Attachment request

request

REQUEST submitted by DIRECTV

request

2004-06-29

This document pretains to SAT-STA-20030903-00300 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2003090300300_382694

                       IFOR INTERNAL USE ONLY
                       r
                                                           1
                                                                              I200 EIGHTEENTH STREET, NW
                                                                              WASHINGTON, DC     20036

                                                                              TEL 202.730. I300 FAX 202.730. I30 I
                                                                              WWW.HARRISWILTSHIRE.COM

                                                                              ATORNEYS AT LAW




                                         June 23,2004
                                                                                                       G n




       Re;     DIRECTV, Inc., Request for Special Temporary Authority to Relocate
               DIRECTV-3 to 82 W.L. and to Conduct Telemetry, Tracking and
                                    O

               Command (“TT&C”) Operations for an Interim Period
               File No. SAT-STA-20030903-00300
               Request for Confidential Treatment
Dear Ms. Dortch:

        On October 7,2003, DIRECTV Enterprises, LLC,’ on behalf of itself and its
subsidiaries and affiliates (“DIRECTV”), requested that the Commission withhold certain
documents submitted in connection with the above-referenced STA request from public
inspection and accord them confidential treatment pursuant to sections 0.457 and 0.459 of
the Commission’s rules, 47 C.F.R. $0 0.457, 0.459. On March 22, 2004, the International
Bureau issued a Protective Order in this proceeding that covered those and other related
documents that had been submitted to the Commission.2 Today, DIRECTV advised the
International Bureau of the finalization of the operational agreement between DIRECTV
and Telesat Canada that is referenced in the documents previously submitted and should
be associated with them in the record of this proceeding.

       DIRECTV today is submitting this operational agreement directly to Messrs. Jay
Whaley and Karl Kensinger of the International Bureau, along with a copy of this letter.
DIRECTV hereby requests confidential treatment for this supplemental documentation,
incorporating by reference the detailed justifications set forth in its October 7, 2003

1
       DIRECTV Enterprises, LLC is a licensee in the high-power Direct Broadcast Satellite service and
       a wholly owned subsidiary of The DIRECTV Group, Inc.
2
       See DIRECTVEnterprises, LLC, 19 FCC Rcd. 5255 (Int’l Bur. 2004) (“Pr


HARRIS,WILTSHIRE& GRANNIS
                        LLP

Marlene H. Dortch
June 23,2004
Page 2 of 2

submission, which remain applicable. DIRECTV is voluntarily providing this trade
secret and commercial and financial information “of a kind that would not customarily be
released to the public” and, therefore, this information is “confidential” under Exemption
4 of the Freedom of Information          Moreover, DIRECTV would suffer substantial
competitive harm if this documentation and the information contained therein were
publicly di~closed.~  Accordingly, DIRECTV requests confidential treatment pursuant to
the Protective Order.

       Please do not hesitate to contact the undersigned with any questions.

                                                  Respectfully submitted,




                                                  William M. Wiltshire
                                                  Michael D. Nilsson
                                                  HARRIS,WILTSHIRE     & GRANNIS
                                                                               LLP
                                                  1200 1gth Street, N. W.
                                                  Washington, DC 20036

                                                  Counselfor DIRECTV Enterprises, LLC


cc:    Thomas Tycz (without enclosure)
       Jay Whaley (with enclosure)
       Karl Kensinger (with enclosure)
       Bruce Jacobs (with enclosure)
       Kirsten Embree (with enclosure)
       Pantelis Michalopoulos (with enclosure)
       Howard Symons (with enclosure)
       Phillip Spector (with enclosure)




3
       See Critical Mass Energy Project v. NRC, 975 F.2d 871, 879 (D.C. Cir. 1992).
4
       See National Parks & Conservation Ass’n v. Morton, 498 F.2d 765 (D.C. Cir. 1974).



Document Created: 2004-07-13 15:03:26
Document Modified: 2004-07-13 15:03:26

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