘s Technical Annex, attached as Appendix A hereto, responds tothe Technical Appendix in MSV‘s December 23, 2004 Opposition. ? A point—by—pointrebuttal of a number of MSV‘s distortions is attached as Exhibit 1.

BGAN (or RBGAN) service is a developmental offering over a Thuraya satellite that does not even see North America. BGAN is an entirely new and completely different broadband MSS service. BGAN (i)uses new spacecraf, (i) employs completely different user terminal technology, i) provides three times the transmission speeds, (iv) offers significantly enhanced user functionalities, and (v) has new RF characteristcs, pricing and service offerings Ubiquity is a hallmark of MSS service. The new 1—4 network and BGAN service are designed to meet the expectations of MSS users of service capabilty "anywhere and any time," as reflected in the record," and to provide the recognized public policy benefits of MSS to U.S businesses and consumers nationwide.* Inmarsat has met the needs of MSS users for over 23 years, constantly improving its service, and developing a successful commercial business, and is now able to launch a new MSS system optimized for high—speed data services to small mobile terminals (rates of up to 432 kbps}.. This new system will, for the frst time, enable critical broadband connections for mobile users, governmental, militry, public safety, humanitarian, and commercial alike, "anywhere and any time." MSV,in sharp contrast,has apparently not found a successful commercial formula for MSS, and therefore seeks to compete directly with terrestrialcellular and PCS voice services Maximizing spectrum efficiency was a key design element of the 1—4 MSS network. The spacecraft design reflects this, with 228 spot beams, and 13x the current level offrequency reuse.® BGAN terminals similarly have been optimized for high—throughput data services, using ms and MarineSat (Dec, 23, 2004); Letter from IMSO (Dec. 17, 2004); Leter from Ofcom (Dec. 20, 2004); Letter rom Telenor (Dec. 20, 2004); Letter from Nera (Dec. 23, 2004); Letter from Satcom Direct (Dec. 8, 2004); Letter from GMPCS Personal Communications (Dec. 20, 2004);Letter from Global Communications Solutions (Dec. 16, 2004); Letter from AOS (Dec. 20, 2004); Letter from Glocom (Dec. 15, 2004) * See In re Establishment ofPolicies and Services Rulesfor MSS in the 2 GHz Band, FCC 00—302 at 11 (rel. Aug, 25, 2000) (recognizing that MSS enhances comperition with errestril communications services and provides important benefits to all U.S. consumers nationwide), *1—4 spacecraft can share even more spectrum with MSV than before. The Commission should not countenance MSV‘s warchousing of L—Band spectrum orallow MSV*s use ofa two—decade—old

a state—of:the art modulation scheme (16QAM with Turbo Coding) that maximizes performance over the limited spectrum resource. This advanced system design supports a substantially arger Inmarsat MSS customer base, including in the United States," Now six years in the making, and developed in reliance on longstanding allocations governing the L—Band and the February 2003 ATC rulemaking decision, the 1—4 system is a reality. The first spacecraft is being shipped in less than a month for a launch from Florida on March 10, 205. ‘The second spacecraft—planned to serve North America———is undergoing testing, and is scheduled for launch in July of this year. The third spacecraft, to be maintained as a ground spare untl the successful launch of the other two, is about to commence tests, and is scheduled to be available for Iaunch by January 2006, when it could be placed into a number of Jocations to serve the U.S.° To facilitate the deployment ofbroadband MSS data services, Inmarsat has developed new, lightweight, and low—cost BGAN anternas, some as small as 5.5"x 8", and some with "tracking" antennas never possible before in such a small and inexpensive MSS terminal." Those smaller, more affordable, and more functional MSS terminals are particularly suited for cars, trucks and aireraft that will operate in the vast parts of the US———including urban and suburban areas———where there are simply no constraints on the location of ATC base stations. MSV argues that "market forces" somehow will obviate the potential for ATC interference into MSS, because MSV asserts there will be no overlap between MSS and ATC satelite design to serve as a barrier to more efficient MSS use of the L—Band. MSV‘s latest replacement satellte design is at least 4—5 years away from ever being realized. " MSV‘s estimate ofthe number of supportable 1—4 users has no basis and does not reflect reality. * The need to take it account the locations ofthe 1—4 spacecraft is supported by the recognition that the Commission‘s ATC interference analysis must consider all L~Band networks in the ITU quene. In re MSY, DA 04—3553 (rel. Nov. 8, 2004) at 163. * MSV‘s arguments that BGAN terminals will be the equivalent ofSS and thus not entiled to interference protection therefore are misguided. MSV Opp. at n.27. Anticipating these new MSS antenna technologies was the reason the Commission did nor exempt all BGAN terminals from E91 1 requirements. See MSS 911 Report and Order, 18 FCC Red 25340 (2003), at 128.

service areas. This is flatly contradicted by the record."" Moreover, even MSV does not dispute that satelite service in urban areas is technically feasible, or that the Bureau was wrong when it assumed that an MSS satellite signal will not be "usable" in the vicinity of an ATC base station. MSV‘s assertion that the urban usage ofMSS will be lower than the urban usage of DBS or FSS because there is less MSS bandwidth available is nonsense and it misses the point. The ESS and DBS experience demonstrates thatsatellite service is used in urban areas, particularly where it offers important advantages. This is true for Inmarsat‘s —4 network, which offers the significant advantage of ubiquitous coverage~——service any time, anywhere—and reliable, high— speed connectivity thatis independent ofthe vulnerable local phone and power networks. Indeed, MSV provides a litany ofexamples where first responders rely on MSS terminals in urban environments for these very reasons. MSV Opp. at 13—14. Moreover,the pricing ofthe transitional RBGAN service compares favorably to the roaming charges for GPRS, terrestrial data service;"" BGAN service will be priced even lower. Thus,it is regulatory actions in the U.S—relaxations of ATC rules that will cause harmful interference into MSS, and continued ORBIT Act imitations on "advanced services"~—— that threaten to constrain the growth of new Inmarsat land mobile services in the U.S. Admitting that its ATC network poses an interference threat to MSS, MSV tums to new policy issues, urging the Commission to require that Inmarsat terminals be made like PCS or cellular handsets, to overcome ATC interference. This radical suggestion ignores the realities that () MSS satellite terminals are carefully designed to operate with low noise so they can be sensitive enough to communicate with their "base station" located 22,300 miles away, (i) MSS satelliteterminals are fundamentally different than PCS terminals, (ii) over 350,000 Inmarsat terminals already have been commissioned at an estimated investment of over $3 Billion and ‘* See comments and leters cited in note 2. "‘ See Exhibit 2.

