Attachment request

request

REQUEST submitted by Inmarsat

request

2005-10-04

This document pretains to SAT-PPL-20050926-00184 for Permitted List on a Satellite Space Stations filing.

IBFS_SATPPL2005092600184_459000

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LATHAMeWATKINS«                                                    Som      fevtet
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                                       OCT 0 5 2005                Hantuy   Smd
   October 4, 2008                                                 reegrong Smrmaico
                                       Poly Branch                 tonien      Stegw
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   Mr. Donald Abelson                                              Nerluner    vtiegon 06
   Chief, International Bureau
   Federal Communications Commission                                                RECEIVED — FGG
   445 12th Street, S.W.
   Washington, D.C. 20054                                                                 OCT ~ 4 2008
          Re:4    Request to Designate
                                 i
                                       Proceeding as @"Permit But Disclose
                                                                    i     »                 Mimiys ggtspal
                                                                                   FedeatConmunicaion   in
                  EXPEDITED PROCESSING REQUESTED

                  Inmarsat Global Limited
                                        20050926—00184

   Dear Mr. Abelson:

                  Inmarsat Global Limited (‘Inmarsat") respectfully requests that the Commission
   designate as "permit but disclose" the exparte status of this proceeding, which involves
   Inmarsat‘s Petition for Declaratory Ruling to serve the U.S. with a 2 GHz MSS spaceeraft. The
   Commission has discretion to modify the application of its ex parterules in any particular
   proceeding where, as here, the public interest warrants doing so. 47 C.F.R. § 1.1200(@).
                  This matter is inextricably intertwined with two pending proceedings where the
   Commission is considering licensing "returned" 2 GHz MSS spectrum to TMTerreStar and
   1CO, IB Docket Nos. 05—220 and 05—221. Both ofthose proceedings () involve proposals to
   modify the satellte authorizations ofother entities, and (i) have been designated "permit but
   disclose" for exparte purposes.. Inmarsat‘s submissions in those two proceedings discuss its
   general plans for the 2 GHz satellite network with respect to which authority is sought here, and
   those intentions are more specifically delineated here.
                  Therefore, the free exchange ofviews made possible by "permit but disclose"
   status would allow for a more complete record," and would apply the same ex parte rules to

          ‘ Comments Concerning Use ofPortions ofReturned 2 GHz Mobile Satellie Service
   Frequencies, ECC 05—133, 05—134 (rel. Tune 29,2005).
           * See, e.g. Public Notice, Report No. SPB—136 (Aug. 25, 1998) (modifying ex parte
   status of contested TMZ earth station application to "permit but disclose" to "assist the
   Commission in developing a complete record on which a well—reasoned decision can be made").


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LATHAM®WATKINS«

     Inmarsat‘s 2 GHz request as those that apply to the pending requests of TMUTerreStar and ICO
     for additional 2 GHz spectrum. Conducting this matter on a permit—but—disclose basis also would
     be consistent with the ex parte treatment of otherxeqnms for satellite—related authorizations that
     were related to pending rulemaking proceedings
                    Inmarsat respectfully secks expedited grant ofthis request to allow it to continue
     the dialogue with the Commission that Inmarsat was able to have prior to TMUTerreStar‘s
     October 3, 2005 letter indicating its intention to participate in this proceeding.
                                                  Respectfully submitted,




     ce (by hand):
             Roderick K. Porter, Deputy Chief, International Bureau
             Gregory C. Staple
             Edward Price
             viNson & BLINS
             1455 Pennsylvania Avenue N.W.
             Washington, D.C. 200041008
             Counselfor TMI Communications and
                    Company Limited Partmership
             Jonathen D. Blake
             Kurt A. Wimmer
             Matthew S. DelNero
             COVINGTON & BURLNG
             1201 Pennsylvania Avenue N.W.
             Washington, D.C. 20004—2401
             Counselfor TerreStar Networks Inc.




             * See, e.g.Motion to Designate Proceedings as "Permit But Disclose,"SAT—MOD—
     20031118—00333, SAT—AMD—20031 118—00332 (iled Nov. 19, 2003, granted by grant stamp
     Dec.2, 2003) (liting "restricted" status ofMSV satellte modification application in light of the
     related pending ATC rulemaking).



Document Created: 2005-10-06 14:47:00
Document Modified: 2005-10-06 14:47:00

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