Attachment Response

Response

REPLY submitted by Inmarsat Ventures Limited

Response

2007-07-03

This document pretains to SES-AMD-20070112-00106 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2007011200106_576605

                                              Before the                    QR*B‘NAL
                             Federal Communications Commission
                                        Washington, D.C. 20554

In the matter of                    )     File Nos.
                                    )
Telenor Satellite, Inc.             )     SES—LFS—20050930—01352 (Call Sign £E050276)
Application for Title III Blanket   )     SES—AMD—20051111—01564                 ?ggfigggfigggggfigfigg
License to Operate BGAN             )     SES—AMD—20060109—00019                                  C
Terminals with Inmarsat 4F2 at©     y     SES—AMD—20060607—00942                        s4L s Pipy
52.I5°W                             )     ~SES—AMD—20070112—00106                                   o
                                    )                                                   1

FTMSCE US, LLC                      )     ~SES—LFS—20051011—01396 (Call Sign EO50284)
Application for Title III Blanket   )     SES—AMD—20051118—01602
License to Operate BGAN             ) ~SES—AMD—20060605—00926                    RECEIVEp
Terminals with Inmarsat 4F2 at      )     SES—AMD—20060804—01315
52.75°W                             )                                              JUL 1 7 2007
                                                                                   Satellite Divigion
                                               REPLY                             internationaltBureay

       Mobile Satellite Ventures Subsidiary LLC ("MSV") hereby files this Reply to the

Responses submitted by VIZADA Services LLC (“VLZADA”),1 Telenor Satellite, Inc.

("Telenor"), and Inmarsat Ventures Limited ("Inmarsat") concerning the Supplement filed by

MSV in the above—referenced proceedings." In the Supplement, MSV requested that the

Commission limit to no more than 5,000 terminals the combined total of Broadband Global Area

Network ("BGAN") terminals the two now—affiliated applicants are permitted to operate in the

United States under Special Temporary Authority ("STA"). MSV cited uncontradicted evidence

that 5,000 terminals is far more than the companies have customers for and expressed its concern




~VIZADA was formerly FTMSC US, LLC and changed its name on June 7, 2007. See
VIZADA Services, LLC, Request for Special Temporary Authority, File No. SES—STA—
20070619—00833, at Attachment 1.
* See VIZADA Services LLC and Telenor Satellite, Inc., Reply to Supplement (July 2, 2007);
Inmarsat Ventures Limited, Response of Inmarsat Ventures Limited (July 3, 2007) (hereafter,
collectively "Responses").


that the excess capacity serves only to disincentivize Inmarsat from coordinating the satellite it

uses to provide BGAN service. Nothing in the Responses rebuts MSV‘s conclusions.

        No party disputes MSV‘s key point that the Commussion authorized an excessive number

of BGAN terminals and that drastically reducing the number of terminals authorized to the two

affiliates would cause no harm to any entity. Instead, VIZADA and Telenor claim that MSV has

provided no evidence of harmful interference from BGAN operations." MSV does not concede

that BGAN operations have not caused harmful interference to MSV. In any event, however, the

current operation of only a few BGAN terminals demonstrates nothing regarding the potential

for interference if an increasing number are operated in the future. The fact that the STA

operations are authorized on a non—interference basis does not moot this concern, as VIZADA

and Telenor imply.* Such a condition simply requires MSV and its customers to suffer

interference before action is taken to mitigate the interference.

        VIZADA, Telenor, and Inmarsat also question how the continued authorization of BGAN

terminals distorts the coordination process." Inmarsat even boldly claims that it "has every

incentive to coordinate with MSV. * But that is far from the truth. Because each of Inmarsat‘s

distributors has more capacity than it needs now or in the near future and the FCC continues to

grant renewals of the STAs to provide BGAN service, Inmarsat is effectively providing BGAN

service to the U.S. without any coordination agreement and has no practical need to coordinate

its satellite any time soon. Accordingly, for the above reasons, MSV requests that the



* See VIZADA Services LLC and Telenor Satellite, Inc., Reply to Supplement, at 2 (July 2,
2007).
* See id. at 2 n.1.
° See id. at 2; Inmarsat Ventures Limited, Response of Inmarsat Ventures Limited, at 2 (July 3,
2007).
° Inmarsat Ventures Limited, Response of Inmarsat Ventures Limited, at 2 (July 3, 2007).


Commission drastically reduce the aggregate number of BGAN terminals authorized to

VIZADA and Telenor.




                                  Respectfully submitted,
                       % &                            ;f          .       /%Z.       Z


 Bruce D. Jakoby                               Jenx{;{fér A. Manner
 Tony Lin                                      Vice President, Regulatory Affairs
 PILLSBURY WINTHROP                            MOBILE SATELLITE VENTURES
        SHAW PITTMAN LLP                                SUBSIDIARY LLC
 2300 N Street, NW                             10802 Parkridge Boulevard
 Washington, DC 20037—1128                     Reston, Virginia 20191
 (202) 663—8000                                (703) 390—2700

Dated: July 13, 2007


                                 CERTIFICATE OF SERVICHE

        1, Sylvia Davis, a secretary with the law firm of Pillsbury Winthrop Shaw Pittman LLP,
hereby certify that on this 13°" day of July 2007, I served a true copy of the foregoing by first—
class United States mail, postage prepaid, upon the following:


John P. Janka                                      Diane J. Cornell
Jeffrey A. Marks                                   Vice President, Government Affairs
Latham & Watkins LLP                               Inmarsat, Inc.
555 Eleventh Street, N.W.                          1101 Connecticut Avenue NW
Suite 1000                                         Suite 1200
Washington, DC 20004                               Washington, DC 20036

Peter A. Rohrbach                                  Keith H. Fagan
Karis A. Hastings                                  Robert W. Swanson
Hogan & Hartson L.L.P.                             Telenor Satellite, Inc.
555 13"" Street, N.W.                              1101 Wootton Parkway
Washington, D.C. 20004                             10°" Floor
                                                   Rockville, MD 20852
Counsel for VIZADA Services LLC
                                                   Nancy J. Victory
                                                   Catherine M. Hilke
                                                   Wiley Rein LLP
                                                   1776 K Street NW
                                                   Washington, DC 20006

                                                   Counsel for Telenor Satellite, Inc.




                                                 $yiv1 a Davis







Document Created: 2007-07-03 16:16:04
Document Modified: 2007-07-03 16:16:04

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