cannot be retrofited, and (iv) t is disingenuous for MSV to assert that Inmarsatand ts manufacturers in the 11" hour ofa 6—year, S1.5 Billion program can change system designs and hardware on which they have proceeded in reliance on longstanding regulatory structures, and the February 2003 ATC rulemaking order,in favor of an ATC system still on drawing board and that may never be realized. While MSV must overcome significant financial, technical and other implementation hurdles before ts ATC network becomes operational, the first 1—4 spacecraft will be launched in the next rwo months. Ifthere are changes to be made in the way ATC is accommodated in the L—Band, MSV has the fexibility to make those changes, not Inmarsat."" MSV eannot have its wish that the L—Band be treated like other MSS bands: (i there is a shortage ofL—Band MSS spectrum, (i) the L—Band is shared on a co—channel basis (not segmented), and (ii) billions have been invested in reliance on longstanding allocations governing the L—Band. Once MSV acquires the TMI 2 GHz MSS license, MSV can deploy an ATC system in the "ereenfield" at 2 GHz, without any of the constraints MSV complains ofin the L—Band. 2 GHz is where MSV‘s experiment with a vastly different concept ofATC—with tens of millions of users———should be conducted, not in the heavily utiized L—Band. For these reasons, the Commission must protect Inmarsat‘s 1—4 system from ATC interference, and must reject MSV‘s proposal that Inmarsat,its distributors, manufacturers, and users bear the burden of resolving ATC interference.. As demonstrated in the record of this proceeding, the critical and sensitive nature of many uses of the Inmarsat system, and the seted expectations that ubiquitous MSS service will continue to be available to serve those needs, must be protected. Therefore, the Commission must follow its February 2003 ATC rulemaking order, and ensure that ATC does not cause harmfulinterference o the Inmarsat MSS system. "* Inmarsat has met with MSV to discuss the interference problems posed by MSV‘s ATC system. But MSV has not made any concrete proposals, MSV‘stechnical analyses were not conclusive, and MSV insisted on Inmarsat making system changes to accommodate MSV‘s ATC system

Respectfullysubmitted, January 5, 200

Exhibit1 MSV Misstatements: "BGAN service costs over one hundred times more than a faster terrestral wireless service, ata whopping S1 /megabyte (compared with $0.08/megabyte for existing terrestral service)." "There is simply no demand for expensive and unswieldy land— transportable MSS terminals when wireline providers,terrestrial wireless providers and even Fixed Satellite Service (‘FSS") operators offer the same service at significantly lower prices." MSV ativ, 11, 12. Eaets: BGAN service is not yet offered, and when it is offered, this 432 kbps broadband service will be competitive with third generation terrestrial wireless networks (3G) in terms of both price and service quality.. This cited rate is the average current retail price for the transitional Regional BGAN service, which compares favorably with 3G (or 2.5G/GPRS) roaming charges for terrestral wireless through providers such as Vodafone. See Exhibit 2. Wholesale Regional BGAN airtime is being reduced in some geographic areas by over 40% as part of a program where Inmarsat is seeking to replace a single global rate with pricing reflective ofthe local competitive environment. BGAN service will be even less expensive. MSV Misstatements; "BGAN equipment is priced at about $1600,is big and bulky, and requires precise pointing and line ofsight to a satellite." MSV atiiv, 11. Eaets: BGAN terminals have not yet even been introduced. Regional BGAN terminals are available for ess than $500 as part of a 12 month service commitment. Inmarsat‘s BGAN terminals will be as small and easy to cany, and will have ISDN, Bluetooth, USB, Ethemnet and Wi—Fi connectivity. One ofthe smallest BGAN terminals will be about 5.5" by 8", and will appear as follows. Reviews of Regional BGAN terminals comment favorably on ease of use and set up, and forthcoming BGAN terminals will be even casier to use: * "It takes seconds [to set up} and seems foolproof. Once thisis done, and the BGAN has logged into the satellite network, you have a TCPP network connection — it‘s that simple." Jon Honeyball, Pumarsat Regional BGAN Satellite IP Modem, PC Pro, February 2003, at 195.

* "It doesn‘t require a PhD to plug it init‘s justlike a voice modem, only it‘s a small box instead ofa wire." Lindsay Nicolle, Dish ofthe Day, INTERNET WoRLD February 2003 at 35. MSV Misstatements; "Even Inmarsat‘s CEO has predicted that Inmarsat will experience no more than single—digit growth in the minimal expected BGAN penetration in the United States." (MSV at 11, citing Communications Daily (August 25, 2004)) Eaets: This is a misrepresentation ofthis article, which describes the situation today, with ORBIT restrctions in place: "Sukawaty said only 0.5% ofthe company‘s revenue (associated with U.S. terminals for land—based services) would be impacted ifthe company were found not compliant with the [Orbit] Act: ‘The immediate impactis fairly minimal, but we want to be Hicensed for land—based services in the U.3."" (emphasis supplied). There is no reason to believe the U.S. portion of Inmarsat‘s land mobile business will not increase significantly once BGAN is introduced and related ORBIT Act restrctions are lifed. For the nine—month period ended September 30, 2004, land mobile services accounted for 29.3% of Inmarsat‘s global revenues.

Exhibit2 Aftached is a summary of errestrial roaming charges for mobile internet access, as of August 2004, almostall ranging from 8 to 17 Euros/mb ($10.80 to $22.95/mb).

