Attachment Exhibit F#A21

This document pretains to SES-ASG-20020114-00098 for Assignment on a Satellite Earth Station filing.

IBFS_SESASG2002011400098_244398

Exhibit F Statement of Public Interest This attachment is submitted in response to FCC Form 312 – Schedule A, Item A21. Response to Item A21 The application seeks the FCC’s prior approval for the conversion of a Delaware corporation (Globalstar USA, Inc.) that is an earth station licensee into a Delaware limited liability company (Globalstar USA, LLC). Although it is arguable that under Delaware law the conversion would not constitute a pro forma assignment of licenses (an event requiring prior FCC approval), the applicant is filing this application out of an abundance of caution. Both before and after the proposed transaction, the ultimate U.S. parent of the license holder is Vodafone US Partners, a Delaware corporation. The ultimate owner of Vodafone US Partners is Vodafone Group, Plc. (“Vodafone”), a corporation headquartered in Newbury, United Kingdom. See also Exhibit E. The Commission has previously passed on the qualifications of Vodafone subsidiaries to hold FCC licenses. See, e.g., AirTouch Satellite Services US, Inc., 14 FCC Rcd 17328 (1999). The Wireless Telecommunications Bureau previously determined that “[b]ecause the United Kingdom is a member of the World Trade Organization (WTO), under the Commission’s Foreign Participation Order, we presume that the public interest would be served by authorizing, under Section 310(b)(4), common carrier radio licenses held by entities indirectly owned by Vodafone [Group Plc.] and citizens of the United Kingdom.” AirTouch Communications, Inc. and Vodafone Group Plc., 14 FCC Rcd 9430, 9434 (1999) (footnote omitted). Vodafone Group Plc. will continue to hold its indirect ownership of earth station licensees through U.S.- incorporated subsidiaries Vodafone US Partners and VAAI.


Document Created: 2019-04-20 11:38:09
Document Modified: 2019-04-20 11:38:09
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