Attachment DIRECTV - Grant Augu

DIRECTV - Grant Augu

DECISION submitted by IB, FCC

Grant

2019-08-13

This document pretains to SAT-MOD-20190625-00050 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2019062500050_1849521

~. .w- ,~. -. piløj .~SA1 ~ /M4’~~I ~q ~ft~r~I~i ~ ~ S2641 SAT-MOD-20190625-00050 1B20 19002522 i~ ~ DIRECTV Enterprises, LLC .~ c~nsignS2(o’-1I GrantDate V “~{W~ \ ~‘ (o~’otherJdentifler).~. ..~. ~ TermDatcs’ Appro~ed by 0MB 3060—0678 PromO, Thu’ IS’ To O3/i3/Zz GRANTED~ Date & Time Filed: Jun 25 2019 2:23:45:583PM Internal innal Bureau Ai~nrnv~c1~ File Number: SAT MOD—20 190625—00050 C-~1 ,S~Iellt~ POIk~J £~rnc~ FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD - MAIN FORM FCC Use Only FCC 312 MAIN FORM FOR OFFICIAL USE ONLY APPLICANT INFORMATION Enter a description of this application to identify it on the main menu: Modification Application to Change Tl0 Orbital Location (Call Sign S264l) 1 8. Legal Name ofApplicant Name: DIRECTV Enterprises, LLC Phone Number: 3 10—964 4996 DBA Fax Number: Name: Street: 1 120 20th Street, NW E—Mail: spdulac a att.corn Suite 1000 City: Washington State: DC Country: USA Zipcode: 20036 Attention: Steve Dulac

ATTACHMENT TO GRANT DIRECTV Enterprises, LLC IBFS File No. SAT-MOD-20190625-00050 IBFS File No(s): SAT-MOD-20190625-00050 GRANTED — Licensee/Grantee: DIRECTV Enterprises, LLC (DIRECTV) With Conditions Call Sign: S2641 Satellite Name: TI 0 (formerly DIRECTV 10) Orbital Location: 102.75° W.L. (required station- (± 0.025 degrees) keeping tolerance) Administration: United States of America Nature of Service: Fixed-Satellite Service (FSS) International Bureau Satellite_Division Scope of Grant: Authority to specify operations at the 102.75° W.L. orbital location instead of the previously authorized orbital location of 102.85° W.L. and to provide FSS service at 102.75° W.L. Previous Grants: Authority to operate DIRECTV 10 at 102.85° W.L. See IBFS File No. SAT-MOD- 20150320-00012 (granted Apr. 30, 2015) Authority to operate DIRECTV 10 at 102.8 15° W.L. See IBFS File No. SAT-MOD- 20091009-00109 (granted Feb. 26, 2010) Authority to operate DIRECTV 10 at 102.775° W.L. See IBFS File No. SAT-MOD- 20070626-00086 (granted Dec. 17, 2007) Authority to launch and operate DIRECTV 10 at 102.8° W.L. See IBFS File No. SAT LOA-20040909-00 169 (granted Mar. 7, 2005) Service Area(s): CONUS, Alaska, Hawaii, Puerto Rico Frequencies1: 18.3-18.8 GHz (space-to-Earth) 28.35-28.6 GHz (Earth-to-space) 29.25-29.5 GHz (Earth-to-space) Telemetry, Tracking, and Command 18.30025 GHz and 18.30075 GHz (space-to-Earth) 29.25 10 GHz and 29.4930 GHz (Earth-to-space) Unless otherwise specified herein, operations under this grant must comport with the legal and technical specifications set forth by the applicant or petitioner and with Federal Communication Commission’s rules not waived herein. This grant is also subject to the following conditions: 1. DIRECTV must prepare the necessary information, as may be required for submission to the International Telecommunication Union (ITU), to initiate and complete the advance publication, international coordination, due diligence, and notification process for this space station, in accordance with the ITU Radio Regulations. DIRECTV shall be responsible for all cost-recovery fees associated with 1TU filings. No protection from interference caused by radio stations authorized by other administrations is guaranteed unless coordination and notification procedures are timely completed or, with respect to individual administrations, by successfully completing coordination agreements. Any radio station authorization for which coordination has not been completed may be subject to additional terms and conditions as required to effect coordination of the frequency assignments with other administrations. See 47 CFR § 25.111(b). T10 is authorized to use the 18.3-18.59 GHz (space-to-Earth) and 28.35-28.6 GHz, 29.25-29.5 (Earth-to-space) frequency bands, but these frequencies will be used for backhaul rather than direct provision of service to subscribers. Page 1 of 2

