Second Extension of

REQUEST submitted by Intelsat License LLC andn Intelsat New Dawn Company, Ltd.

Request for Extension of Closing Deadline

2012-03-16

This document pretains to SAT-T/C-20110810-00160 for Transfer of Control on a Satellite Space Stations filing.

IBFS_SATTC2011081000160_945177

                                                                                                       Jennifer D. Hindin
1776 K STREET NW          March 16, 2012                                                               202.719.4975
WASHINGTON, DC 20006
                                                                                                       jhindin@wileyrein.com
PHONE     202.719.7000
FAX       202.719.7049


7925 JONES BRANCH DRIVE
                          Ms. Marlene H. Dortch, Secretary
McLEAN, VA 22102          Federal Communications Commission
PHONE     703.905.2800    445 12th Street, SW
FAX       703.905.2820
                          Washington, DC 20554

www.wileyrein.com
                          Re:     Intelsat License LLC and Intelsat New Dawn Company, Ltd.
                                  Request for Extension of Closing Deadline; File Nos. SAT-T/C-
                                  20110810-00160, SAT-T/C-20110811-00161, SES-T/C-20110811-00948,
                                  SES-T/C-20110812-00963, and 0004825139.

                          Dear Ms. Dortch:

                          Intelsat License LLC and Intelsat New Dawn Company, Ltd. (collectively, the
                          “Intelsat Licensees”), by counsel, respectfully request an additional 120 days—until
                          August 8, 2012—to consummate the pro forma transfer of control that the
                          Commission previously approved in the above-referenced proceedings.

                          On August 11, 2011, the Intelsat Licensees sought authority for the pro forma
                          transfer of control of all of the earth station, space station, and wireless licenses and
                          authorizations held by the Intelsat Licensees. Specifically, the Intelsat Licensees
                          proposed two non-substantial changes to the ownership of the Intelsat Licensees as
                          a part of a corporate reorganization: (1) the creation of new holding companies and
                          (2) the removal of certain holding companies.

                          On October 13, 2011, the International Bureau authorized the pro forma transfer of
                          control of the earth station and space station licenses held by the Intelsat Licensees.1
                          The Commission has extended the deadline for consummating the pro forma
                          transfer of the earth and space station licenses until April 10, 2012.2

                          On October 19, 2011, the Wireless Telecommunications Bureau authorized the pro
                          forma transfer of control of the wireless authorizations held by the Intelsat


                          1
                                   See Policy Branch Information; Actions Taken, Report No. SAT-00815, DA 11-1713, File
                          Nos. SAT-T/C-20110810-00160 and SAT-T/C-20110811-00161 (rel. Oct. 14, 2011; effective Oct.
                          13, 2011); Satellite Communications Services Information; Actions Taken, Report No. SES-01390,
                          File Nos. SES-T/C-20110811-00948 and SES-T/C-20110812-00963 (rel. Oct. 19, 2011; effective
                          Oct. 13, 2011).
                          2
                                   See Letter from Jennifer Hindin to Marlene H. Dortch, File Nos. SAT-T/C-20110810-
                          00160, SAT-T/C-20110811-00161, SES-T/C-20110811-00948, and SES-T/C-20110812-00963
                          (stamp grant Dec. 13, 2011).


Ms. Marlene H. Dortch
March 16, 2012
Page 2


Licensees.3 Pursuant to Section 1.948(d), 47 C.F.R. § 1.948(d), the deadline for
consummating the pro forma transfer of control of the wireless license is 180 days
after authorization—April 16, 2012.4

However, the corporate reorganization is still pending and additional time is needed
to conclude the business steps that are necessary prerequisites to the reorganization.
Grant of the requested extension will serve the public interest by permitting Intelsat
an opportunity to complete the already approved restructuring in a time frame
consistent with current business considerations.

Accordingly, the Intelsat Licensees respectfully request a 120-day extension of the
closing deadline. Please do not hesitate to contact the undersigned if you have any
questions.



Sincerely,

/s/ Jennifer D. Hindin

Jennifer D. Hindin

cc:      Karl Kensinger
         Jeanette Spriggs
         Jeff Tobias




3
          See Wireless Telecommunications Bureau, Assignment of License Authorization
Applications, Transfer of Control of Licensee Applications, De Facto Transfer Lease Applications
and Spectrum Manager Lease Notifications, Designated Entity Reportable Eligibility Event
Applications, and Designated Entity Annual Reports Action, Report No. 7258, File No. 0004825139
(rel. Oct. 26, 2011; effective Oct. 19, 2011).
4
          Intelsat understands that the requested extension until August 8, 2012 is not technically 120
days after the April 16, 2012 deadline for consummation of the pro forma transfer of the wireless
authorizations, Intelsat, however, seeks to conform the consummation deadline for the wireless
authorizations to the consummation deadline for the earth and space station licenses.



Document Created: 2012-03-16 14:59:16
Document Modified: 2012-03-16 14:59:16

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