Attachment Opposition

This document pretains to SES-LFS-20050930-01352 for License to use Foreign Satellite (earth) on a Satellite Earth Station filing.

IBFS_SESLFS2005093001352_538150

RECEIVED s« . «.ORIGINAL MSV NOV 2 7 2006 ferii Mobile Satellte Ventures i> Sateite Diston IntornationalBureau November 22, 2006 Via Hand Delivery FILED/ACCEPTED Ms. Marlene H. Dortch Srroms Nov 22 2006 Federal Communications Commission FodenlConmnestrs Commsoen 445 12th Strees, S.W. sufiey Washington, D.C. 20554 Re: Pending Applications to Operate with an Uncoordinated Inmarsat Satellite File Numbers Attached as Exhibit A Dear Ms. Dortch: To date,the Intemational Bureau ("Bureau") has granted Special Temporary Authority ("STA") for the operation of30,000 Broadband Global Area Network ("BGAN®) terminals in the United States." Mobile Satellite Ventures Subsidiary LLC (MSV") has opposed the grant of applications to operate BGAN terminals due to the potential that their use on uncoordinated Inmarsatsatelltes will cause harmful interference to MSV‘s licensed operations." Recently, it has come to light hat Inmarsat has onl5,547 BGAN subscribers worldwide, the vast majority of which presumably operate outside the United States," This new information helps to demonstrate that: () any absence of interference from BGAN operations to date demonstrates nothing regarding the potentialinterference that will resultif more and more BGAN terminals are operated in the future; and (i) Inmarsatand its distributors have greatly exaggerated the demand for the BGAN service. Since grant of the BGAN $TAs, Inmarsat and itsdistributors have contended that BGAN service has been provided in the United States without interference.". Inmarsat and its distributors, however, have never revealed how many of the 30,000 BGAN terminals authorized ! See, eg., Stratos Communications, Ic., Request for Special Temporary Authority, File No. SES—STA—20060310—00419 (filed March 10, 2006; granted with conditions on May 12, 2006) * See, eg., Mobile Satellite Ventures Subsidiary LLC, Petition to Hold in Abeyance, File No. SES—LRS—20060303—00343, File No. SES—AMD—200603 16—00448 (Call Sign EO60076) (April 14, 2006). * See Exhibit B, ataching excerpts from Inmarsat Group Limited‘s Form 6—K filed with the SEC on November 15, 2006, available at hitps/fwwwsee.gouArchives/edgar/data/1291398/0001 19312506235898/0001 193 125—06.— 235898—index hm * See Inmarsat Ventures Limited, Reply, File No. SES—STA—20061019—01868 (Call Sign £O60179) (November 8, 2006), at 1, 2.

Ms. Marlene H. Dortch November 22, 2006 Page2 bythe Bureau are actually in operation today. In fact, although Inmarsat‘s BGAN service was Iaunched almost a year ago in December 2005," Inmarsat in a November 15, 2006 filing submitted with the U.S. Securities and Exchange Commission ("SEC") reveals that there are only 5,547 BGAN subscribers worldwide today." These terminals are used in 172 countries, with Inmarsat‘s Chinese distribution partner accounting for 12% of BGAN sales, mostly to Chinese media,oil, and gas companies," While MSV is not aware of any publicly available figures on the number of BGAN terminals deployed in the United States (and Inmarsat has failed to provide any such figure in the record), it is safe to assume that only a fraction ofthe 5500 BGAN terminals activated worldwide today are used in the United States. Thus, despite Inmarsat‘s claims, the operation of a handful (if any) BGAN terminals to date demonstrates nothing regarding the potential for interference if more and more BGAN terminals are operated in the future. In fact, if these BGAN terminals have been provided tofrst responders, it is most likely that the terminals are being used only during an emergeney. During these emergencies, interference is likely to those first responders that use MSV‘s service that are responding to the same emergency. To alleviate this isk ofiterference, MSV has urged the Bureau to establish a firm expiration date for the BGAN STAs and provide that nofurther extensions will be granted without Inmarsat having first completed coordination ofits new satellte with other North American L band operators.® If, however, the Bureau continues to renew the BGAN STAs without insisting that Inmarsatfirst complete coordination, there are no reasonable prospectsthat such coordination will ever be successfully completed. This is especiallythe case now that Inmarsat has revealed that only roughly 5500 BGAN terminals have been activated worldwide in the past year.. At this rate, it will be many years before Inmarsat and itsdistributors approach the limit of 30,000 BGAN terminals authorized in the United States pursuant to STA.. Only a firm expiration date for the BGAN STAs will provide Inmarsat with the needed incentive to satisfy its obligation to coordinate ts satelite with other North American L band operators. Not only will successful coordination mitigate the harmfulinterference that would otherwise resultfrom operation of Inmarsat‘s uncoordinated satellte, this coordination should also facilitate rebanding of L band spectrum into more contiguous frequency blocks that will increase efficient use of L band spectrum and maximize the potential for offering broadband services, which Chairman Martin recently explained is the Commission‘s top priorty." * See Inmarsat Announces Launch of BGAN Service (December 7, 2005), available at: hitp:/fabout.inmarsat.com/news/00018831.aspx?language=EN&textonly=False © See supra note 3. " See Communications Daily (November 16, 2006), at 12 (quoting Inmarsat‘s ChiefOperating Officer). * See Mobile Satellite Ventures Subsidiary LLC, Comments, File No. SES—STA—20061019— 01868 (Call Sign EO6O179) (October 24, 2006), at 4—5. * See Remarks of FCC Chairman Kevin J. Martin, Imagining the Digital Healthcare Future in the Rural West, Montana State University — Bozeman (July 7, 2006).

