Attachment ex parte

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

IBFS_SATMOD2003111800333_415559

       ._
W I R E L E S S                                    ’ARTE 0‘          -I=    FILED               Sunrise Teilinology Park
                                                                                                12369-6 SunriseValley Drive
                                                                                                Re5ton.W 20191
                                                                                                www wireleismatrixiorp corn
                                                                                                1: 703.262.0500
                                                                                                F 703.262.0380



    January 13,2005
                                                                  JAN      18   2005

                                                            I FCC-MAILROOM I                   RlGlNAL
    Ms. Marlene H. Dortch, Secretary
    Federal Communications Commission
    445 12th Street, S.W.
    Washington, D.C. 20554                            EX PARTE OR LATE FILED

            Re:    Mobile Satellite Ventures Subsidiary LLC
                   Ex Parte Presentation
                   IB Docket No. 01-185
                   File No. SAT-MOD-20031118-00333 (ATC application)
                   File No. SAT-AMD-20031118-00332 (ATC application)
                   File No. SES-MOD-20031118-01879 (ATC application)

    Dear Ms. Dortch:

             Wireless Matrix Corporation (‘‘Wireless Matrix”) hereby urges the Commission to afford
    L-band Mobile Satellite Service (‘‘MSS”) operators greater flexibility in their provision of an
    Ancillary Terrestrial Component (“ATC”), as requested by Mobile Satellite Ventures LP
    (“MSV”) in the above-captioned proceedings. The increased flexibility requested by MSV will
    ensure that next-generation MSS systems in the L-band will achieve the ubiquitous coverage,
    capacity, and economies of scale needed for a true consumer service. In contrast, we believe the
    restrictions on L-band ATC advocated by Inmarsat Ventures plc (“Inmarsat”) would limit MSS
    to a niche service catering to price-insensitive users operating in remote areas.

           Wireless Matrix has provided MSS since 1997 using the L-band satellites of MSV and
    Mobile Satellite Ventures (Canada) Inc. and we currently provide data, voice, and dispatch
    services to end user customers throughout the United States and Canada. We service multiple
    markets such as Transportation, Public Utilities, the Public Safety and Resources Sector, as well
    as Marine and Forestry markets with all of these aforementioned services.

             While Wireless Matrix has developed a viable business using current-generation MSS
    satellites to serve niche markets, we are excited about the future potential for MSS when
    supplemented with ATC. To date, MSS has been characterized by unacceptably large user
    terminals, limited coverage, low data rates, and equipment and service prices far exceeding that
    offered by terrestrial wireless operators. Because the market for this type of service is small, the
    economies of scale needed to drive down equipment and service prices have not developed.
    With ATC, however, MSS has the potential to evolve into a true consumer service. ATC will
    provide the coverage, capacity, and economies of scale needed to bring MSS equipment and
    service prices to affordable levels. Moreover, by overcoming satellite signal blockage in urban
    areas, ATC will allow MSS to become a truly ubiquitous service, allowing service providers to


                                                                     No. of Go ies rec’d
                                                                     Let AB&
                                                                                           0


Ms. Marlene H. Dortch
January 13,2005
Page 2


market their products to customers not only in rural and remote areas but to customers in the
most densely populated urban cores as well.

         Wireless Matrix understands that another MSS Operator is taking opposition to MSV’s
efforts to make MSS into a more attractive service. If MSV does not succeed in its development
of a next-generation MSS system, we believe the current operator would have a monopoly in the
L-band MSS market across North America. With no competitive pressure to discipline existing
rates, terms, and conditions for MSS services, L-band MSS service providers will struggle to
survive. Moreover, with only one operator, the prospects for innovation in L-band MSS
technology will cease to exist.

        We are aware that opposition has been taken to MSV’s application citing a potential for
interference with existing satellite services to delay MSV’s development of a next-generation
MSS system. We feel these concerns are overstated and speculative in that our current
customers who operate satellite only terminals are doing so because they operate in very remote
areas not covered by terrestrial wireless service. MSV’s plan is to deploy base stations to
overcome satellite signal blockage, which is not the operating environment for our satellite only
customers. By definition, if MSV needs to deploy an ATC base station to overcome signal
blockage, our satellite-only terminals will not work effectively in those areas.

      Wireless Matrix urges the Commission to follow the path of innovation and better
consumer service by adopting MSV’s proposals for increased flexibility for ATC in the L-band.


                                                     Very truly yours,



                                                  d J. Richard Carlson
                                                     President & CEO



Document Created: 2005-01-25 17:01:35
Document Modified: 2005-01-25 17:01:35

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