ATTACHMENT TO GRANT DIRECTV Enterprises, LLC IBFS File No. SAT-MOD-20190625-00050 2. DIRECTV must maintain the Tl0 space station within an east-west longitudinal station-keeping tolerance of ±0.025° of its assigned 102.75° W.L. orbital location.2 3. Prior to commencing operations, DIRECTV must coordinate its space-to-Earth operations in the 18.3-1 8.8 GHz frequency band with the U.S. Federal systems, including Federal operations to earth stations in foreign countries, in accordance with Footnote US334 to the U.S. Table of Frequency Allocations, 47 CFR ~ 2.106. Two weeks prior to the start of any operations in the 18.3-18.59 GHz frequency band, DIRECTV must provide contact information for a 24/7 point of contact for the resolution of any harmful interference to the Federal user, Jimmy Nguyen, Email: Jimmy.Nguyen@us.af.mil. 4. The power flux-density (PFD) at the Earths surface produced by the emissions from the Tl0 space station for all atmospheric conditions, and for all methods of modulation in the 18.3-18.59 GHz frequency band (space-to-Earth), must not exceed a level of -118 dBW/m2/MHz at any angle of arrival. 5. In the 28.35-28.6 GHz (Earth-to-space) frequency band reception is permitted at levels up to the applicable equivalent power flux-density requirements of Article 22 of the ITU Radio Regulations. 6. The 29.25-29.5 0Hz frequency band is designated for uplinks for FSS systems using geostationary satellites and for feeder uplinks for Mobile Satellite Systems using non-geostationary orbit satellites on a co-primary basis. Communications between U.S.-licensed earth stations and the T10 space station in the 29.25-29.5 GHz frequency band must comply with sections 25.258 and 25.278 of the Commission’s rules. 47 CFR §~ 25.258 and 25.278. 7. DIRECTV must file with the Commission the information required by section 25.172 of the Commission’s rules, 47 CFR § 25.172. 8. Nothing in this grant changes the license term for the T10 space station (Call Sign S2641), which expires on September 13, 2022. Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned. This action is taken pursuant to Section 0.261 of the Commission’s rules on delegated authority, 47 C.F.R. § 0.261, and is effective upon release. Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as amended, 47 U.S.C. § 309(h). Action August 13, 2019 Date: Term Dates From: August 13, 2019 To: September 13, 2022 Approved: Stephe J uall Chief, tellite Policy Branch 2 DIRECTV Tb, T12, and T15 each operate within an east-west longitudinal station-keeping tolerance of ±0.025 of their respective assigned orbital locations. Page 2 of 2

9—16. Name of ~.ontact Representative Name: Jennifer D. Hindin Phone Number: 202—719—4975 Company: Wiley Rein LLP Fax Number: 202—719—7049 Street: 1 776 K Street, NW E—Mail: jhindin~~wileyrein.com City: Washington State: DC Country: USA Zipcode: 20006— Attention: Relationship: Legal Counsel CLASSIFICATION OF FILING 17. Choose the button next to the classification that applies to this filing for (N/A) b1. Application for License of New Station both questions a. and b. Choose only one (N/A) h2. Application for Registration of New Domestic Receive—Only Station for I 7a and only one for 17h. 0 b3. Amendment to a Pending Application b4. Modification of License or Registration 0 al. Earth Station b5. Assignment of License or Registration • a2. Space Station b6. Transfer of Control of License or Registration 0 h7. Notification of Minor Modification (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States (N/A) blO. Other (Please specify) (N/A) bi I. Application for Earth Station to Access a Non—U.S.satellite Not Currently Authorized to Provide the Proposed Service in the Proposed Frequencies in the United States (N/A) bl2. Application for Database Entry o b13. Amendment to a Pending Database Entry Application o b 14. Modification of Database Entry 7