Ms. Marlene H. Dortch November 22, 2006 Page 3 in the event that the Bureau permits the BGAN STAs to continue without establishing a firm expiration date,the Burea should at least require the STA holders to disclose the number of BGAN terminals that are actuallyin operation using the Inmarsat—4 satellte that is serving the United States. L band operators can use this information to assess the potential aggregate interference to their operations. Moreover, until coordination is completed, the Bureau limit the BGAN terminals authorized under these STAs to those terminals that are issuedshould to "first responders,""" based on swom affidavits provided by the STA holders supporting their claims. Please contact the undersigned with any questions. Very truly yours, &&;:{. Manner ‘* The Bureau should define a "first responder®as a unit of the Federal Government or any entity that would qualify to hold a license under Section 90.523 of the Commission‘s rules. See 47 C.F.R. §90.523 (providing that State or local govemnment entities and certain nongovernmental organizations that provide services, the sole or principal purpose of which is to protect the safety oflife, health, or property, as well as satsfy other critera, may qualify to hold certain licenses).

Exhibit A Pending Applications to Provide BGAN Services with Inmarsat 4F2 Applicant File Number Stratos Communications Inc. SES—LES—20050826—01175 (Call Sign EOS0249) SES—AMD—20050922—01313 (Call Sign EO50249) SES—AMD—20051117—01590 (Call Sign E050249) Telenor Satellite, Inc. SES—LES—20050930—01352 (Call Sign EO50276) SES—AMD—20051 1 11—01564 (Call Sign EO80276) SES—AMD—20060109—00019 (Call Sign EO50276) SES—AMD—20060607—00942 (Call Sign EOS0276) FIMSC US, LLC SES—LFS—20051011—01396 (Call Sign EO50284) SES—AMD—20051118—01602 (Call Sign EO50284) SES—AMD—20060605—00926 (Call Sign EOS0284) MVS USA, Inc. SES—LES—20051 123—01634 (Call Sign EO50348) SES—AMD—20060329—00540 (Call Sign EOS0348) BT Americas Inc. SES—LES—20060303—00343 (Call Sign EO60076) SES—AMD—20060316—00448(Call Sign EO60076) Thrane and Thrane SES—LFS—20060522—00852(Call Sign B060179) Applications for STA to Provide BGAN Services with Inmarsat 4E2 Applicant File Number Stratos Communications Inc. SES—STA—20061103—01946 (Call Sign EO50249) Telenor Satellite, Inc. SES—$TA—20061027—01898 (Cll Sign EOS0276) FIMSC US, LLC SES—$TA—20061006—01820 (Call Sign E050284) MVS USA, Inc. SES—STA—20061106—01955 (Call Sign EOS0348) BT Americas Inc. SES—STA—20061 101—01933 (Call Sign E060076) Thrane and Thrane SES—STA—20061019—01868 (Call Sign E060179)


