Attachment Opposition

This document pretains to SES-LFS-20050826-01175 for License to use Foreign Satellite (earth) on a Satellite Earth Station filing.

IBFS_SESLFS2005082601175_465796

"RECEIVED cm wov 1 7 2005 Before the RECEIVED . seteite Dvision FEDERAL COMMUNICaTiONs commssion NOY 1 0 200 IntormatonaiBureau Washington, DC 20554 Federl . Commnicatone Comnissn Offen t Seaiay ) In the Matter of § ) Stratos Communications, Inc ) File No. SES—LES—20050826—001175 Application for Title I1l Blanket License ) File No. SES—AMD—20050922—0313 to Operate Mobile Earth Terminals with ) Inmarsat4F2 at 52.75° W.L ) ) Stratos Communications, Inc ) File No. ITC—214—20050826—00351 Application for Section 214 Authorization ) to Operate Mobile Earth Terminals with ) Inmarsat 4F2 at 52.75° W.L ) in To: International Bureau OPPOSITION TO MSV PETITION TO HOLD IN ABEYANCE OR TO GRANT WITH CONDITIONS Alffed M. Mamlet Philip L. Malet Mare A. Paul Sreproe & Joinson i 1330 Connecticut Avenue NW Washington, D.C. 20036—1795 (202) 420—3000 Counsel to Stratos Communications, Inc. November 10, 2005

TABLE OF CONTENTS INTRODUCTION AND SUMMARY . 1. MSV HAS NOT PROVIDED A LEGITIMATE BASIS FOR CONDITIONING OR DELAYING GRANT OF THE STRATOS BGAN APPLICATION A.—— Grant of the Stratos BGAN Application Should Not Be Delayed Pending Completion of a New L—band Coordination Agreement. B. Stratos Should Not Be Prevented From Using AnyAvailable Inmarsat Spectrum.. C.— The Inmarsat 4F2 Satellite Is Properly Regarded As A Replacement Satellit D. The Commission‘s FSS Station Keeping Rule Does Not Apply to MSS Satellites E. Stratos Has Satisfied Its Obligations Under DISCO 1 For National Security, Law Enforcement and Public Safety Concerns.. us CONCLUSION

Refore the RECEIVED FEDERAL COMMUNICATIONS COMMISSION NOV1 0 2005 Washington, DC 20554 Fede Commnieato Conmisson OftcclSecntay In the Matter of Stratos Communications, Inc. File No. SES—LFS—20050826—001 175 Application for Title I1I Blanket License File No. SES—AMD—20050922—01313 to Operate Mobile Earth Terminals with Inmarsat 4F2 at 52.75° W.L. Stratos Communications, Inc File No. TC—214—20050826—00351 Application for Section 214 Authorization to Operate Mobile Earth Terminals with Inmarsat 4F2 at 52.75 W.L memaremmremmmmmnaay To: International Bureau OPPOSITION Pursuant to Section 25.154(c) of the Commission‘s Rules, 47 C.F.R. § 25.154(c), Stratos Communications, Inc. ("Stratos") hereby opposes Mobile Satellte Ventures Subsidiary LLC‘s (MSV‘s") Petition to hold in abeyance or to grant with conditions the above—captioned applications of Stzatos (collectively referred to as the "Stzatos BGAN Application‘)," ‘ See MSV Petition To Hold in Abeyance Or To Grant With Conditions (Oct. 28, 2005) (‘MSV Petition®). Concurrently with this Opposition, Stratos is filig a Motion to Strike Portions ofthe MSV Petition. See Stratos Motion to Strike (filed Nov. 10, 2005), As set forth in that Motion to Strike, the MSV Petition should be dismissed by the Bureau because it contains confidentil information and redacted arguments that Stratos has not been given access to by MSV, thereby depriving Stratos of a full and fair opportunity to defend its applications. At a minimum, the Bureau cannot base anydecision to hold in abeyance, or grant with conditions, the Stratos BGAN Application on what has been deemed confidential by MSV and withheld from Stratos. As set forth in the Motion to Strike, to do otherwise would un afoul of the Commission‘s obligations under the Administrative Procedures Act ("APA®). To the extent that Stratos is given access to the confidentialinformation contained in the MSV Petition after this Opposition is filed, Stratos reserves the right to amend this Opposition as necessary.

