Media Networks Motio

MOTION submitted by Media Networks Services USA Inc.

Motion for Extension of Time

2013-04-30

This document pretains to SES-LIC-20130219-00188 for License on a Satellite Earth Station filing.

IBFS_SESLIC2013021900188_994995

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) MEDIA NETWORKS SERVICES USA INC. ) File No. SES-LIC-20130219-00188 ) Application for Earth Station License ) Applicant Media Networks Services USA Inc.’s Motion for Extension of Time Pursuant to Commission Rule 1.46(c), Media Networks Services USA Inc. (“MN USA”) hereby submits this motion for an extension of time to submit its response to the petitions filed, as described below, with regard to MN USA’s above-captioned application (the “Application”). As background and in support of this motion, MN USA states as follows: 1. MN USA filed its Application on February 19, 2013, seeking a license for a transmit/receive satellite earth station that would communicate with U.S.-licensed satellites that are on the Ka-band Permitted Space Station List. On March 20, 2013, the Commission accepted the Application for filing and it was placed on Public Notice. 2. On April 19, 2013, O3b Limited (“O3b”) filed its “Petition to Hold in Abeyance Pending Clarification,” stating, in sum, (i) its request that the Application be held in abeyance pending additional submission by MN USA as to the portion of the Application relating to the 18.8-19.3 GHz, 28.1-28.35 GHz and 28.6-29.25 GHz bands; and (ii) that O3b did not object to the portions of the Application related to the 18.3-18.8 GHz, 19.7-20.2 GHz, 28.35-28.6 GHz and 29.25-30.0 GHz bands. 1

3. On April 19, 2013, Iridium Satellite LLC (“Iridium”) filed its “Petition to Dismiss” the Application, which objected to the proposed use of the 19.4-19.6 GHz, 29.1-29.25 GHz, and 29.25-29.3 GHz bands. Iridium did not object to any other aspect of the Application. 4. The filing date for MN USA’s response to the O3b and Iridium petitions is May 2, 2013.1 In response, MN USA intends to amend its Application in a manner that will fully address and render moot the objections identified in the petitions, as well as file a response per Commission Rule 1.45(b) identifying how the objections have been addressed. 5. However, MN USA is not in a position to complete its intended amendment and responsive filing at this time. First, MN USA is in the process of collecting information necessary to amend the Application and needs additional time to collect such information due to the unanticipated unavailability of MN USA decision-making personnel, from whom coordination is needed to ensure its amendment and response are consistent with the business considerations underlying the purpose of the Application. Second, MN USA’s lead FCC counsel is currently traveling out of the country and is not able to complete and submit MN USA’s proposed filings absent an extension of time. 6. Accordingly, MN USA requests that it be granted an extension of time to respond to the petitions and that the filing be extended to May 17, 2013. 7. Pursuant to Rule 1.46(c), counsel for MN USA contacted the representative listed on O3b Limited’s petition (Ms. Joslyn Read) and informed her that MN USA would be filing this motion. Ms. Read, on behalf of O3b, stated that O3b does not object to MN USA’s request 1 Because Iridium and O3b served their petition via U.S. Mail (see respective certificates of service), the filing deadline for MN USA’s response is extended by 3 days to May 2, 2013. See 47 C.F.R. § 1.4(h) (“If a document is . . . in fact served by mail and the filing period for a response is 10 days or less, and additional 3 days (excluding holidays) will be allowed to all parties in the proceeding for filing a response.”) (internal citations omitted); see also id. at § 1.45(b) (oppositions to petitions may be filed within 10 days following the filing of the petition). 2

that the filing deadline for MN USA’s response be extended to May 17, 2013. MN USA has also contacted the representative listed on Iridium Satellite LLC’s petition (Ms. Donna Bethea Murphy) and informed her that MN USA would be filing this motion.2 8. Pursuant to Rule 1.46(c), counsel for MN USA has also notified the Commission staff personnel responsible for acting on this motion, Mr. Stephen Duall and Mr. Paul Blais, that MN USA would be filing the motion. For the foregoing reasons, MN USA requests that its motion for extension of time be granted and that the deadline for responding to the petitions be extended to May 17, 2013. Dated: April 30, 2013 Respectfully submitted, Media Networks Services USA Inc. By: /s/ Matthew W. Lewis Counsel for Media Networks Services USA Inc. Winston & Strawn LLP 1700 K ST NW Washington, D.C. 20006 (202) 282-5633 2 As required by Rule 1.46(c), counsel for MN USA provided oral notice to Iridium’s representative that this motion would be filed by leaving a voicemail on the representative’s direct phone number. Counsel for MN USA was not able to speak with Iridium’s representative directly and therefore cannot comment as to Iridium’s position on MN USA’s request to extend the filing deadline to May 17, 2013. 3 DC:729797.2

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Media Networks Services USA Inc.’s Motion for Extension of Time was sent by first class mail, postage prepaid, this 30th day of April 2013, to each of the following: Iridium Satellite LLC Donna Bethea Murphy Vice President, Regulatory Engineering Iridium Satellite LLC 1750 Tysons Boulevard Suite 1400 McLean, VA 22102 (703) 287-7400 O3b Limited Joslyn Read Vice President, Regulatory Affairs for O3b Limited 1129 20th St. NW #1000 Washington, DC 20036 (202) 478-7183 Joseph A. Godles Goldberg, Godles, Wiener & Wright 1229 Nineteenth Street, NW Washington, DC 20036 (202) 429-4900 /s/ Matthew W. Lewis 4


Document Created: 2013-04-30 16:58:19
Document Modified: 2013-04-30 16:58:19
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