17c. isa fee submitted with this application? • If Yes, complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1 114). 0 Governmental Entity ~ Noncommercial educational licensee o Other(piease explain): I 7d. Fee Classification BFY — Space Station Modification(Geostationary) l8. lfthis filing is in reference to an 19. If this filing is an amendment to a pending application enter both fields, if this filing is a existing station. enter: modification please enter only the file number: (a) Call sign of station: (a) Date pending application was filed: (b) File number: S264 I SATMOD2O 15032000012

TYPE OF SERVICE 20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply: a. Fixed Satellite Q b. Mobile Satellite c. Radiodeterm ination Satellite E3 d. Earth Exploration Satellite Q e. Direct to Home Fixed Satellite Q f. Digital Audio Radio Service Q g. Other (please specify) 21. STATUS: Choose the button next to the applicable status. Choose 22. If earth station applicant, check all that apply. only one. Q Using U.S. licensed satellites 0 Common Carrier Non—Common Carrier Q Using Non—U.S. licensed satellites 23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these facilities: o Connected to a Public Switched Network Not connected to a Public Switched Network N/A 24. FREQUENCY BAND(S): Place an ~X’ in the box(es) next to all applicable frequency band(s). Q a. C—Band (4/6 GHz) Q b. Ku—Band (12/14 GHz) c.Other (Please specify upper and lower frequencies in MHz.) Frequency Lower: 18300 Frequency Upper: 29500 (Please specify additional frequencies in an attachment)

TYPE OF STATION 25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one. 0 a. Fixed Earth Station o b. Temporary—Fixed Earth Station o c. o d. Mobile Earth Station e. Geostationary Space Station o ~ Non—Geostationary Space Station O g. Other (please specify) 26. TYPE OF EARTH STATION FACILITY: o Transmit/Receive ~ Transmit—Only ~ Receive—Only ® N/A “For Space Station applications, select N/A.”

PURPOSE OF MODIFICATION 27. The purpose of this proposed modification is to: (Place an ‘X’ in the box(es) next to all that apply.) Q a authorization to add new emission designator and related service —— Q h authorization to change emission designator and related service — Q c authorization to increase EIRP and EIRP density —— Q d authorization to replace antenna —— Q e authorization to add antenna —— Q f—— authorization to relocate fixed station Q g authorization to change frequencv(ies) —— Q h authorization to add frequency — Q i authorization to add Points of Communication (satellites & countries) —— Qi —— authorization to change Points of Communication (satellites & countries) Q k authorization for facilities for which environmental assessment and —— radiation hazard reporting is req uired —— authorization to change orbit location Q Iii —— authorization to perform fleet management Qn — authorization to extend milestones Qo —— Other (Please specify)

ENVIRONMENTAL POLICY 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental 0 Yes No impact as defined by 47 CFR 1.1 307? If YES, submit the statement as required by Sections 1 1308 and 1.131 1 of . the Commission’s rules. 47 C.F.R. 1.1308 and I 131 1, as an exhibit to this application.A Radiation Hazard Study . V must accompany all applications for new transmitting facilities, major modifications, or major amendments. ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or aeronautical fixed radio station services are not required to respond to Items 30—34. 29. Is the applicant a foreign government or the representative of any foreign government? 0 Yes No 30. Is the applicant an alien or the representative of an alien? Yes No N/A 31. Is the applicant a corporation organized under the laws of any foreign government? o Yes No N/A 32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by o Yes No N/A aliens or their representatives or by a foreign government or representative thereof or by any corporation organized under the laws of a foreign country?

33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than o Yes No N/A one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign government or representative thereof or by any corporation organized under the laws of a foreign country? 34. If any answer to questions 29. 30. 31.32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote. BASIC QUALIFICATIONS 35. Does the Applicant request any waivers or exemptions from any of the Commission’s Rules? o Yes No If Yes. attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents. 36. Has the applicant or any party to this application or amendment had any FCC station authorization or license o Yes No revoked or had any application for an initial. modification or renewal of FCC station authorization, license. or construction permit denied by the Commission’? lfYes, attach as an exhibit, an explination of circumstances.