. INTRODUCTION AND SUMMARY The Stzatos BGAN Application seeks authority for Stratos to offer the Inmarsat Broadband Global Area Network (‘BGAN®) services in the United States through mobile carth terminals (‘METs®) communicating with a recently (November 8, 2005) launched fourth generation Inmarsat satelite to be located at 52.75° W.L. ("the Inmarsat 4F2 satellite"). Grant of the Stratos BGAN Application is in the publicinterest because it will allow U.S. consumers to obtain an enhanced Mobile Satellite Services (°MSS") offering (including email, LAN, Internet, video conferencing and voice communications) at data tansmission speeds of up to 492 kbps, several times more than current MSS product offerings, and more than 100 times faster than MSV‘s servicesWith the launch earlier this year of another fourth generation Inmarsat satellite ("the Inmarsat 4F1 satellite‘),customers in Europe, Africa, the Middle East and Asia will have access to Inmarsat‘s BGAN service by the end ofthis year. The Inmarsat 4F2 satellte was successfully launched on November 8, 2005. If prompily approved, the Stratos BGAN Application will provide U.. consumers with the same opportunity to enjoy high speed MSS by early 2006, when testing ofthe Inmarsat 4F2 satellte is complete. The recent natural disasters associated with hurricanes Katrina, Rita and Wilma in the Gulf of Mexico region demonstrate an urgent need for the BGAN offering and prompt approval ofthe Stratos BGAN Application..Inthe aftermath of these hurricanes, the current Stratos/Inmarsatservice was used by FEMA, the National Guard, the U.S. Army, state and local governments, law enforcement personnel and the petroleum industry to facilitate voice communications and Intemet access in the absence oftrrestrial networks. Although serving a vital role in the recovery and restoration efforts, the data transmission speeds of Inmarsat‘s * See hitp://www. msvlp.com/solutions/voice_dial_service.cfm (indicating that the MSV "Cireuit Switched Data provides 2400 bps. ..and 4800 bps throughput") 3.

current service do not match the high speed terrestral networks people now rely on and come to expect. With the higher data speeds offered by BGAN, these government "First Responders® and private industry will have available to them a genuine high speed backup to terrestrial Interet and data communications networks when the next natural disaster, or terroristattack, takes place. Rather than compete with the BGAN offering in the marketplace, MSV seeks to derall the introduction of these advanced services to U.S. consumers and First Responders. In addition, MSV attempts to use the fling ofthe Stratos‘s BGAN Application as leverage to resolve an on—going dispute between MSV and Inmarsat that is not t issue in this proceeding, but should be resolved through the agreed—upon mechanism for international coordination established under the Mexico City Memorandum of Understanding (*Mexico City MoU®). The effect of the MSV Petition is to deprive and delayU.S. consumers and First Responders of a much needed service that virtually the rest of the world will soon have access to. ‘The Bureau should not be distracted by MSV‘s efforts to use the Stratos BGAN Application as a pawn in its on—going dispute with Inmarsat. ‘The Stratos BGAN Application satisfies the Commission‘s Rules and should be prompily granted by the Bureau. Contrary to the claims of MSV, a new intemational L—band coordination agreement is not needed before the Stratos BGAN Appliation can be granted. Indeed, two MSV satellite applications (one for a replacement satellitat 101° W.L.. and a new satellite at 63.5° W.L.were granted by the Bureau this year on a non—interference basis and in the absence of a new L—band coordination agreement. There is no justification for treating the Stratos BGAN Application and its proposed use of the Inmarsat 4F2 satellte differently.

