Attachment supplemental filing

supplemental filing

SUPPLEMENT submitted by Inmarsat Group Holdings Limited

supplemental filing

2004-12-16

This document pretains to SAT-MSC-20040210-00027 for Miscellaneous on a Satellite Space Stations filing.

IBFS_SATMSC2004021000027_411592

108 Bm sven nw. um eeo Hategen 0. mosersoe 1e« goniesramo rec aonisraze sw LATHAMeWATKINS« tm.Hiiom Same We Sogs seventign hm npm howes fow Kearow Smd o forges wrmgim desvagy Srowse RECEIVED Yninigon.oc December 16, 2004 DEC 1 7 207 Kasd ros on Ff&v’“«::fl,”“w"""'"'"w eceived Recei Ms. Marlene H. Dortch bet 2 8 gi0e Secretary Policy Brench Federal Communications Commission Into Bureau 445 12" Street, S.W. Washington, D.C. 20554 Re: Supplemental Submission SAT—MSC—20040210—00027 Request for Declaratory Ruling Dear Ms. Dortch: This leter is submitted on behalf of Inmarsat Group Holdings Limited (*Inmarsat‘) to supplement its November 15, 2004 Request for Declaratory Ruling in this matter (the "Request"). In the Request,Inmarsat addressed, among other things, the requirement in Section 621(5)(F)G)of the ORBIT Act that "no intergovernmental organization has...more than a minimal ownership interest in a successor entty of Inmarsat."‘ Namely, Inmarsat explained that + the International Mobile Satellite Organization ("IMSO") is the only intergovernmental organization that has any ownership interest in Inmarsat * 1MSO is residual entity left in place by the Inmarsat Assembly of Parties when the decision to privatize Inmarsat was made in early 1999; * IMSO‘s sole involvement in Inmarsat is the oversight ofcertain public services, mainly the continued provision of space segment capacityfor the global maritime distress and safety system ("GMDSS®); and ! ORBIT Actat § 621(5)(P)GQMD

Orcenter sez00e Pagea LATHAMeWATKINS@ * IMSO‘s ownership in Inmarsat is limited to a *special share" of Inmarsat Ventures Limited that confers neither any normal voting rights nor any rights o participate in Inmarsat‘s profits; it only gives IMSO the right to veto any proposals to amend those provisions of the Memorandum ofAssociation or Articles of Association of Inmarsat Ventures Limited that relate to Inmarsat‘s public service obligations, especially GMDSS Inmarsat herebyconfirms that the nature and extent of IMSO‘ limited ownership interest in Inmarsat remain as they were in 2001 when the Commission determined that the sole ownership interest in Inmarsat held by IMSO constitutes "minimal ownership" by an intergovernmental organization within the meaning of the Orbit Act.* Moreaver, based on its review of distress alert data from the Distress Alert Quality Control System (DAQCS), Inmarsat has determined that GMDSS—related traffic on the Inmarsat system accounts for less than 1% of Inmarsat‘s total revenus for the twelve months ended October 31, 2004 Respectfully submitted, Inmarsat Group Holdings Limited Fgton, D.C. 20004 (202) 637—2200 ee: Roderick K. Porter Thomas S. Tycz Steven Spacth Andrea Kelly Marilyn Simon JoAnn Lucanik See In the Matter of Comsat Corporation d/b/a Comsat Mobile Communications, eal, 16 FCC Red 21,661, 21,686 (2001).

CERTIFICATION OF INMARSAT GROUP HOLDINGS LIMITED 1, Andrew Sukawaty, Chairman and ChiefExecutive Officer for Inmarsat Group Holdings Limited (together with ts subsidiaries, "Inmarsat"), declare under penalty of perjury as follows: () Inmarsat has achieved substantial dilution ofthe aggregate amount of former signatory financial interest in Inmarsat; (i) Any signatories or former signatories that etain a financialinterest in Inmarsat do not possess,together or individually, effective control ofInmarsat; (ii) No intergovernmental organization has more than a minimal ownership interest in Inmarsat; and, (iv) Thave read Inmarsat‘s November 15, 2004 Request for Declaratory Ruling and the Attachments thereto, as supplemented by the foregoing letter dated December 16, 2004. The representations contained therein are true and correct Inmarsat Group Holdings Limited fete tss 4 Andrew Sukawaty Chairman and Chief Executive Officer Executed on: December 16, 2004


Document Created: 2004-12-28 14:29:33
Document Modified: 2004-12-28 14:29:33
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