INTUG — international mobile roaming prices — GPRS — Olympics 2004 Page 1 of 2 | | August 2004 rN;TU G International mobile roaming in Greece Prices for GPRS NTUG > surveys > gsm > Obmpics 2004 there are also prices for SMG and voice Gountry 1MB |Exchange |Operator| ,U0d Tute home enc |URL (only host shown) Spain vodafone 5.00 Iutps/www.vodafone.es/ [Denmark |sonofon 7.56 7.44]] 5625 itpo//www.sonofondi Ircland [vodafone £.00 \ [nups/Parwwvodafonsie/ uk vodafonc 8.84 0.66]| 5.88)]itpo//wwwvodafone.coutd Hungary __|pannon _| 9.60|_25425]] 2441.40]ntpo/wwwpesmhw/ [Netheriands |itmobite 9.80] J [rtps//ww.—mobile.al/ (Crostia ___|fitmobile]] 9.91 7307320 [Belgium __|fproximus 10.00 hy uk 0; 10.60 0.66] 7.05|itpiliwww,02.could! Singspore _]sinetel _[_10.80] I Intpo/{www.ideassingtel.com Norway ::fb““}c’ 10.7 8.28] 90.00]mtp:/ftelenormobil.no! Spain telefonical] _11.00 https/fwew.movistar.com/ sweden |iB,, 11.00 Intp:/inwtelismobile.se/ uk [cmobite ][_11.28)] ___0.60[ 7.50}[iups/wwe.t—mobile.co.uts [Romania |connex maz]l 123][ 14.01mtp/www.comenro/ [usa Jatws [ _11.65] 1.72] 20.00[itpoiwwwattwireless.com/ [Austia _ _|at 11.s0 Intpo/inewal.neu [Portueat __|foptimus _12.00] Iitpo/{wwwoptimusp¥ usA emobile 1222 1.23]|__15.00 [mttps/wwat—mobile.com/ Switzeriand |sunrise 13.10 1.54)[__ 20.12]/itps/mobile:sunrise.ch/ I I I I I I hitps//www.intugnet/surveys/gsm/olympics/gprs himl usra0os

INTUG — intemational mobile roaming prices — GPRS — Olympics 2004 Page 2 of2 [Bclgium mobistar B31 hittpo/fwerss.mobistarbe/ [Austria lone 13.50 Iitpowers.one.at! (Germany Jitmobite |_13.80) | —mobite [raly wind Intpo/fwereswindi¥ [Austria [cmobite \ [rtps//www.t—mobile. ay [NewZealand]{vodafone 1.88]__ 30.00}/nntps/wwwvodafone.co.nz‘ Italy m Iitpo/fwves privattim i/ xt 5°"®|smmartone 9.68|| 160.00Iitp:/wwwsmartone.comh/ [Austratia __[vodafone | 17.47] 1.72)] 3000 [mnpiiiwwcwvodafone.comaw [Australia Jtelstra 17a7 1.72] 30.00}ntpoliwwntelstra.com.aw [France ___\[bouygues|| _20.00| | Imtp://wwwservicevoyagebouysuestelecomfw France t 24.00 Iitpolheww.stt France lorange _|_25.00] [intpo/fwwrnorange.ff Notes: All data are from public web sites. They confirmed the week ending 21 August 2004. The prices are for Internet access and not special access or tothe "walled gardens® of the mobile network operators. Tariffs used are for monthly subscription (business or the equivalent). The data presented here are intended only for policy purposes and for not the selection ofoperators. Connex in Romania quotes its prices in US$ copyright © INTUG, 2004. hitp:inwintug netsurveysigsm/alympics/gprs himi This page is maintainad by the webmaster Last updated 24 August 2004 hitps\www.intugnet/surveys/gsm/olympics/gprs himl usraoos

Appendix A Technical Annex — January 5, 2005 In this technical annex we respond to the technical points raised in MSV‘s December 23 pleading, which are mainly contained in the Technical Appendix to that pleading." For clarity, the numbering scheme in this technical annex corresponds o that in the MSV Technical Appendix. 3: Impact of Increased ATC Base Station EIRP and Relaxed ATC Base Station Overhead Antenna Gain Suppression on the Downlink Interference into Inmarsat METs MSV has once again failed to adequately address Inmarsat‘s concemns about the downlink interference to Inmarsat‘s METs, which will degrade and obstruct Inmarsatservice by creating tens of thousands of"no—g0" areas around ATC base stations where Inmarsatterminals will no longer work, but where Inmarsat users expect to be able to receive interference—free service. A.— Appropriate Propagation Model for Interference from ATC Base Stations to Inmarsat METs MSV asserts that a Walfisch—Ikegami model is the appropriate propagation model to use in all cases when assessing the interference from ATC base stations to Inmarsat receivers. Inmarsatdisagrees, as explained in its December 8 Application for Review, and believes that there are many scenarios of ATC base station deployment where a free—space line—of—sight propagation model is appropriate, and should be used to assess the required separation distances * This is particularly true as MSV extends ts base stations outside of the "high—rise" urban centers into "low— rise" urban and suburban areas — scenario that is inevitable given MSV‘s stated desire to deploy ATC through the very same tower sites used to provide cellular and PCS service. MSV also implies that Inmarsat is inconsistent insofar as its following two claims are concemmed: (@ the relaxation in ATC base station EIRP limit will result in harmful interference into Inmarsat METs at relatively large distances from ATC base stations where there is line—ofsight between the base station and the Inmarsat MET. (b) high levels ofblockage between ATC terminals and the ATC base station could force many MSV ATC terminals to ransmit at high EIRP levels and thereby : Opposiion afMSV to the Application for Review ofInmarsat, December 23, 2004 + Inmarst‘s tionale fo thii filly explained i Secton 1.2 oftTechnical Amnex t Inmrsr‘s Applcation for Review, December8, 2004