Further, the Stratos BGAN application does not contain the three deficiencies claimed by MSV to warrant further "scrutiny" by the Bureau" First, under the Commission‘s Rules, the proposed Inmarsat 4F2 satellteis properly considered a replacement satelite for the third generation Inmarsat satllite ("Inmarsat 3 satellite") at 54° W.L. because it will cover the same geographic areas as that satellite, and does not seck to use any additional L—band frequencies beyond those currently in use. Second, despite MSV‘s suggestion otherwise, Section 25.210() of the Commission‘s Rules, 47 C.F.R. § 25.210(), requiring FSS satelltes to operate with +/0.05° East—West station keeping, does mor apply to MSS satellites. Third, as set forth in the Stratos BGAN Application, Stratos has fullysatisfied the Executive Branch and FBI that the BGAN METs proposed use in the U.S. will not hinder any lawenforcement and national security efforts. The Bureau should prompily grant the Stratos BGAN Application and allow U.S. consumers to enjoy the same 492 kbps MSS that users in the rest o the world will soon have. 1t MSV HAS NOT PROVIDED A LEGITIMATE BASIS FOR CONDITIONING OR DELAYING GRANT OF THE STRATOS BGAN APPLICATION Rather than pursuing its spectrum dispute with Inmersat as part ofthe established interational coordination procedures for the L—band, MSV is attempting to use its Petition against the Stratos BGAN Application as leverage for resolving an on—going and protracted L~ band spectrum dispute with Inmarsat. Allowing MSV to do so would be inconsistent with the Commission‘s obligations under the Mexico City MoU, violate the D/SCO// principles regarding the treatment of applications for access to foreign satellites licensed by WTO Member countries, and succeed in delaying the introduction to the U.S. of a much needed MSS offering ° See MSV Petition at 10—14.

that the rest of the world will soon have. The Bureau must rejectthe arguments in the MSV Petition. A. Grant of the Stratos BGAN Appllul n Should Not Be Delayed Pending Completion of a New L—band Cooi tion Agreement MSV suggests that the Stratos BGAN Application should be delayed pending the "conclusion of a coordination agreement that results in a more efficient assignment ofL—band spectrum among the existing operators, including the assignment of contiguous and wider frequency blocks."" a The absence ofan L—band coordination agreement, however, is not an adequate justification for the Bureau to delayaction on the Stratos BGAN Application. Just this year, the Bureau granted two MSV appliations to operate in the L—band —— one for a replacement satellite at 101° W.L.. and one for a new satellte (%e, a satellite not contemplated by the Mexico City MoU)at 63.5° W.L.® Rather than delaying action on either application pending the completion of a new L—band coordination agreement, both applications were granted on a "non—harmful interference basis t other mobile—satellite service systems operating in the L—band."" Stratos simply asks that the Bureau treat the Stratos BGAN Application similarly. Indeed, since the UK is a WTO Member, the U.S. has an obligation to do so. 7 * MSV Petition at 1. 5 See In the Matter ofMobile Satellite Ventures Subsidiary LLC, DA 05—50 (rel. Jan. 10, 2008) ("MSV 63.5° W L. Order®); In the Matter ofMobile Satellite Ventures Subsidiary LLC, DA 05—1492 (rel. May 23, 2008) (CMSY 107° TL Order®). * See MSV 63.5° W.L. Order at 1 39; MSY 107° W.L. Order at 1 59. " See SaiCom Systems, Inc. t al. 14 ECC Red. 20798, 20813 (1999) (°TMF Marker Aecess Order")(rejecting the attempt of AMSC to preclude other L—band systems from serving the U.S. until AMSC had completed coordination of 20 MHz of spectrum because doing so *would be inconsistent with U.S. market access commitments in the WTO Agreement"); Amendment ofthe Commission‘s Regulatory Policies to Allow Non—U.S. Licensed Satellites a$s

MSV suggests that the Stratos BGAN Application should be treated differently because the Inmarsat 4F2 satellite will use "wide band" carriers which will resultin an increased tisk of harmful interference to other L—band operators.". According to MSV, a new L—band coordination agreement is needed to eliminate the isk of such interference." MSV‘s claims of increased risk of interference due tothe use of "wide band" carriersare not accurate for several reasons. First, the Inmarsat 4F2 satelite does not use "wide band" carriers. Indeed, the widest carriers set forth in the application are 200 kHHz."" Conveniently, MSV fails to note that the widest carriers of its own recently approved replacement satellite at 101° W.L.. are 5 MHz." However, despite carriers 25 times wider than those on the Inmarsat 4F2 satellie, the Bureau granted MSV‘s application without requiring completion of a new L—band coordination agreement. There is no reason to treat Stratos‘s application for the Inmarsat BGAN service any differently. Second, MSV fails to substantiateits claims thatthe Inmarsat 4F2 satellte will cause "harmfulinterference" to other L—band operators."" The Inmarsat 4F2 satellite contains numerous technical advancements for reducing interference when compared to the Inmarsat 3 satelltethatit will replace, including narrower spot beams with steeper antenna side lobes which will reduce interference to adjacent areas. Because the BGAN METs operate at one—tenth the Providing Domestic and International Service in the United States, 12 FCC Red. 24094, 24104(1997)("DISCO /7") (recognizing the US commitment "to provide market access to all basic telecommunications services and national treatment to service suppliers of WTO members®). * See MSV Petition at 7—8. * ul ‘° See Stratos BGAN Application (Title 11)at Attachment A (Technical Narrative),pp. 2137. " See File No. SAT—AMD—20031118—00335 at Appendix A, p.23. "" See MSV Petition at 7—9.