37. Has the applicant, or any party to this application or amendment. or any party directly or indirectly controlling 0 Yes No the applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an exhibit, an explination of circumstances. 38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant, o Yes No guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication. directly or indirectly, through control of manufacture or sale of radio apparatus. exclusive traffic arrangement or any other means or unfair methods of competition?lf Yes, attach as an exhibit, an explanation of circumstances 39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending o Yes No matter referred to in the preceding two items? If yes. attach as an exhinit, an explanation of the circumstances. 40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names. address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer’s voting stock and the percentages so held. In the case of fiduciary control, indicate the heneficiary(ies) or class of Question 40 beneficiaries. Also list the names and addresses of the officers and directors of the Filer.

41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is Yes No subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for the meaning of &quot~part3’ to the application&quot: for these purposes. 42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If Yes, o Yes No answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137. as appropriate. If No, proceed to question 43. 42b. What administration has licensed or is in the process of licensing the space station? If no license will he issued. what administration has coordinated or is in the process of coordinating the space station? 43. Description. (Summarize the nature of the application and the services to he provided). (If the complete description does not appear in this box. please go to the end of the form to view it in its entirety.) DIRECTV Enterprises, LLC seeks to modify its authorization for TlO (Call Sign S2641) to change the authorized orbital location from 102.85 WL to 102.75 WL. Narrative

43a. Geographic Service Rule Certification By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25. By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements. OC By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25 and ~vill not comply with such requirements because it is not feasible as a technical matter to do so. or that, while technically feasible, such services would require so many compromises in satellite design and operation as to make it economically unreasonable. A narrative description and technical analysis demonstrating this claim are attached. CERTIFICATION The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application. The undersigned. individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.

44. Applicant is a (an): (Choose the button next to applicable response.) o Individual ~, Unincorporated Association o Partnership 0 Corporation 0 Governmental Entity • Other (please specify) 45. Name of Person Signing 46. Title of Person Signing Steve Dulac Director, Content Technology & Regulatory Policy WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.S. Code, Title 47, Section 31 2(a)( I)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 2 hours per response. including the time for reviewing instructions, searching existing data sources. gathering and maintaining the required data. and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission. AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA~fcc.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember You are not required to respond to a collection of information sponsored by the Federal government, and the government may not — conduct or sponsor this collection. unless it displays a currently valid 0MB control number or if we fail to provide you with this notice. This collection has been assigned an 0MB control number of 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507.

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 ) In the Matter of ) ) DIRECTV ENTERPRISES, LLC ) File No. SAT-MOD_______________ ) Application to Modify Authorization for TI 0 ) (S2641) ) ___________________________________________________________________________________ ) APPLICATION OF DIRECTV ENTERPRISES, LLC TO MODIFY AUTHORIZATION FOR T10 (S2641) DIRECTV Enterprises, LLC (“DIRECTV”). pursuant to Section 25.117 of the rules of the Federal Communications Commission (“FCC” or “Commission”),1 hereby requests to modify its authorization for 110 (call sign S264l).2 Specifically. DIRECTV seeks authority to change the authorized orbital location of T10 from 102.85° W.L. to 102.75° W.L. In accordance with the Comrnission~s rules,3 this application is being filed electronically as an attachment to FCC Form 31 2. Because the satellite will he relocated just 0. 10° from its currently authorized orbital location, the technical information on file with the Commission for Tl0 (including the technical information submitted on Schedule S) remains unchanged and is incorporated by reference.4 To the extent necessary, I)IRECTV requests that any previously granted technical waivers continue to apply to the operation of Ti 0 at 102.75° W.L. 47 C.F.R. § 25.117. 2 Policy Branch Information; Ac/ions Taken, Public Notice. Report No. SAT-0 1080, File No. SAT-MOD-20150320-00012 (May 1,2015). ~ See 47 C.F.R. § 25.117(c). ~ See IBFS File Nos. SAT-MOD-20150320-00012. SAT-MOD-20091009-00 109, SAT-MOD 20070626-00086, SAT-LOA-20040909-00 169.

