Panasonic Notice and

LETTER submitted by Panasonic Avionics Corporation

Notice and Clarification

2010-10-18

This document pretains to SES-LIC-20100805-00992 for License on a Satellite Earth Station filing.

IBFS_SESLIC2010080500992_845871

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) Application of Panasonic Avionics ) File Nos. SES-LIC-20100805-00992 Corporation for Authority to Operate Up to ) SES-AMD-20100914-01163 15 Technically Identical Aeronautical ) SES-AMD-20101115-01432 Mobile-Satellite Service (“AMSS”) Aircraft ) Earth Stations (“AESs”) in the 14.0-14.4 ) Call Sign E100089 GHz and 11.7-12.2 GHz Frequency Bands ) REPLY TO “CONSOLIDATED REPLY” OF ROW 44, INC. Anita Kartic Carlos M. Nalda Senior Director, Regulatory Affairs Joshua T. Guyan and Strategic Partnerships Squire Sanders & Dempsey L.L.P. Panasonic Avionics Corporation 1201 Pennsylvania Avenue, NW 26200 Enterprise Way Suite 500 Lake Forest, CA 92630 Washington, DC 20004 (202) 626-6659 Counsel for Panasonic Avionics Corporation December 13, 2010

SUMMARY Panasonic Avionics Corporation (“Panasonic”) hereby submits its reply to the late-filed pleading of Row 44, Inc. regarding Panasonic’s application for blanket license authority to operate a limited number of aircraft earth stations (“AESs”) as part of the “eXConnect” Ku-band aeronautical mobile-satellite service (“AMSS”) system. It the pleading, Row 44 continues its spurious attacks on Panasonic’s straightforward AMSS application. From a technical standpoint, Panasonic proposes to combine a small number of previously licensed MELCO antennas with well-known modem technology operating at a lower maximum power spectral density to provide aeronautical connectivity to the same aircraft that operated in the United States under prior Commission authority. From a procedural standpoint, Panasonic’s application was filed under Section 25.220 with the required supporting technical documentation and its operations have been fully coordinated with potentially affected satellite operators, so the Commission need not address Row 44’s unsupported criticisms. Panasonic voluntarily provided supplemental technical data regarding MELCO antenna operations similar to that required for earth stations onboard vessels (“ESV”) and vehicle- mounted earth stations (“VMESs”) to further demonstrate compliance with the Commission’s two-degree spacing policies. However, Row 44 inappropriately seeks to bootstrap this additional technical information to require full compliance with the Commission’s ESV and VMES rules, even though its own AMSS application was considered under Section 25.220. Although the Commission need not substantively consider Row 44’s latest filing, Panasonic addresses the arguments set forth in that submission. Specifically, Panasonic (i) correctly and appropriately incorporated by reference technical information from the prior MELCO AMSS licensing proceeding; (ii) addressed the differences between the Connexion by


Document Created: 2010-10-18 16:05:42
Document Modified: 2010-10-18 16:05:42
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