power of existing high speed data METs using the Inmarsat3 satellite at 54° W.L., the level of interference generated by the BGAN service will bless, not more, than what is currently experienced in the L—band."". As the Bureau recognized, the current L—band operators have been operating "interference—free" for some time."" MSV has not provided any evidence to suggest that this "interference—free" operation will change with the Iaunch and operation ofthe Inmarsat 4B2 satellite. Like the MSV satelltes,the Stratos BGAN Application secking use of the Inmarsat 4F2 satellte should be granted by the Bureau on a non—harmful interference basis and without waiting for a newinternational L—band coordination agreement. As the Commission has clearly stated, "[wJithout an agreement assigning each of the five systems to specific operating frequencies, all systems must operate on a non—interference basis consistent with the ITU Radio Regulations."* B.— Stratos Should Not Be Prevented From Using Any Available Inmarsat Spectrum MSV also suggests thatif the Stratos BGAN Application is granted, it should be conditioned on the BGAN METs and the Inmarsat 4F2 satellite not using any frequencies that were "loaned" by MSV to Inmarsat.* Stratos opposes such a condition. If MSV has a dispute ‘" See Stratos BGAN Appliation at Schedule B; see Stratos Call Signs E010047, £010048 and 010080. "* See MSY 63.3° W.L. Order at‘* 23 ("While the most recent annual operator—to—operator agreement has not been renewed since1999, the five parties have continued to coordinate their operations informally and have been operating interference—free.");MSV 101° W.L. Order at 34. "* TMI Market Access Order, 14 FCC Red. at 20814. in the Matter ofCOMSAT Corporation db/a COMSATMobile Communications et al. 16 FCC Red. 21661, 21699 (rel. Oct.9, 2001) (*Anmarsar Market Access Order") (‘IWe conclude that the absence of an annual operator—to—operator agreementis not a suficient basis upon which to deny the applications presented here."). ‘* See MSV Petition at 9.

over the current distribution and coordination of L—band spectrum, it should bring this dispute with Inmarsat in accordance with the agreed—upon procedures forintemational coordination, not in this application proceeding."" The BGAN METs in the Stratos BGAN Application should be fiee to use all of the L—band frequencies used by Inmarsat, subject t the outcome of any international coordination. Subject to a non—interference condition, the Commission has consistently held that MSV, TMI, Stratos and others could use the entire range of L—band frequencies in the absence of a coordination agreement."* There is no reason to treat Stratos differently now. Ifinternational coordination changes the spectrum available to Inmarsat, Stratos will modify the operations ofits BGAN METs accordingly.. Until that time, however, there is no reason to delay approval ofthis application and the introduction of the Inmarsat BGAN service to the U.S. C..— The Inmarsat 4F2 Satellite Is Properly Regarded As A Replacement Satellite Citing the Commission‘s bond posting rule (47 C.F.R. § 25.165(e)), MSV suggests that the Inmarsat 4F2 satellte is not properly regarded as a replacement satellite because it is unclear whether the Inmarsat 4F2 satellite wl serve the same geographic areas as the satellite it is replacing.""" As a threshold matter,the Commission‘s bond posting rule is not applicable here since the Inmarsat 4F2 satellite was launched on November 8, 2005, and the bond requirement does not apply to satellites that have been launched. Regardless, the Inmarsat ‘" Despite what MSV may imply, the Bureau acknowledges in the MSF 63.5° L. Order and MSV 101° W.L. Order that "informal® arrangements nowgovern the coordination of L—band spectrum, not the 1999 coordination agreement...See MSF 63.5° L. Order at 1 23; MSF 107° W.L. Order art 34. "* See MSV 107° W.L. Order at 1 34; See MSV 63.5° W.L. Order at1 23; Inmarsat Market Access Order, 16 ECC Red. at 21712; TMI Market Access Order, 14 FCC Red. at 20814. ‘" See MSV Petition at 10.