cause higher levels of interference to Inmarsatsatellites than the Commission has calculated These two claims are not inconsistent atall. In reality both situations will occur. The point is thatsituation (a) leads to worse downlink interference tInmarsat and of course occurs closer to the center of an ATC cell (e., nearer to the base station). Situation (b) leads to worse uplink interference t Inmarsat and is ikely to occur more when MSV‘s ATC MTs are located towards the edge of an ATC cell, well away from the base station. Neither is an acceptable situation and each will lead to harmful interference into the Inmarsat system Regardless of what propagation model is valid,it remains a fact that an 8 dB increase in ATC base station EIRP will significantly increase the size ofthe harmful interference zones around ATC base stations." B. The Combined Effect of Relaxed ATC Base Station Overhead Antenna Gain Suppression and Increased ATC Base Station EIRP Limits on Interference to Inmarsat‘s Acronantical METs In the record ofthis proceeding Inmarsat has repeatedly voiced its serious concerns over the harmful interference that would occur to Inmarsat receivers operating on aircraft, particularly as those aireraft are at the critical tage of flight on take—off and landing flight paths. In its atest pleading MSV states that Inmarsat‘s analysis of this interference mechanism for a single ATC base station interfereris incorrect and that MSV‘s own analysis shows that an aireraft fying at 65 meters altitude maintains more than 6 dB margin against harmful interference as it passes over an ATC base station. Further, MSV asserts that, as the horizontal distance between the aireraft and the ATC base station increases, the interference margin increases rapidly.. As demonstrated below, MSV‘s calculations are incorrect,and its presentation of the data is misleading. As an inital matter,and as Inmarsat has repeatedly expressed in the past, —50 dBm is the wrong interference threshold to use for assessing ATC interference into acronautical receivers. The ~50 dBm value was derived from the non—mandatory ARINC Characteristic 741 for the LNA compression point. However, saturation ofthe LNA is not the limiting factor. Other stages or components of the receiver chain down—stream from the LNA are likely to be susceptible to saturation and intermodulation product generation at a significantly lower level. It should be stressed that the ARINC Characteristics are not mandatory requirements. They are voluntary avionics implementation guidelines developed by the Airlines Electronic Engincering Committee (AEEC) primarily to foster equipment interchangeability among different suppliers. ‘The relevant interference threshold is derived from the mandatory interference susceptibility requirement as presented in RTCA DO—210D, section 2.2.4.1.3, as Honeywell has explained and as Inmarsat has expressed in previous pleadings." Moreaver,the FAA‘s Technical Standard Order (TSO) C—132 (attached as Annex A) presents the minimum requirements for certification * Using the W—I LOS propagation modethe require separtiondistnce will doubl, and the are aifected inerease by fouimes, asa resiltofth 8 dB increase in ATC base sution EIRP. Usinga freespace in o—sigh modelth ditance willinerease by 2. imesand tharen affectd willincreas by 625 times + OppositionoIemarsat, March 25, 2004 at 48& Appendix C

of Inmarsat acronautical terminals and that TSO is entirely reliant on the RTCA requirements Using the correct specification, the relevantinterference threshold level is 72 dBm, which will result in a substantial increase in the calculated aireraft altitude and horizontal distances where service to Inmarsat acronautical terminals will b disrupted by ATC interference. The terms of MSV‘s ATC license, and the protectioncriteria in the ATC rules, must be modified totake into account the correct interference criteria Turning to MSV‘s new analysis, MSV‘s results are summarized in its table which is reproduced below: MSV‘s Analysis of AMS(RJ Receiver Trajectory over one ATC Base Station Emitting32 dBW ETRP per Sector and using the Relazed Overhead Gain Suppression Pattern (AMS()S Receiver at 68 Meters Altitude; Base Station Located at %, ¥ = 00 k) x 5 Ti e +2 +s s es os es s 22| 2s k 1 ¥ 5[ 5| e 22 +s s os as os s 22| ra e k over Leverigem 5o 5o 50 50 5o 5o s o sn 5o se s| 40 5o Zog Ree So sn |—ons |—ora |—aa 7| —aa 0 —ana se s al se l se 7| —ara| sn 0 e 7| w2 ma‘ Magi e ___|nest] 22} ts 7| is o i as} a o sar o ar o 1e i as o wo is m 2e na s From this table MSV concludes that when the aireraft is horizontally close to the ATC base station (%e., within 300 meters) the margin is 6.87 dB, and that the margin increases to 18.51 dB for horizontal distances of4 km. Unfortunately, although MSV liss ts assumptions used in this analysis, it does not provide the calculations that support these results. Inmarsat has been unable to replicate these results, as explained further below. MSV‘s assurmptions used in its analysis are as follows: (2) ATC base station antenna height is 30 meters above the ground; (b) 4 dB interference reduction due to voice activity; (€) 5.2 dB interference reduction due to power control; (d) AMS(R)S antenna gain is 0 dBi; (€) ATC base station down—tlt angle is 5%; (D No shielding due to aireraft body; (&) 0 dB polarization discrimination. Using these assumptions, Inmarsat‘s interference calculations, for the simple case ofthe aircraft immediately overhead the ATC base station, are as follows® ATC base station peak EIRP per sector Inmarat hs alsoanalyzed thinterferencefor allirerat brizontl poitonsrlative to the ATC base sttions, but is demonstatingthis one caleultion for claiy.

=+32 dBW (Le., 8 dB increase over the value in the ATC rules) Gain suppression towards aireraft (at 2enith) =30 dB (ie., using the relaed overhead gain suppression mask) ATC base station EIRP per sector towards aircraft =+2 aBw Distance between ATC base station anterna and aireraft at zenith = 35 meters (Le., 65 meters altitude less ATC antenna height of30 m) Spreading loss from ATC base station antenna toaircraft = 10 log (4 135?) =41.87 dB Effective aperture of 0 dBi receive antenna at 1.5 GHz G2*/ 4 x=0.003183 m —25.0 dB—m‘ Interfering signal power at Inmarsat receiver (per sector) =+2 — 41.87 —25.0 —4 — 5.2 = —74,07 dBW = ~44.07 dBm This shows there is a problem. The resulting interfering signal power is approximately 6 B higher than the assumed overload threshold, and therefore the margin is nesative 6 dB and not positive 6.87 dB. This represents a significant difference from MSV‘s results. In fact the altitude would need to be increased to 100 meters, using this same analysis with identical assumptions as MSV, to get zero interference margin, and 182 meters altitude to get the positive 6.87 dB margin that MSV indicates.® Inmarsat ialso unable to confirm MSV‘s assertionthat ®... as the horizontal distance between the aircraft and the ATC base station increases, the interference margin increases rapidly ...". Because of the nature of the proposed ATC base station antenna overhead gain suppression mask, the zenith situation is not the worst case in terms of interference margin, as Inmarsat has shown repeatedly in the past. ‘The figure below shows the margin, relative to the assumed interference threshold of —50 dBm, for a range of horizontal distances, and using the same calculation methodology and assumptions as described above." Note that the margin is 6 dB at zero horizontal distance (as shown above), but the margin then becomes positive before then going negative again, reaching a worst—case of —9.2 dB at around 425 meters from the base station. Clearly this shows a result that is completely different from what MSV asserts. The significance of this is that the worst—case interference is not when the aircraftisimmediately over f Tnmarsat ha usedtheassurmptions proposed by MSV for this analysi, which are ot thesame as Tnmarsat‘s own assumptionsused in the past ‘Theseresults have been obtsined by systematcally varying the horizonta distance from zero o 2400 meters,and calcultingthe corresponding rangedistnce and hence spreading losforeach case In addiin, for each case th approprite ATC basestation antenna gain is calculatebased on the angular offict elativ o peak gain

