Attachment Ex Parte

Ex Parte

LETTER submitted by Richard A. Zyvoloski

letter

2006-05-26

This document pretains to SES-LFS-20051123-01634 for License to use Foreign Satellite (earth) on a Satellite Earth Station filing.

IBFS_SESLFS2005112301634_528079

                                     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.



Document Created: 2006-09-01 15:04:27
Document Modified: 2006-09-01 15:04:27

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