4F2 satellteis properly regarded as a replacement satellte. Through the Inmarsat 3 satellte at 54° W.L., Stratos currently provides Inmarsat services to the continental U.S., Puerto Rico and the U.S. Virgin Islands.. Although 1.25¢ further east,the Inmarsat 4F2 at $2.75° W.L. will also serve the continental U.S., PuertRico and the U.8. Virgin Islands, as well as operate over the same L—band service link frequencies that are authorized for use on the Inmarsat 3 satellite at 54° W.L... Despite what MSV may imply, Stratos does not seek FCC authority to use the BGAN METs in conjunction with the Inmarsat 4F2 satellie in any regions ofthe U.. which are not presently served by the Inmarsat3 satelit. Accordingly, under the Commission‘s Rules, the Stratos BGAN Application and proposed use of the Inmarsat 4F2 satellite can be considered a replacement satellie. This was precisely the Bureau‘ treatment of MSV‘s satelliteapplication at 101° W.L. —— the Inmarsat 4F2 satellite should not be treated any differently.®" D. The Commission‘s FSS Station Keeping Rule Does Not Apply to MSS Satellites The MSV Petition states thatit is not clear whether the Commission‘s Rule, 47 C.F.R. §25.210(), requiring FSS satelltes to operate with +/0.05° East—West station keeping ®* See MSV 101° W.L. Order t 88 13—14. In fact, MSV‘s satellte at 101° W.L.increased its geographic coverage area from the satellte it replaced by adding parts of South America to ts coverage area, but t was still regarded as a replacement satellite by the Bureau. Compare MSV 101° W.L. Order at% 1 ("The satelite will provide MSS on a common carrier basis within the United States, and between the United States and North America, Central America, the northemn part of South America, and the Caribbean.") with Amendment ofParts 2, 22, 23 ofthe Commission‘s Rules to Allocate Spectrumfor and to Establish Rules and Policies Pertaining to the Use ofFrequencies in a Land Mobile Satellite Servicefor the Provision of Various Common Carrier Services, Memorandum Opinion and Order and Authorization, 4 FCC Red. 6041, 6053 (1989) ("The proposed beam coverage areas for the MSS network include the continental United States (CONUS), Alaska, Hawaii, Puerto Rico, Virgin Islands, Canada, parts of Mexico and Central America, including the Gulfof Mexico, and U.S. coastal areas up to 200 milesoff— shore.").

applies to MSS satellites."" a However, the Commission‘s Rule and subsequent decisions are very clear on this point —— Section 25.210G) does not apply to MSS satelltes. The Commission clearly enunciated this in its 2004 decision concering the mitigation of orbital debris: "We decline, at this time, to adopt changes to Section 25.210G) to specify a longitudinal tlerance of +/—0.05° for all space stations, including MSS and remote sensing space stations.""".Indeed, in filing a Petiion for Clarification or Partial Reconsideration of it 101° W.L. authorization, MSV acknowledged that "there is no rule requiring MSS satellites to operate with a +/> 0.05° East— West station keeping box.""" Section 25.210G) is not applicable to the Inmarsat 4F2 satellie, and accordingly, a waiver ofthis rule by Stratos is not required for the Stratos BGAN Application " E. Stratos Has Satisfied Its Obligations Under DISCO 17 For National Security, Law Enforcement and Public Safety Concerns MSV suggests that the Stratos BGAN Application should be subject to further "serutiny" becauseit fails to include a copy ofis revised agreement with the Executive Branch *‘ See MSV Petition at 11. * In the Matter ofMitigation of Orbital Debris, 19 ECC Red. 11567, 11586 (2004). * MSV Petition for Clarification or Partial Reconsideration, filed in File No. SAT—LOA— 19980702—00066 et al. (June 22, 2005). This is not an unsettled point of law as MSV argues. As the MSV Petition for Clarification or Partial Reconsideration makes clear, MSV‘s own request for a waiver of Section 25.210() for its replacement satelite at 101° W.L. (and its new satellite at 63.5° W.L) was filed because when those applications were fled there was a proposal to apply 25.210() to MSS. See id. at 2. However, as the 2004 Orbital Debris Mitigation Order makes clear, this proposal to modify 25.210() was never adopted by the Commission. * 1f Section 25.210G) were applicable to MSS, which it is not,the Inmarsat 4F2 satellite would be in a better position than MSV to receive such a waiver. Unlike the orbital positions where MSV is authorized to operate, the 52.75° W.L. orbital location for the Inmarsat 4F2 is not nearly as congested, thereby mitigating the need for strictstation keeping rule with a longitudinal tolerance of +/—0.05%. See MSP63.5° W.L. Order at § 12; MSV 101° W.L. Order at «92021 siBe