the ATC base station, but when it is some distance (425 meters for the particular assumptions used here) horizontally away from the base station. Thus, MSV‘s analysis is not only incorrect in the calculated values, but also appears misleading in the way the results were presented in tabular form, where the true shape ofthe margin curve has effectively been concealed by appropriate choice of horizontal spacing values in the MSV table. we, 88 $ $8 is 28 4 BB sho § & = Horizontal Distance of Aircraft from Base Station Transmitter (m) MSV‘s analysis, as well as the analysis presented above, only takes account of the interference from one sector of the ATC base station antenna.. Although this may be appropriate for situations where the aireraft is a large distance horizontally from the base station, it certainly is not the case when the aireraft is close to being overhead relative to the ATC base station. In these situations the interfering power ofall sectors should be added together to assess the interfering power to the Inmarsat receiver. In the case of an ATC base station with three sectors, this would be a 4.77 dB increase in interference, or reduction in interference margin, resulting in a 73% increase in the required separation distances relative to those calculated in this Technical Annex. Furthermore, itis highly questionable whether the voiceactivity interference power reduction (4 dB) and the power control reduction (5.2 dB) are appropriate for the case ofa single ATC base station. The Commission included these factors when assessing the impact ofa large number (1000) of ATC base stations, based on the statistial effect of these mechanisms over a large number ofchannels, and MSV has assumed that they apply equally well t the case of a single ATC base station. The voice activity power reduction would be approximately zero for data communications, which is a growing type oftraffic on mobile communications systems. Similarly, when a base station is communicating with a disadvantaged ATC user, there will be no power control reduction. These two factors amount to 9.2 dB, which is a 2.9 times increase in

the required separation distances to avoid harmful interference. This needs to be taken into account when assessing the size of the zones around ATC base stations where ATC interference will preclude or disruptInmarsat MSS service. . MSV‘s Proposition that Inmarsat Overcome Downlink Interference by Changes to the Inmarsat Receivers, and by the Use of Power Control Admitting that its ATC network poses an interference threat to Inmarsat, MSV urges the Commission to require that Inmarsat terminals be made like PCS or cellular handsets, s they can overcome the effects of ATC interference. MSV proposes that simple dual conversion heterodyne receivers are the solution to the problem. This suggestion ignores the following realities: (i) Satellte receivers are designed with great emphasis on minimizing front—end noise so that they can be highly sensitive to reeeive very weak signals from their "base station" located 22,300 miles away; (ii) This low—noise requirement is fundamentallydifferent from PCS terminals which do not require such high sensitivity because they are able to use base station power control to combat interference; (ii) Inmarsat‘s terminal manufacturers would be required to carry out lengthy research on new and innovative technologies for effectively dealing with the interference that Inmarsat terminals will be subject to when in the proximity ofthe high~ powered ATC base stations, that do not comply with the February 2003 ATC rules; (iv) Thover 350,000 Inmarsatterminals that already have been commissioned at an estimated total investment of more than 53 billion cannot be retrofited; (¥) ts far too late to suggest that Inmarsat change a system design on which it has proceeded in relianceon the February 2003 issuance of ATC rules by the Commission, in a proceeding that started almost four years ago in 2001. (vi) In proposing that Inmarsat use power control to combat downlink interference into Inmarsat terminals, MSV, despite being an MSS operator, fils t acknowledge that the primary driver for the introduction ofa power control mechanism in MSS systems, and the way in which the downlink power control system operates. Downlink power control is used to minimize satellite power to the level actually required depending on the link characteristies. It cannot be used to overcome the high levels ofATC interference, including receiver saturation, that would occurin the vicinity of ATC base stations. In view of the above, and considering that ATC has not yet been implemented, it begs the question ofwhy MSV is not willing to explore what it can do to modify its ATC implementation to limit interference, for example, by the use of a MSS operation detection mechanism in the

neighborhood of ATC base stations, which can be used to limit, on a dynamic basis, the base station transmitted power ofthe relevant sector in which the MSS terminal may be operating. 11. Uplink Interference to Inmarsat Satellites The Commission‘s February 2003 ATC order assumed that the average equivalent outdoor EIRP of all ATC terminals will be atleast 20 dB below maximum EIRP." There is simply is no evidence that the MSV ATC system is consistent with this assumption. As a result, there is no assurance that Inmarsat spacecraft will be protected from uplink interference from ATG, as assumed in the February 2003 ATC Order. ‘This is demonstrated below MSV quotes its August 31, 2004 ex parte as evidence that it will achieve an interference reduction factor of 20 dB due to power control. The key parameters ofMSV‘s GSM link budget are shown below. [Required soiropic power atbase sation anena aow 160 Maximem MEiRP aow |_o imictral atiemuation margin «s is [opnormal margin as 7 athloss to clledge (S% Po) as iss ellradius with Cost 2317ata model im 10 The EIRP at the cell edge (for 75% coverage) can be calculated to be —25 dBW from these parameters. Also, based on the charaeteristics of the cell it can be estimated that the average range taper is 3.6 dB. Hence, the MT EIRP required for 75% coverage within the cell is ~28.6 dBW. Finally, based on the lognormal margin assumed, the standard deviation of the distrbution can be calculated as 10.4 dB. With this information we can produce the distribution of EIRP levels in the cell. In doing this we take into account that the EIRP range is —30 dBW to 0 dBW. The EIRP distribution is shown in the following figure. * Fledblityor Delivry of Communication by Mobil Satlite Service Providers n the 2 GHts Band, e L—Band, and the 1.62.4 GHz Bands, 18 ECC Red 1962 (2003), Emate, 1B Docket Nos.O1—185 and 02—361 (rl. March 7, 2003), on reconsideration, PGC O3—162 (rl. uly3,2003) (be "ATC Order®)at 2152 (Appendix C2 §13.5)