L PROPOSED MODIFICATION AND PUBLIC INTEREST SHOWING DIRECTV is implementing certain changes to its existing satellite fleet in connection with the recent launch of DlRECTV~s Tl6 satellite (Call Sign S3039) on June 20, 2019. T10 isa Ka-band satellite operating in the 1 8.3-1 8.8 GHz (space-to-Earth) and 28.35-28.6 GHz/29.25- 29.5 Gl-fz (Earth-to-space) frequency bands.3 On June 6, 2019, the Commission granted DIRECTV’s request for special temporary authority to drift TI 0 from its current location at 102.85° W.L. to 102.75° W.L. and to operate the TT&C and communications frequencies on the TI 0 satellite at 102.75° W.L. and during the drift from 102.85° W.L. to 102.75° W.L.6 By this modification application, DIRECTV seeks authority to permanently change the authorized orbital location of Tl0 from 102.85° W.L. to 102.75° W.L. [)IRECTV’s Tl5 satellite (Call Sign S2930) is permanently authorized to operate at 102.75° W.L.7 but is currently operating at 100.85° W.L. pursuant to a grant of special temporary authority.8 DLRECTV is simultaneously filing a separate modification application to permanently change the authorized orbital location ofTI5 from 102.75° W.L. to 102.85° W.L. Grant of this relocation request will not result in increased risk of harmful interference. DIRECTV will operate Tl0’s TT&C and communications frequencies at 102.75° W.L. in ~ T10s telemetry, tracking, and command (“TT&C”) frequencies are 18300.25 MHz and 1 8300.75 MHz (space-to-Earth) and 2925 I .0 MHz and 29493.0 MHz (Earth-to-space). 6 See Satellite Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-0l395, File No. SAT-STA-20 190531-00043 (June 7, 2018). ~ See Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-0 1086, File No. SAT-LOA-20l40825-00094 (May 22, 2015): Policy Branch infOrmation; Actions Taken, Public Notice, Report No. SAT-01084, File No. SAT-MOD-20140612-00066 (May 15, 2015). T15’s 17/24 GHz BSS band payload was originally authorized under Call Sign S2712, which was consolidated with Call Sign S2930 in September 2017. 8 See Satellite Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-0 1395, File No. SAT-STA-20l904l6-00028 (June 7,2019).

conformance with FCC rules and I)IRECT’V’s coordination agreements concerning the nominal 1030 Wi. orbital location. DIRECTV will operate T10 at 102.75° W.L. in accordance with all previously imposed FCC conditions. Grant of this application will serve the public interest because it will facilitate DIRECTVs fleet management operations in connection with the recent launch of DIRECTV’s T16 satellite, which will extend coverage, improve service performance, and provide additional capacity to DIRECTV customers. IL MILESTONES AND’ BOND I)IRECTV requests grant of this application without milestones or a bond because the Commission’s milestone and bond requirements do not apply to satellites that are already in- orbit and operating.9 111. ITU COST RECOVERY DIRECTV is aware that processing fees are currently charged by the International Telecommunication Union (“ITU”) for satellite filings and that Commission applicants are responsible for any and all fees charged by the LTU.1° DIRECTV is aware of and unconditionally accepts this requirement and responsibility to pay any ITU cost recovery fees associated with the ITU filings that the Commission makes on behalf of DIRECTV for the satellite relocation proposed in this application. ~ See, e.g., Jnielsat License LLC~ Modi,flcation Application to Redeploy and Operate fntelsat 16 at 58.1° W.L., File No. SAT-MOD-20160201-00009, Condition No. 12 (stamp grant May 18. 2016) (“Because [ntelsat 16 is already in-orbit and operating, grant of authority to operate Intelsat 16 at 58.1° W.L. is not subject to milestone conditions and Intelsat is not required to post a bond. As such, waiver of Sections 25.164(a) and 25.165 of the Cornmission’s rules is not necessary.”). ~ See Implementation ofITU Cost Recovery Charges!ör Satellite Network Filings. Public Notice, 16 FCC Rcd 18732 (2001).

IV. CONCLUSION For the reasons set forth above, DIRECTV respectfully requests that the Commission grant this modifkation application. Respectfully submitted. i)IRECTV ENTERPRiSES, LLC By :/s/ Steve ,Dulac Steve Dulac Director, Content Technology & Regulatory Policy Of Counsel: Jennifer D. Hind in Daniel P. Brooks WILEY REIN LLP 1 776 K Street. NW Washington, DC 20006 Tel: (202) 719-7000 Fax: (202) 719-7049 jhindin~wileyrein.com dbrooks@,wi leyrein.com June 25, 2019


Document Created: 2019-08-15 13:24:38
Document Modified: 2019-08-15 13:24:38
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