Attachment Reply

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

IBFS_SESLFS2005093001352_583209

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: 2007-08-01 12:52:02
Document Modified: 2007-08-01 12:52:02
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