Attachment other

other

SUBMISSION FOR THE RECORD submitted by XM Radio; Sirius Satellite Radio

other

2005-03-14

This document pretains to SAT-MOD-20040212-00017 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2004021200017_426195

                                         March 14, 200
                                                                                ORIGINAL
                                                                       Recet
Mr. Thomas S. Tyez                                                        ceived
Chief, Satellte Division                                              MAR 9 o 20
Interational Bureau                                                            l
Federal Communications Commission                                     Polcy Branch
445 Twelfth Street, S.W.                                           InfematonalBursay
Washington, DC 20554
        Re:     TB Docket No. 95—91; SAT—MOD 20040212—00017; SAT—RPL—20040212—
                00018; SAT—RPL—20040212—00019; SAT—AMEND—97;
                10/1 1—DS§—P.9312/15/92; 26/27—D8§—LA—931/15/93;
                83/83—SAT—AMEND—953/1098

Dear Mr. Tyer:
        On January 28, 2005, you asked XM Radio Inc. ("XM") and Sirius Satellite Radio
Inc. (‘Sirius") to update you on their activitiesrelated to receiver design." XM and Sirius
jointly submit this letter in response to your request, and reconfirm their compliance with
Section 25.144(a)(3)(i) of the Commission‘s rules by including interoperable radios in
their respective system designs.
       XM and Sirius have designed and licensed receiver systems that share a common
head unit, antenna, and wiring hamess, while other entities continue to be responsible for
the manufacture and distribution ofsatelite rdios. Several aftermarket and OEM radio
manufacturers now produce head units that operate with the receiver boxes of either
service provider. Some head units are also branded and marketed as "SAT Ready" to
denote their ability to work with both systems. At least one automaker factory installs
head units and antennas that are compatible with both XM and Siius® systems. This
configuration allows the customer to purchase a trunk—mounted box for ither satelite
radio provider without disturbing the rest of the components. This unit can be swapped at
any time for a trunk—mounted box from the other satellite radio provider.
        In February 2000, XM and Siius signed a joint development agreement to
develop interoperable technologies, and cross—licensed to each other their respective
intellectual property and technology to advance the joint venture. This joint venture has
been tasked with combining XM‘s and Sirius‘ proprietary chipsets into a compact and
efficient device capable of receiving both services, The joint venture has been staffed
with engineering personnel that are independent of XM and Sirius. To date, the



‘ See Leter from Thomas S. Tyez to Lon C.Levi, XM Radio Inc. (January 28, 2009); Leter from Thomas
5. Te to Patick L. Donnely,is Satlite Radio n. January 28, 2009)


Mr. Thomas S. Tycz
March 14, 2005
Page2
companies have spent nearly $5,000,000 to fuind the joint venture and expect to spend
more in the future. Both Sirius and XM are optimistic that, at a minimum, a prototype for
this type of interoperable radio(e., a receiver using a common antenna, a common RF
tuner,and two bascband modules, one for XM and one for Sirius) will be completed by
the joint venture in 2005. Upon completion, and subject to successfil performance and
manufacturability testing, we believe this prototype could be manufactured.
        Nevertheless, the market will ultimately determine the success of these products.
Competition for the attention of consumers in automobiles is not limited to SDARS
Hicensees, AM, FM, HD radio, cassette decks, CD players, navigation systems, DVD
players, iPod and other MP3 players all compete for space in automobile head units.
Soon wireless broadband services and cell phones may further crowd this busy space.
All ofthese devices affectthe quality, quantity, and price points that manufacturers
careffully assess before introducing a product.
       In the four and a half years that have passed since XM‘s and Sirius® previous
submission, the two companies have invested billions of dollars, and have been
extraordinarily successfulin fulfillng the Commission‘s vision ofproviding Americans
with "continuous nationwide radio programming"that will "increase the variety of
programming available to the listening public." Abead ofthe Commission‘s milestones,
each company launched satellites, icensed technology to manufacturers, and began
offering over 120 channels of digital music, news, sports, entertainment, trafic and
weather. The new service has been well received in the marketplace and has been a
positive development for consumers, the consumer electronics industry, the music and
artist community, and the United States commercial satellite industry.
       That success is due in signifieant part to the Commission‘s decision not to
mandate the use of a particular technology. The freedom to design systems unbounded
by government—imposed mandates has allowed each company to get to market quickly
and continue to innovate. The satelliteradio industry has not only developed the
expected satellite receiver units which operate with car radios, but has also pioncered the
development of whole new eategories of audio products, including satellite radio "plug
and play" devices, standalone home stereo component systems, integrated
AM/FM/Satellite receivers, portable/wearable satellte radio devices with integrated
antennas and "time shifted" recording capability, and various ancillary telematics and
data/navigation services. All ofthis has been done at prices that have made the
equipment increasingly affordable.
       Simply put, Sirius and XM have invested considerable time, effort and money
designing, launching and operating systems compliant with the Commission‘s rules,
including an interoperable radio design offered to manufacturers. The companies are
continuing those efforts to streamline and improve that design. The availability of


Mr. Thomas S. Tyez
March 14, 2005
Page3
interoperable radios, however, will depend in large part on factors outside ofthe control
of either XM or Sitius, including consumer demand for interoperability and the
willingness of manufacturers to manufacture, distribute, market and sell interoperable
radios after carefully weighing the integration, qualification, costs and efficiency
considerations.
       Please contact the undersigned if you have any further questions.
                                              Very truly yours,

W illim m ty                                          BBAcl. boak
William Bailey                                        Patrick L. Donnelly
Senior Vice President                                 Executive Vice President and General Counsel
Regulatory and Government Affairs                     Sirius Satellite Radio Inc.
XM Radio Inc.                                         1221 Avenue ofthe Americas
1500 Eckington Place, NE                              New York, NY 10020
Washington, DC 20002                                  212 584 5100
202 380 4000
ces    Office of the Secretary
       JoAnn Lucanik
       Stephen Duall



Document Created: 2005-03-30 11:09:52
Document Modified: 2005-03-30 11:09:52

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