ason. ason so a aso wr eme com The average EIRP from this distrbution is ~17.5 dBW, ie. 2.5 dB above —20 dBW. 1t should be noted that in this example we have used the maximum EIRP of0 dBW as specified by MSV in its link budget. If the maximum EIRP instead were —4 dBW (due to an average antenna gain of—4 dBi) there would be no significant difference. The minimum EIRP would become —34 dBW, the distribution above would be shifted by 4 dB and, to comply with the 20 dB power control margin, the required average EIRP would be —24 dBW. The main difference in this case is that MSV would be required to reduce the size ofthe cell to maintain the same link margin. In MSV‘s example link budget the average path loss at 1 km distance is given as 135 dB compared to the free—space loss 0f 97 dB. Hence, the MSV link budgetincludes a 38 dB margin with respect to free—space conditions, but does not satity the assumption that the average equivalent outdoor EIRP ofall ATC terminals will be atleast 20 dB below maximum EIRP. ‘The margins and average EIRP would vary depending on the specific characteristics ofthe cell and depending on the design techniques that are employed by MSV, but t is clear from MSV‘s example that significant care has to be taken to ensure that the average EIRP is kept at least 20 dB below maximum. Certainly, the need to control ATC emissions toward MSS spacecraft is much greater than the need to simply "ba licensees from extending a base station‘s coverage area to such an extent that a mobile terminal atthe edge ofthe area would have to transmit at EIRP higher than —18 dBW merely to overcome free—space loss", which is the only significance the Bureau places on the 18 dB structural attenation margin requirement. (MSV Order at 33) Based on the Bureau‘s interpretation of the 18B structural attenuation requirement, MSV could deploy cellsthat require an MT to transmit at 18 dB below maximum EIRP only when the MT is at the edige ofa cell and has line—of—sight to the base station. Under this approach, all MTs that do not have line—of—sight to the base station would be allowed to increase the EIRP above this evel. Such a result is antithetical to the interference calculations underlying

the February 2003 decision to authorize ATC on a secondary, non—harmfulinterference, basis. As demonstrated in Inmarsat‘s Application for Review — this interpretation would result in an average MT EIRP far sbove what was assumed in the Commission‘s original ATC interference analysis, and it therefore cannot be reconciled with the February 2003 ATC decision. Although it is evident from the above discussion that a cell in an urban area that is designed to require an MT EIRP 18 dB below maximum for ine—of—sight conditions atthe edge ofthe cell would leave significant holes in the coverage, there may stll be cases where MSV would decide thatit is in its best interest to do this. For example, this would be a method to extend the size of cells atthe edge of ATC coverage areas. Most importantly, there are many intermediate cases between the "minimalist" design required based on the Bureau‘s interpretation of the structuralattenuation rule and the near—ideal coverage case shown in MSV‘s Hink budget. MSV may well choose to deploy such intermediate cell designs, and i it does they would eause much more interference to Inmarsat than the FCC intended. As even the near—ideal case fails to meetthe intent of the rule to limit the average MT EIRP, there is little hope that MSV will voluntarily go to the trouble needed to protect Inmarsat‘s satelltes. For these reasons, Inmarsat continues to urge the Commission to ensure that the average MT EIRP ofthe MSV ATC system is at least 20 dB below maximum EIRP.

10

Department of Transportation TSO—C132 Fodaral Aviation Administration Alrcrat Certfcation Sorvice Effectve V Washington, DC Date: 3r25/04 Technical Standard Order Subject: TS0—C132, Geosynchronous Orbit Acronautical Mobile Satellite Services Aircraft Earth Station Equipment 1. PURPOSE. This Technical Standard Order (TSO) is for manufacturers of geosynchronous orbit Aeronautical Mobile Satellite Services (AMSS) Aircraft Earth Station (AES) equipment applying for a TSO authorization. In it, the Federal Aviation Administration (FAA) tells you what minimum performance standards (MPS) your AMSS AES equipment must meet for approval and identification with the applicable TSO marking. 2. APPLICABILITY, This TSO affects new applications submitted after this TSO‘s effective date. 3. REQUIREMENTS, New models of AMSS AES equipment identified and manufactured on or after the effective date of this TSO must meet the MPS in RTCA Document No. RTCAMDO—210D, "Minimum Operational Performance Standards (MOPS) for Geosynchronous Orbit Aeronautical Mobile Satellite Services (AMSS) Avionics," Section 2.0, dated April 19, 2000 to include Change 1, dated December 14, 2000, and Change 2, dated November 28, 2001. a. Functionality. This TSO‘s standards apply to AMSS AES equipment that provides direct worldwide communications between aircraft subnetworks and ground subnetworks using aeronautical mobile satellites and their ground earth stations. AMSS will support both data and voice communications between aireraft users and ground—based users, such as Air Route Traffic Control Centers (ARTCCs) and aireraft operators. Communication services with AMSS fimctions include four categories:_ Air Traffic Services (ATS), Airerat Operational Control (A0C), Aeronautical Administrative Communications (AAC), and Acronautical Passenger Communications (APC). NOTE: We may have more airworthiness requirements for installing AMSS AES equipment intended for ATS communications. Contact your local geographic Aireraft Certiication Office (ACO) for more information. b.. Eailure Condi Classification. Failure of the function defined in paragraphs 3 and 3a of this TSO is a minor failure condition. You must develop the system to at leastthe design assurance level equal to this failure condition classification. c Environmental Qualification. Test the equipment according to RTCA Document No. DO—160D, "Environmental Conditions and Test Procedures for Airbome Equipment," dated July 29, 1997 to include Change 1, dated December 14, 2000, Change 2, dated June 12, 2001, and Change 3, dated December 5, 2002. d.. Software Qualifieation. 1fthe article includes a digital computer, develop the software according to RTCA Document No. RTCA/DO—178B, "Software Considerations in Airbome Systems and Equipment Certification," dated December 1, 1992.