Tomék 6—K. 1 dkchtm FORM 6—K. Table of Gontents SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 6—K REPORT OF FOREIGN PRIVATE ISSUER Pursuant to Rule 13a—16 or 15d—16 of the Securities Exchange Act of 1934 September 30, 2006 sas—1se65—05 Inmarsat Group Limited (Exact name ofReistrant as specifid in its charter) Inmarsat Group Limited (Transtation of Repistrant‘sname nto Englist) England and Wales (Juristition ofincorporation ororganization) 99 City Road, London United Kingdom, ECIY 1AX (Adressof principal executhve offce) ass—11s865—06 Inmarsat Finance ple (Exact name of Registrant a specifed in its charter Add hysegovicivatpnten91396001 o tasogzsstanh( oz ons tels

roomex Inmarsat Finance ple (ZranstationofRegistrant‘s name into Englt England and Wales (Jurstletion of incorporation or organization) 99 City Road, London United Kingdom, ECIY 1AX (Address o principa xecutive offce) ass—115ses Indicate by check mark whether the Registrant fils or willfile annual reports under cover Form 20—or Form 40— a 20r «0r o Indicate by check mark whether the Registrantis submiting the Form 6—K in paper as permitted by Regulation S— T Rule 101() (1):— Indicate by check mark whether the Registrant is submiting the Form 6—K in paper as permitted by Regulation S— T Rute 101() (7)— Indicate by check mark whether by furnishing the information contained in this Form, the registrant is also thercby furnishing the information to the Commission pursuant to Rule 12€3—2(b) under the Securites Exchange Act of 1934. Yes 0 No C 1 "Yes"is marked, indicate below the file number assigned to the registrant in connection with Rule 1283—2(b): 82 Hup hnas qochivseteatantasi6oon on rasonsssoi en( orm atont i: it Ald

tomex Table of Contents INMARSAT GROUP LIMITED conpENsED CoNsoLmaATED FINANCIAL REsULTS For the three and nine months ended September 30, 2006 (unaudited) s tt Alt HupaoAsiveetpe asisogornionrasorsserbit or) avac

fomék Table of Contents Asat September 30 200 z008 Active terminals(@) oo ie Maritime 1373 1206 Land . 821. 7ea Aeronsutical 7 6 Total active terminals 268 2084 (1) Activeterminals are the numberof subscribers (BGAN and R—BGAN) or terminals that have been used to access services at any time during the preceding twelve—month period (other services except hand—held) registered at September 30. Active hand—held terminals are the average number of terminals active on daily basis during the period. (2) Activeterminals as at September 30, 2006 include 10,368 ACeS terminals and 5,547 BGAN subscribers (as| ® at Septembe r 30, 2005; nil and nil respectively).The average daily active number of hand—held STM cards . was 14,274, During the three months ended September 30, 2006,revenues from mobile satellte communication services were US$127.3 million, an increase of US$11.5 million, or 10%, compared with the three months ended September 30, 205. Growth has been strong in all sectors as a result of continued success in the newer services such as Fleet and Swift 64 and following the launch of BGAN in December 2005, The maritime, land, aeronautical and leasing sectors aceounted for 57%, 24%, 6% and 13% of total revenues from mobile satelite communication services respectively during the three months ended September 30, 2006. Active terminal numbers have increased by 12% between September 30, 2005 and September 30, 2006 through growth in the maritime and seronauticalsectorsplus the addition of ACeS handheld terminals in September 2006. Meritime Sector. During the three months ended September 30, 2006, revenues from the mariime sector were US $72.6 million, an increase ofUSSS.5 million, or 8%, compared with the three months ended September 30, 2005. "This principallyreflects an increase in data revenves. Revenues from data services in the maritime sector during the three months ended September 30, 2006 were US $47.1 million, an increase of US4.6 million, or11%, compared with the three months ended September 30, 2005. The increase in revenues from data services reflects greater demand, a a result of the continued take—up and strong usage of our Flect services, Demand for Fleet terminals has also been driven by growth in the global shipping fleet new—build market. Revenues from volce services in the maritime sector during the three months ended September 30, 2006 were US $25.5 million, an increase of USS0.9 million or 4% compared with ththree months ended September 30, 2005. Historically our voice revenues for the maritime sector have been affeeted by the migration of users from our higher—priced analogue service to our lower—priced digialservices and to a lesser extent by competition. This has been more than offset by growth in both our newer Flectservice and various promotions we have initiated to respond to increased competition in certain of our established services. hapsfinsas qoAnhiveedte o oshoo n esorssenta m lt ram)at zse s And