that addresses national security and law enforcement concems."". Stratos, however, has already satisfied the Executive Branch‘s national security and law enforeement concerns. As set forth in the Stratos BGAN Application, Stratos‘s current National Security Agreement with the Department of Justice and the FBI already covers the proposed BGAN services. This Agreement is already a matter of public record —— included as Appendix B o the 2001 Inmarsat Market Access Order."" Ithas not been modified because it is applicable to BGAN, Earlierthis year, Stratos, the FBI,the Department ofJustice, and the Department of Homeland Security amended the confidential Implementation Plan for this National Security Agreement in order to facilitate the Iawful interceptofthe proposed BGAN services."" In 2001 (at the time of the Zmarsar Market Access Order) the Implementation Plan was not made part of the public record at the request ofthe Executive Branch for obvious security reasons. Similarly, the modified Implementation Plan has not been made part ofthe public record in this proceeding at the request ofthe Executive Branch, If there were legitimate securityconcemns, then the Commission would hear from the Executive Branch rather than a private entity secking delay for competitive advantage. Accordingly, MSV‘s concerns and request for greater "serutiny" on this point should be refected by the Bureau. The Commission should also reject MSV‘s suggestion that there is a public safety issue with the Stratos BGAN Application because the European location of the gateway earth stations will hinder compliance with E911 for MSS."" As MSV is well aware, E911 is not applicable to MSS —— in fact,a formal proposalto make it applicable to MSS has not even been * See MSV Potition at 12. * See Inmarsat Market Access Order at Appendix E. *‘ Stratos BGAN Application at Attachment 3, p.7 °* See MSV Petition at 13. «1#+

made.®" If there is a proceeding to apply E91 1 to MSS and such a rule is adopted, Stratos and Inmarsat will make the necessary modifications to their network to ensure compliance. In the absence of E911 rules for MSS, however, there is no basis to deny or delay approval ofthe Stratos BGAN Application. IHI. CONCLUSION For the reasons stated above, Stratos respectfullyrequests that the Bureau dismiss or deny the MSV Petition and prompily grant the Stratos BGAN Application as set forth therein. Respectfullysubmitted, Sw Alfred M. Mamlet Philip L. Malet Mare A. Paul Steptoe & Johnson LuP 1330 Connecticut Avenue, NW Washington, D.C. 20036 (202) 4293000 Counselfor Stratos Communications, Inc. November 10, 2005 * See Revision ofthe Commission‘s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems, Second Report and Order, FCC 04—201 (2004) at 7 (establishing an MSS call—center requirement but referring other E911 issues for further study to the Network Reliability and Interoperability Council) age

CERTIFICATE OF SERVICE 1, Mare A. Paul, an attorney with the law firm of Steptoe & Johnson LLP, hereby certify that on this 10th day ofNovember, 2005, served a true copy of the foregoing "Opposition," by first class mail, postage pre—paid (or as otherwise indicated) upon the following: James Ball® Andrea Kelly* International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Cassandra Thomes* Scott Kotler® Interational Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Howard Griboft® Karl Kensinger® Interational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12"Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Fem Jarmulnek® Jennifer A. Manner Interational Bureau Vice President, Regulatory Affairs Federal Communications Commission Mobile Satellite Ventures Subsidiary LLC 445 12"Street, S.W. 1002 Park Ridge Boulevard Washington, DC 20554 Reston, Virginia 20191 Robert Nelson® Bruce D. Jacobs Interational Bureau David S. Konczal Federal Communications Commission Pillsbury Winthrop Shaw Pittman LLP 445 12" Street, S.W. 2300 N Street, N.W. Washington, DC 20554 Washington, DC 20037—1128 JoAnn Ekblad* International Bureau Federal Communications Commission 445 12" Street, S.W. ()@o_ Washington, DC 20554 Mare A. Paul * by Hand Delivery


Document Created: 2005-11-22 14:28:21
Document Modified: 2005-11-22 14:28:21
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