TSO—C132 305704 e. Deviations. We have provisions for using altemmate or equivalent means of compliance to the crieria in the MPS of this TSO. If you invoke these provisions, you must show that your equipment maintains an equivalent level of safety. Apply for a deviation under 14 CFR § 21.609 4. MARKING. a. Mark at least one major component permanently and legibly with all the information in 14 CFR § 21.607(0), except for: (1) Section 21.607(d)(2). Use the name, type, and part number instead ofthe optional model number, and (2) Section 21.607(d)G). Use the date of manufacture instead of the optional serial number. b.. In addition, mark the following permanently and legibly with at least the name ofthe manufacturer, manufacturer‘s subassembly part number, and the TSO number: (1) Each component that is easily removable (without hand tools); (2) Bach interchangeable element, and (3) Each separate sub—assembly ofthe article that you determined maybe interchangeable. .. Ifthe component includes a digital computer, then the part number must include hardware and software identification. Or, you can use a separate part number for hardware and software. Either way, you must include a means for showing the modification status. NOTE: Similar software versions, approved to different software levels, must be differentiated by part number. .. When applicable,identify the equipment as an incomplete system or that the appliance performs finctions beyond those described in paragraphs 3 and 3a of this TSO. 5.. APPLICATION DATA REQUIREMENTS. Under 14 CFR § 21.605(a)(2), you, as a manufacturer—applicant, must give the FAA‘s ACO manager responsible for your facilities, one copy each of the following technical data to support our design and production approval a. Operating instructions and equipmentlimitations, sufficient to describe the equipment‘s operational capability b.. Installation procedures and limitations, sufficient to ensure that the AMSS AES equipment, when installed according to the installation procedures, stll meets this TSO‘s requirements. The limitations must identify any unique aspects ofthe installation. Finally,the Himitations must include a note with the following statement: The conditions and tests for TSO approval ofthis article are minimum performance standards. Those installing this article, on or within a specific type or class of aireraft, must determine thatthe aircraft installation conditions are within the TSO standards. TSO articles must have separate approval for installation in an aireraft The article may be installed only according to 14 CFR part 43 or the applicable airworthiness requirements.

3725704 Tso—Ci32 . When applicable, identify the appliance as an incomplete system or a multi—use system. Describe the functions that the appliance is intended to provide. d. Schematic drawings of the installation procedures. .. Wiring diagrams of the installation procedures. 1. Listof the components, by part number, that make up the AMSS AES system complying with the standards in this TSO. ‘You should include vendor part number cross—references, when applicable. g.. Instructions, covering periodic maintenance, calibration, and repair,for the continued airworthiness of installed AMSS AES equipment. Instructions should include recommended inspection intervals and service life h. Material and process specifications list. i. The quality control system description required by 14 CFR §§ 21.605(a)(3) and 21.143(a),including fimctional test specifications. These test each production article to ensure compliance with this TSO. j Manufacturer‘s TSO qualification test report k. Nameplate drawing with the information required by paragraph 4 of this TSO. 1. A list ofall drawings and processes, including revision level, to define the article‘s design. For a minor change, you only need to make revisions to the drawing listavailable on request m. An environmental qualifieations form as described in RTCA/DO—160D for each component ofthe system. .. If the article includes a digital computer: a Plan for Software Aspects of Certification (PSAC); Software Configuration Index; and Software Accomplishment Summary. We recommend that you submit the PSAC carly in the software development process. Early submittal allows us quickly to resolve issues, such as partitioning and determining software levels 6. MANUFACTURER DATA REQUIREMENTS, Besides the data to be furnished directly to the FAA, a manufacturer must have available for review (by the responsible ACO) the following technical date: .. The functional qualification specifications for qualifying each production article to ensure compliance with this TSO. b. Equipment calibration procedures Corrective maintenance procedures within 12 months after TSO authorization. s m s mos Schematic drawings. Wiring diagrams. Material and process specifications. The results ofthe environmental qualification tests conducted per RTCA/DO—160D

TS0—C132 375704 7. FURNISHED DATA REQUIREMENTS. With each article manufactured under this TSO, provide the following: (1) One copy of the technical data and information specified in paragraphs Sa(1) through (8) of this TSO. Add any other data or information necessary for the proper installation, certifiation, and use, or for continued airworthiness, ofor both, ofthe AMSS AES equipment (2): One copy ofthe data and information in paragraphs Sa(11) through (13),if the appliance performs functions beyond those described in paragraphs 3 and 3a of this TSO. You must send these data to each person receiving one or more of the equipment for use 8. HOW TO GET REFERENCED DOCUMENTS. 2. _You can buy copies ofRTCA Document Nos. DO—210D, DO—160D, and DO—178B, from RTCA, Inc.,1828 L Street, NW, Suite 805, Washington, DC 20036. Telephone (202) 833—9339, fax (202) 833—9434. You can also get copies through the RTCA website @ wirwertea ore b. You can buy copies of 14 CFR part 21, Subpart O, from the Superintendent of Documents, Govemment Printing Office, Washington, DC 20402—9325. Telephone (202) 512—1800,fax (202) 512—2250. You can also get copies fromthe Government Printing Office (GPO), electronic CFR Internet website @ wirwccess.spo.gou/ecf. .. You can get FAA Advisory Circular (AC) 20—110 or the most current revision, "Index of Aviation Technical Standard Orders," and AC 20—115 or the most current revision, "Index of Articles Certified under the Technical Standard Order System," from the U.S. Department of Transportation, Utlization and Storage Section, M—443.2, Washington, DC 20500. Telephone (301) 322—4477, fix (301) 386—5394. You can also get copies from the FAA‘s Regulatory and Guidance Library (RGL) @ wwwairweb.faa.gounel. On the RGL webpage, select "Advisory Circulars." Susan J. M. Cabler Susan J. M. Cabler Acting Manager, Aireraft Enginecring Division Aireraft Certification Service

