Attachment Ligado - Request for

This document pretains to SAT-MOD-20101118-00239 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2010111800239_1304074

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                                                    October 31, 2017


     Marlene H. Dortch                                                                fififié              /F“-ED
     Secretary                                                                             m# d t yidn g

     Federal Communications Commission                                                   0CJ 3 1 zui/
     Office of the Secretary                                                     Federal Communtcatio
     445 12th Street SW                                                                Office of the Sefigm;ymm
     Washington, DC 20554

                    Re: IB Docket No. 08—184 and IBFS File No. SAT—MOD—20101118—00239

     Dear Ms. Dortch:

     Ligado Networks Subsidiary LLC ("Ligado")‘ hereby submits this combined semi—annual
     report pursuant to the Memorandum Opinion and Order and Declaratory Ruling adopted
     by the Commission on March 26, 2010 in 1B Docket No. 08—184 (the "MO&O"), and
     quarterly report pursuant to the Order and Authorization adopted by the Commission on
     January 26, 2011 in IBFS File No. SAT—MOD—20101118—00239 (the "O&A") (collectively,
     the "Orders"). By separate letter, Ligado requests confidential treatment of this report.

     On February 15, 2012, the Commission released a Public Notice seeking comment on
     the letter sent to it on February 14, 2012 by the National Telecommunications and
     Information Administration‘s (NTIA)." The Public Notice addressed certain issues
     related to the potential incompatibility of GPS receivers with Ligado‘s planned
     operations, and recommended vacating the Commission‘s Conditional Waiver Order
     and modifying Ligado‘s satellite license to suspend indefinitely its ATC authority.

     The Conditional Waiver Order itself provides that Ligado and members of the GPS
     industry must resolve certain outstanding issues"before Ligado commences offering
     commercial service pursuant to [the waiver granted in the Conditional Waiver Order] on
     its L—band MSS frequencies."" in light of the Commission‘s Public Notice and the
     unresolved condition in the Conditional Waiver Order, Ligado is not yet providing
     commercial service using its ATC authority. Ligado remains committed to working

     ! See Letter from LightSquared to FCC (JQ;y 20,2010) (notifying the Commission that SkyTerra had
     changed its name to LightSquared); Letter from Ligado Networks to FCC (Feb. 11, 2016) (notifying the
     Commission that LightSquared had changed its name to Ligado Networks).
     * See Public Notice: International Bureau Invites Comment on NTIA Letter Regarding LightSquared
     Conditional Waiver, IB Docket No. 11—109, DA 12—214 (Feb. 15, 2012).
     3 LightSquared Subsidiary LLC, 26 FCC Red 566, at 41 (2011).

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     cooperatively with Congress, federal government agencies, and the GPS industry to
     address the concerns raised by the GPS industry and others.

     Beginning in September of 2012, Ligado made a series of filings with the Commission
     proposing solutions that would allow it to deploy terrestrial broadband service in a way
     that ensures that GPS receivers are compatible with Ligado‘s operations. These filings
     have been accepted by the Commlssmn and all have been placed on public notice for
     comment.*

     SITE DEVELOPMENT

     As a result of the Commission‘s Public Notice of February 15, 2012, Ligado has not _
     undertaken any significant site development activity related to the provision of two—way
     terrestrial mobile service during this reporting penod Ligado has focused its efforts on
     resolving the underlying spectrum and deployment issues identified by the Commission
     through the series of filings referenced above.

     DEVICE MANUFACTURERS

     Qualcomm Incorporated has integrated L—Band LTE technology in its chipset roadmap
     and has developed an advanced satellite air interface technology to enable the satellite
     mode of operation in mobile devices.

     SATELLITE

     Each of the satellites operated by Ligado has performed nommally and as expected
     over the past six months.

     PARTICULAR REPORTING REQUIREMENTS

             1. Pursuant to reporting requirement III.A of the O&A, Ligado reports that as of
                September 30, 2017 there were approximately              terminals and
                approximately           active private network customers on its MSS—only network.
                Ligado can only provide an estimate of the latter figure because the company
                does not have direct access to the subscriber counts of its wholesale customers.
                As noted above, Ligado is not yet providing commercial MSS/ATC or terrestrial—
                only services. Accordingly, the number of reportable active terminals and active
                users on its network in these categories is zero. As the terrestrial network is not
                yet in commercial service, the number of reportable total bytes carried by
                Ligado‘s terrestrial network also is zero (see Condition 3 to the MO&O).

     * See Public Notice, Federal Communications Commission Invites Comment on LightSquared Request to
     Modify Its ATC Authorization, DA 12—863 (rel, Nov. 16, 2012); Public Notice, Consumer & Governmental
     Affairs Bureau Reference Information Center Petition for Rulemaking Filed, RM No. 11683 (rel. Nov 18,
     2012).
     5 Ligado has implemented a one—way DVB—H network in the 1670—1875 MHz band.


     0   e    0   e   e             10802 Parkridge Boutevard, Reston, VA 20191   |   ligado.com         2


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           2. Pursuant to reporting requirement III.B of the O8A, Ligado provides the following
              list of components available from mainstream component suppliers to support L.—
              band dual mode operations:




                                                       Sincerely,



                                                          Lo Q(fiav:&
                                                      William Davenport
                                                      Senior Vice President & Deputy General
                                                      Counsel, Regulatory Affairs


     co:      Thomas M. Johnson, Jr.
              Tom Sullivan
              Jennifer Gilsenan
              IB—SATFO@fec.gov




     e e 0    e e              10802 Parkridge Boulevard, Reston, VA 20191   |   ligado.com    3



Document Created: 2017-11-15 18:01:26
Document Modified: 2017-11-15 18:01:26

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