Attachment request

request

REQUEST submitted by MSV

request

2006-01-26

This document pretains to SAT-MOD-20051104-00211 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2005110400211_481443

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Zonmremiat use onty                     CONFIDENTIAL —
                                   NoT FOR PUBLIC INSPECTION

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-——-EO—N:&B‘L_                                  Junuary 26, 2006




                                                                 EQR?“B“G                     P
         yLommniadiine Commener
         445 12th Street, S.W.
         Washington, D.C. 20554

                Re:    Response of Mobile Satellites Ventures Subsidiary LLC to
                       Opposition of Inmarsat Ventures Ltd.
                       File No. SAT—MOD—20051104—00212
                       File No. SAT—MOD—20051104—00211
                       File No. SES—MOD—20051110—01561
                       File No. SES—MOD—20051104—02556

         Dear Ms. Dortch:

                Mobile Satellites Ventures Subsidiary LLC (‘MSV) hereby files this non—redacted,
        confidential version of a Response to the Opposition ofInmarsat Ventures Ltd. ("Inmarsat") to
        MSV‘s application to modify its license to operate an Ancillary Terrestrial Component ("ATC®)
        in the L band." As discussed herein, certain information provided in the attached Petition should
        be treated as confidential. A redacted copy ofthisfiling has been filed under separate cover for
        public inspection and has been served on the applicant.




        ‘ See MSV, Application, File Nos. SAT—MOD—20051 104—00212, SAT—MOD—20051 104—00211,
        SES—MOD—20051110—01561 (November 4, 2005) ("MSY ATC Modification Application").
        47 C.F.R. § 0.459(b). Pursuant to procedures adopted by the Commission on October 17, 2001,
        the attached non—redacted, confidential information is not filed in a sealed envelope. See "FCC
        Announces Changes in Filings Procedures," Public Notice, DA 01—2430 (Oct. 17, 2001). MSV
        understands that, asstated in the Public Notice, Commission staff will place the attached
        information in an envelope marked "Confidential" upon receipt.

                      FoR INTERNAL UsE ONLY

                             NON—PUBLIC


Ms. Marlene H. Dortch
"January 26, 2006
Page 2
                                     CONFIDENTIAL —
                            NOT FOR PUBLIC INSPECTION

47 C.F.R. § 0.459(b)()         ——      Identification of the specific information for which
                                       confidential treatment is sought
       MSV requests confidential treatment of information relating to the Mexico City
Memorandum ofUnderstanding and the on—going intemnational L band frequency coordination
process which is confidential to the parties to that coordination, which includes the Commission
and MSV.* When considering other applications to use Inmarsatsatelltes in the United States,
the Commission has acknowledged the confidentiality ofthis information and has afforded it
confidential treatment"
47 C.F.R §0450b)()             —      Identification of the Commission proceeding in which
                                      the information was submitted or a description of the
                                      circumstances giving rise to the submission
       This information is being fild in MSV‘s Response to Inmarsat‘s Opposition to MSV‘s
application to modify ts license to operate an Ancillary Terrestrial Component ("ATC®)in the L
band.
47C.       . § 0.450(b)@)      ——     Explanation of the degree to which the information is
                                      commercial or financial, or contains a trade secret or is
                                      privileged
         As the Commission has acknowledged, the Mexico City Memorandum of Understanding
and related coordination documents are confidential.®

47 C.F.R. §0.459(@b)(4)        —      Explanation of the degree to which the information
                                      concerns a service that is subject to competition
         The information contained herein concerns the market for wireless services, in which
MSV faces competition from other MSS providers as well as from terrestrial wireless operators.

* See Memorandum of Understandingfor the Intersystem Coordination ofCertain Geostationary
Mobile Satellie Systems Operating in the Bands 1525—1544/1545—1559 MFHz and 1626.5—
1646.5/1646.5—1660.5 Miiz, Mexico City, Mexico, 18 June 1996.
* See COMSAT Corporation et. al. Memorandum Opinion, Order and Authorization, 16 ECC
Red 21661, §§ 111 (2001) (°COMSATOrder") (‘The Mexico City Agreement and related
coordination documents, such as minutes of coordination meetings, are considered
confidential.").
* 14.


Ms. Marlene H. Dortch
January 26, 2006
Page 3
                                CONFIDENTIAL —
                           NOT FOR PUBLIC INSPECTION


       ‘R. §0459@b)8)         —      Explanation of how disclosure of the information could
                                     result in substantial competitive harm
        Disclosure of the information for which confidential treatment is sought would result in
violation of the Mexico City Memorandum ofUnderstanding.
47 C.F.R. §0.4590(b)(6)       ——     Identification of any measures taken bythe submitting
                                     party to prevent unauthorized disclosure
       Disclosure to third parties ofthe information for which confidentialtreatment is sought
has been strictly pursuant to non—disclosure agreements.
47 C.F.R. §0.459(b)(7)       —       Identification of whether the information is available to
                                     the public and the extent of any previous disclosure of
                                     the information to third parties
         The information for which confidentialtreatment is sought is not publicly available.
Disclosure to third parties of the information for which confidentia treatment is sought has been
strietly pursuant to non—disclosure agreements.
47 C.F.R. §0459()(8)         ——      Justification of the period during which the submitting
                                     party asserts that material should not be available for
                                     public disclosure
        The information for which confidential treatment is sought should remain confidential
indefinitely or until the parties to the Mexico City Memorandum ofUnderstanding agree that it
can be made publicly available.
47 C.F.R. §0459@b)®)          —      Any other information that the party secking
                                     confidential treatment believes may be useful in
                                     assessing whether its request for confidentiality should
                                     be granted
NA.


Ms. Marlene H. Dortch
January 26, 2006
Page4
                              CONFIDENTIAL—
                         NOT FOR PUBLIC INSPECTION



      Please contact the undersigned with any questions.

                                          Very wuly yours,


                                          Rendy S. Sfgal



Document Created: 2006-02-02 15:59:21
Document Modified: 2006-02-02 15:59:21

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