CERTIRICATION OF PERSON RESPONSIBLE roR PREPARING ENGINEERING INFORMATION Lhereby certify that I am the technically qualified person responsible for preparation of the engineering information contained in the foregoing submission,that Iam familiar with Part 25 ofthe Commission‘s ules, that I have either prepared or reviewed the enginecring information submitted in this pleading, and that it is complete and accurate to the best of my knowledaeand belief. [Ads fasers Richard J. Barmett, PhD, BSc Telecomm Strategies,Inc. 6404 Highland Drive Chevy Chase, Maryland 20815 (301) ase—s9s0 Dated: January 5, 2005

CERtIrICATE or SERVICE 1, Thomas A. Allen, hereby certify that on this Sth day of January, 2005, the foregoing "Reply" was served by hand(*) or via first class mail, postage pre—paid, upon the following: Michael K. Powell® Donald Abelson* Chairman Chief Federal Communications Commission International Bureau 445 12th Street, SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW Washington, DC 20554 Kathlcen Q. Abernathy* Commissioner Bryan Tramont* Federal Communications Commission ChicfofStaff 445 12th Street, SW Office ofChairman Powell Washington, DC 20554 Federal Communications Commission 445 12th Street, SW Michael J. Copps® Washington, DC 20554 Commissioner Federal Communications Commission Shery!J. Wilkerson® 445 12th Street, SW Legal Advisor Washington, DC 20554 Office of Chairman Powell Federal Communications Commission Kevin J. Martin® 445 12th Street, SW Commissioner Washington, DC 20554 Federal Communications Commission 445 12th Street, SW Jennifer Manner® Washington, DC 20554 Senior Counsel Office ofCommissioner Abemnathy Jonathan S. Adelstein® Federal Communications Commission Commissioner 445 12th Street, SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW Washington, DC 20554 Paul Margie® Legal Advisor Edmond J. Thomas® Office ofCommissioner Copps Chief Federal Communications Commission Office ofEngineering and Technology 445 12th Street, SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW Washington, DC 20554 pomnisas

Sam Feder® Roderick K. Porter® Legal Advisor Deputy Chief Office of Commissioner Martin International Bureau Federal Communications Commission Federal Communications Commission 445 12th Street, SW 445 12th Street, SW Washington, DC 20554 Washington, DC 20554 Banry Ohlson* Steven Spacth* Senior Legal Advisor Legal Adviser Office ofCommissioner Adelstein International Bureau Federal Communications Commission Federal Communications Commission 445 12th Street, SW 445 12th Street, SW Washington, DC 20554 Washington, DC 20554 Bruce A. Franca® David Strickland* Office of Engineering and Technology Legal Adviser Federal Communications Commission International Bureau 445 12th Street, SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW Washington, DC 20554 Tra R. Keltz® Office of Engineering and Technology James L. Ball* Federal Communications Commission International Bureau 445 12th Street, SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW Washington, DC 20554 Alan Scrime* Office of Engineering and Technology William H. Bell* Federal Communications Commission International Bureau 445 12th Street,SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW Washington, DC 20554 Richard B. Engelman* ChiefEngineer Chip Fleming* International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12th Street, SW 445 12th Street, SW Washington, DC 20554 Washington, DC 20554 Thomas Tycz* Howard Griboft® International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12th Street, SW 445 12th Street, SW Washington, DC 20554 Washington, DC 20554 pomisa

Karl Kensinger® Billy Cain Intemational Bureau Nera, Inc. Pederal Communications Commission 4975 Preston Park Blvd. 445 12th Street, SW Suite 600 Washington, DC 20554 Plano, TX 75093 Paul Locke® Sue Robinson Interational Bureau AOS, Inc. Federal Communications Commission 17817 Davenport Road 445 12th Street, SW Suite 225 Washington, DC 20554 Dallas, TX 75252 Kathye Mediy® David Greenhill Intemational Bureau Satcom Direct Federal Communications Commission 1901 Highway AIA 445 12th Street, SW Satellite Beach, FL 32037 Washington, DC 20554 J.D. Pan Robert Nelson® Glocom, Inc. InternationalBurcau 20010 Century Blvd. Federal Communications Commission Germantown, MD 20874 445 12th Street, SW Washington, DC 20554 Frank York Global Communications Solutions, Inc. Sean O‘More* 7640 Omnitech Place International Burcau Victor, NY 145649782 Federal Communications Commission 445 12th Street, SW Jerey W. Vonau Washington, DC 20554 International Mobile Satellite Organization 99 City Road Cassandra Thomas® London, BCTY 1AX Interational Bureau United Kingdom Federal Communications Commission 445 12th Street, SW Alfied M. Mamlet Washington, DC 20554 Philip L. Malet Mare A. Paul John Muleta® Steptoe & Johnson LLP Wircless Bureau 1330 Connecticut Avenue, NW Federal Communications Commission Washington, DC 20036 445 12th Street, SW Washington, DC 20554 Counselfor Stratos Mobile Networks (USA) LLC and MarineSat Communications Network, Inc. poviieess

Bob Phillips Lon C. Levin Office of Communications Vice President Riverside House Mobile Satellite Ventures Subsidiary LLC 2a Southwark Bridge Road 10802 Parkidge Boulevard London SE1 9HA Reston, Virginia 20191 Jon Kicin Bruce D. Jacobs GMPCS Personal Communications, Inc. David Konczal 198 Halpine Road, Suite 1318 Shaw Pittman LLP Rockyille, MD 20852 2300 N Street, NW Washington, DC 20037 Bruce Henoch DavidKonczal@shawpittman.com Telenor Satellite Services, Inc. 1101 Wootton Parlcway Counselfor Mobile Satellte Ventures LLC 10° Floor Rocksille, MD 20852 W@ Thomas A. Allen povsisea


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Document Modified: 2005-01-07 15:19:06
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