tomex Table of Contents Revenues from BGAN services during the nine months ended September 30, 2006 are set out in the table below. These figures include voice, data and subscription revenues. As atSeptember 30, 2006 there were 5,547 active BGAN subscribers. Three months ended ine monthsended June30, September3l, 2m6 ams 206 ams BGAN Services Revenues (US$ in millions) 0.5 16 32 53 Active subscribers 2113 3367 5547 5547 Aeronautical Sector. During the three months ended September 30, 2006, revenis from the acronautical sector were USS8.0 million, an increase ofUSS2.3 million, or 40%, compared with the three months ended September 30, 205. The increase continues to be attibuted primarily t the Swift 64 high—speed data service, which targets the government aireraft and business jet markets as well as being used by commercialarlines. In addition revenues for low—speed data services benefited from increased industry demand. Leasing. During the three months ended September 30, 2006, reventes from leasing were US$16.3 million, an increase of US$2.2 million, or 16%, compared with the three months ended September 30, 2005 as a result ofa new acronautical Swift 64 lease, Subsidiary revenes. Following the disposal ofInvsat Limited and the business and assets of Rydex Corporation Limited in September 2005 and October 2005 respectively, subsidiary revenues were USSnil for the three months ended September 30, 2006, compored to USS3.0 million in ththree months ended September 30, 2005. Other income. Other income was USS1.9 million for he three months ended September 30, 2006, an increase of US$0.7 million, or 58%, compared with the three months ended September 30, 2005 as a result of the provision ofadditional in—orbit support services. Other income consists primarily oincome from the provision of conference faciltes, renting surplus office space, fees for in—orbit support services and revenue from sales of R« BGAN end useterminals Seasonalip. Revenues are impacted by volume discounts thatincrease over the course ofthe financial year. ‘There are lower discount levels in early quarters representing the minimum annual discount and higher discount Hevels in later quarters, as distribution partners meet specific volume thresholds, resulting in lower prices beyond the level of the minimum annual discount. Additionally, in 2006 and future years, th total amount of volume discounts willbeaffected by the merger of Xantic B.V. with Stratos Global Corporation which serves to increase the amount ofrevenues attribted to a single distrbution partner. a hapi ho aepuAshiveetiatun 913960 io soenstonit( or mhatons ies ant

CERTIFICATE OF SERVICE 1, Julia Colish, a secretary with the law firm ofPilsbury Winthrop Shaw Pittman LLP, hereby certfy that on this 22nd day of November 2006, served a true copy ofthe foregoing by first—class United States mail, postage prepaid, upon the following: Henrik Norrelyike Alfted M. Mamlet Thrane & Thrane Airtime Ltd. Steptoc & Johnson LLP 509 Viking Drive 1330 Connectiout Avenve N.W. Suites K, L & M Washington, D.C. 20036 Virginia Beach, VA 23452 Counselfor Stratos Communications, Inc. Keith H. Fagan Diane J. Comeil Telenor Satelite,Inc. Vice President, Govermment Affairs 1101 Wooton Paroway Inmarsat, Inc. 10° Floor 1100 Wilson Blvd, Suite 1425 Rockville, MD 20852 Arlington, VA 22209 John P.Janka Linda J. Cicco Jeffey A Marks BT Americas In Latham & Watkins LLP 11440 Commerce Park Drive 555 Eleventh Street, NW. Reston, VA 20191 Sute 1000 Washington, DC 20004 Wiliam K. Coulter Lawrence J. Movshin DLA Piper Rudnick Gray Cary US LLP Stephen L. Goodman 1200 Nineteenth Street, NW. Lee J. Rosen Washington, DC 20036—2412 Wilkinson Barker Knaver, LLP 2300 N St. NW, Suie 700 Counselfor FTMSC US, LLC Washington, DC 20037 Counsel for MVS USA, Inc. Eric Fishman Holland & Knight LLP 2099 Pennsylvania Avene, NW Sute 100 Washington, DC 20006 Counse for Thrane & Thrane Airtime Lid. Tulia Colish *By electronic mail


Document Created: 2006-12-07 15:43:59
Document Modified: 2006-12-07 15:43:59
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