Attachment Ex Parte

Ex Parte

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by iPass

Ex Parte Presentation

2007-11-06

This document pretains to SES-LIC-20070712-00933 for License on a Satellite Earth Station filing.

IBFS_SESLIC2007071200933_604447

W I L K I N S O NB)A R K E R )K N A U E RL L P                                                 2 3 0 0 N STREET. NW

                                                                                               SUITE   700
                                                                                               WASHINGTON,    DC 20037
                                                                                               TEL     202.783.4141

                                                                                               FAX     202.783.5851
                                                                                               www.wbk1aw.com


     November 6,2007

     Marlene H. Dortch
     Secretary
     Federal Communications Commission
     445 Twelfth Street, SW
     Washington, DC 20554

              Attn: Roderick Porter, Deputy Chief
                    International Bureau

              Re:      Notice of Oral Ex Parte Presentation
                       iPass, Inc.
                       Call Sign E070 144
                       File Nos. SES-STA-20070716-00944 and SES-LIC-20070712-00933

     Dear Ms. Dortch:

             Pursuant to Section 1.1206(b) of the Commission’s rules, 47 C.F.R. 9 1.1206(b), iPass,
     Inc. (“ipass”), by counsel, hereby notifies the Commission of an ex parte presentation with
     representatives of iPass and International Bureau staff.’ In attendance from the International
     Bureau were: Roderick Porter, Deputy Bureau Chief; Bob Nelson, Chief, Satellite Division;
     Karl Kensinger, Associate Division Chief, Satellite Division; and Scott Kotler, Chief, Systems
     Analysis Branch, Satellite Division. In attendance for iPass were: David Hawkins, Director of
     Business Development, iPass; and Kathryn A. Zachem and the undersigned of Wilkinson Barker
     Knauer, LLP, counsel for iPass.

              In its STA request, iPass discussed the public safety, law enforcement and homeland
      security benefits underlying its pending request for Special Temporary Authority to operate up to
      4000 Mobile Earth Terminals to provide Inmarsat’s Broadband Global Area Network (BGAN)
      services. iPass currently provides its enterprise customers, including existing government users,
      with a comprehensive global broadband connectivity solution employing broadband and wireless
      technology, bundled with a suite of automated device life-cycle management and security
      validation software and services. Mr. Hawkins explained that current iPass customers include a


       These applications have been designated as “permit-but-disclose” proceedings. See Public Notice, Report. No.
      SES-00973 (IB rel. Oct. 17,2007). While the expurte presentation focused on the merits of the pending STA
      request, insofar as the presentation may be relevant to the Bureau’s consideration of the underlying application
      copies have been filed separately there as well.


number of governmental agencies witl important law enforcement or public safety missions.
These government users already employ iPass’s service, and many have already indicated their
desire for access to iPass’s solution via Inmarsat’s mobile satellite BGAN technology platform -
a fact that underscores the important and immediate public interest benefits that will be achieved
by a prompt grant of the requested STA.

         Mr. Hawkins also explained that upon grant of the STAYiPass will be positioned to
initiate its BGAN offering within a short period of time. iPass anticipates that it would be able to
initiate BGAN service within 45 business days after grant of the STA to its existing customers.
iPass already maintains contractual and service provider arrangements with Federal government
agencies, and BGAN service can be incorporated into these existing arrangements seamlessly
within a short period of time. iPass has also already resolved a number of critical time-
consuming technical measures in close coordination with Inmarsat over the past several months,
such as software development and establishment of mobile terminal registration and
authenticationprotocols. For security and fiscal reasons, government agencies using iPass’s
platform prefer that the offering be available via a comprehensive “one-stop” solution, rather
than through intermediary service providers, and grant of the STA request will enable iPass to
provide BGAN service in this optimal manner.

      Mr. Hawkins also discussed a number of iPass’s existing relationships with Federal
government users. An overview of these and other iPass relationships follows:

            Dept. of Homeland Security (FEMA). The Federal Emergency Management Agency
            (“FEMA”) of the US Department of Homeland Security is an iPass customer and
            relies on its iPass service to meet communications needs in addressing public safety
            requirements during national emergencies.
        0   Dept. of Treasury (ATF). The Bureau of Alcohol Tobacco and Firearms is a
            customer who relies on s a s s service in the execution of its law enforcement and
            related regulatory activities, The iPass service has been lauded as a key productivity
            tool in increasing Agent productivity by 20%. Agents have used these tools
            throughout the US and internationally, and even to ensure public safety during the
            2006 Major League Baseball All Star game.
        0   Department of Defense. The United States Air Force and United States Army are
            both iPass customers.
        0   State and Local Governments. The local police departments of Prince William
            County, Virginia and St. Paul, Minnesota, are both iPass customers.

Other Federal government law enforcement agencies are using iPass service as part of pilot
projects involving an iPass reseller.


        In conclusion, iPass is already an established provider of secure broadband connectivity
services to government agencies, including agencies with a public safety and homeland security
mission, and is capable of initiating competitive BGAN service in a short time frame after
obtaining STA approval. For the reasons discussed herein and in iPass’s pending STA request,
the public safety benefits of granting iPass’s STA are real and expeditious grant of the request is
clearly in the public interest.

       An original and five copies are being submitted.

                                                  Respectfully submitted,

                                                  WILKINSON
                                                          BARKER
                                                               KNAUER,
                                                                     LLP




                                           By:
                                                  Robkrt G. Morse
cc:    Roderick Porter
       Bob Nelson
       Karl Kensinger
       Scott Kotler
       Gardner Foster



Document Created: 2007-11-07 11:21:34
Document Modified: 2007-11-07 11:21:34

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC