Attachment Opposition

Opposition

OPPOSITION submitted by SkyWave Mobile Communications, Corp.

Opposition

2006-02-02

This document pretains to SES-MFS-20051207-01709 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2005120701709_482117

RECEIVED RECEIVED Before the Fep —2 2006 FEDERAL COMMUNICATIONS COMMISSIO];I“‘W‘ conmuntcattescommision FEe 0 8 2008 Washington, D.C. 20554 To iess Satelte Diision IntermatonaiBcreau In the Matter of SkyWave Mobile Communications, Corp File No. SES—MEFS—20051207—01709 Application for Modification of Blanket License (Call Sign E030058) to Operate Mobile Earth Terminals with Inmarsat 4B2 ar 52.75° W.L To: International Bureau OPPOSITION TO MSV PETITION TO HOLD IN ABEYANCE SkyWave Mobile Communications, Corp. Alfred M. Mamiet Mare A. Paul Brendan Kasper Srertos & Jornson Lur 1330 Conectiout Avente NW Washington, D.C. 20036—1795 (202) 4203000 Counselfor SkyWave Mobile Communications, Cor: February 2, 2006

TABLE OF CONTENTS L INTRODUCTION AND SUMMARY L. MSV HAS NOT PROVIDED A LEGITIMATE BASIS FOR DELAYING GRANT OF THE SKYWAVE APPLICATION A.—— Grant of the SkyWave Application is the Public Interest. B. Grant of the SkyWave Application Should Not Be Delayed Pending Completion of a New L—band Coordination Agreement 6. SkyWave Should Not Be Prevented From Using Any Available Inmarsat Spectrum . D. Grant of the SkyWave Application Will Not Create Any Tech Interference Issues E. The Inmarsat 4F2 Satellite Is Properly Regarded As A Replacement Satelli ®. The Commission‘s FSS Station Keeping Rule Does Not Apply to MSS Satel 1. CONCLUSION

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of SkyWave Mobile Communications, Corp. File No. SES—MEFS—2005 120701709 Application for Modification of Blanket License (Call Sign BO30088) to Operate Mobile Earth Terminals with Inmarsat 492 at 52.75° W.L. To: International Bureau OPPOSITION TO MSV PETITION TO HOLD IN ABEYANCE Pursuant to Section 25.154(c) ofthe Commission‘s Rules, 47 C.FR. § 25.154(c), SkyWave Mobile Communications, Corp. (*SkyWave") hereby opposes Mobile Satellite Ventures Subsidiary LLC‘s (°MSV‘s") Petition to hold in abeyance the above—captioned application of SkyWave ("the SkyWave Application‘®)." 1. INTRODUCTION AND SUMMARY SkyWave has filed an application to modify its existing authorization to operate Inmarsat D+ terminals toinclude the recently launched fourth—generation Inmarsat satellite ! See MSV Petition To Hold in Abeyance (Jan. 20, 2006) (°MSV Petiion®). Concurrently with this Opposition, SkyWave is filing a Motion to Strike Portions ofthe MSV Petiion. See SkyWave Motion to Strike (filed Feb. 2, 2006). As set forth in that Motion to Strike, the MSV Petition should be dismissed bythe Bureau because it contains confidential information and redacted arguments that SkyWave has not been given access to by MSV, thereby depriving SkyWave of a full and fair opportunity to defend it applications. At a minimum, the Bureau cannot base any decision to hold in abeyance the SkyWae Application on what has been deemed confidential by MSV and withheld from SkyWave. To the extent that SkyWave is given access to the confidential information contained in the MSV Petition after this Opposition is filed, SkyWave reserves the right to amend this Opposition as necessary.

located at 52.75° W.L. ("Inmarsat 4E2") as a point of communication.®. Sky Wave is currently authorized to use a third generation Inmarsatsatellite located at 54° W.L. to offer the Inmarsat D+ service to customers. Inmarsat migrated this service, along with other existing Inmarsat services, from that third generation satelliteat 54° W.L. to the Inmarsat 4F2 at 52.75° W.L. on January 22, 2006." The Inmarsat D+ service thatis the subject of the SkyWave Application is not new. SkyWave has been authorized to provide these Inmarsat services since 2004. To date, these services have been provided to customers without interference to or complaint from MSV. The SkyWave customers rely heavilyon the existing Inmarsat services to facilitate law enforcement, homeland security and to protect, track and monitor sensitive assets throughout the United States. Any disruption to these services would be devastating to these essential activities and would not be in the public interest. The MSV Petition should be either dismissed or denied by the Bureau as a transparent attempt to use the SkyWave Application as leverage in its on—zoing spectrum dispute with Inmarsat. MSV‘s spectrum dispute should be resolved through the agreed—upon mechanism for international coordination —— £¢, the Mexico City Memorandum of Understanding ("Mexico City MOU®)—— and not this proceeding. ‘The Bureau should not allow MSV to treat SkyWave as a pawn in its dispute,especially when vital communications services are involved. The SkyWave Application satisfies the Commission‘s Rules and should be prompily granted by the Bureau. * See File No. SES—MFS—20051207—01709. * On January 18, 2006, SkyWave was granted special temporaryauthority ("STA") to use the Inmarsat 4F2 in advance of the Bureau‘s decision on its modification application to use the Inmarsat 4F2 as a point of communication. See File No. SES—STA—20051222—01788.

Contrary to the claims of MSV, a newintemational L—band coordination agreement is not needed before the SkyWave Application can be granted. Indeed, two MSV satellite applications (one for a replacement satellite at 101° W.L. and a new satellite at 63.5° W.L.were granted by the Bureau last year on a non—harmful interference basis and in the absence of a new L—band coordination agreement. There is no justification for treating the SkyWave Application and its proposed use ofthe Inmarsat 4F2 satellte differently. Despite what MSV may argue, the SkyWave Application clearly establishes that the existing Inmarsat services will be provided over the recently launched Inmarsat 4F2 satellite within the same technical envelope (e,g, no greater EIRP spectral density, no unauthorized out— of:band emissions, and no needfor greater interference protection) as these services are being provided today, and as a result, there will be no increased interference risk to MSV. MSV has not provided any technical evidence to suggest otherwise Finally, the SkyWave Application does not contain the additional issues claimed byMSV to warrant further "scrutiny" by the Bureau.* First, the proposed Inmarsat 4F2 satellite is properly considered a replacement satellte for the third generation Inmarsatsatelite ("Inmarsat 3 satellite") at 54° W.L.. because it will cover the same geographic areas as that satellte, and does not seck to use any additional L—band frequencies beyond those currently authorized. Second, despite MSV‘s suggestion otherwise, Section 25.210G) of the Commission‘s Rules, 47 C.F.R. § 25.2100), requiring FSS satelltes to operate with +/0.05° East—West station keeping, does nor apply to MSS satellites. * See MSV Petition at 19—20.

The Bureau should prompily grant the SkyWave Application and allow U.S. consumers to continue to receive the Inmarsat D+ service, which they have come to rely on over the past 2 years. 1. MSV HAS NOT PROVIDED A LEGITIMATE BASIS FOR DELAYING GRANT OF THE SKYWAVE APPLICATION Rather than pursuing its spectrum dispute with Inmarsat as part ofthe established interational coordination procedures for the L—band, MSV is attempting to use its Petition against the SkyWave Application as leverage for resolving an on—going and protracted L—band spectrum dispute with Inmarsat, Allowing MSV to do so would be inconsistent with the Commission‘s obligations under the Mexico City MoU, violate the DISCO // principles regarding the treatment of applications for access to forcign satelltes licensed byWTO Member countries, and succeedin disrupting the delivery of an existing Inmarsat service to U.S customers. The Bureau must reject the arguments in the MSV Petition. A.—=— Grant of the SkyWave Application is in the Public Interest Having been licensed for two years, the SkyWave Inmarsat D+— service is known by the Bureau and in the marketplace to offer a unique service totrack and monitor sensitive assets throughout the country. The continued and uninterrupted distribution ofthis Inmarsat service in the U.S. is in the public interest. SkyWave‘s customers for Inmarsat services encompass a wide range of U.S. customers, including the U.S. military, Federal Government, Federal lawenforcement and private sector end—users." U.S. miltary users include: Department of Defense Counter—Narcoterrorism Technology Program Office and the Naval Surface Warfare * See Declaration of Ani Tourian at 99 5—8 (Attachment B of File No. SES—STA— 20051222—01788) (incorporated herein by reference) a44

Centre.® Federal Government users include: Department of Homeland Security and the DEA U.S. private sector customers include: Teletouch, Optec and Global Secure Cargo." The Inmarsatservices are used by these entities to track the location and behavior of assets like trucks or boats or other movable assets, and to monitor the status and condition of facilities to ensure they are functioning properly." Grant ofthis STA request will ensure that these end—users do not experience any disruption to the Inmarsat services they currently use and rely on. Distuption of these services could jeopardize the success ofcritial law enforcement and homeland security applications and endanger the security and safe operation of assets held by SkyWave‘s private sector clients."" B. Grant of the SkyWave Application Should Not Be Delayed Pending Completion of a New L—band Coordination Agreement MSV suggests that the SkyWave Application should be delayed "until an L band coordination agreement is concluded.""" The absence of an L—band coordination agreement, however,is not an adequate justifiation for the Bureau to delay action on the SkyWave Application. According to MSV, the SkyWave Application should be treated differently than other similar applications since"the spectrum management issues presented now are fundamentally different* because other L—band satellites, unlike the Inmarsat 4F2, that have been licensed in the absence of a coordination agreementatleast "had been coordinated in the past for * See Declaration of Ani Tourian at 4 6. * See Declaration of Ani Tourian at47. * See Declaration of Ani Tourian at 48. * See Declaration of Ani Tourian at 49 5—8. ‘° See Declaration of Ani Tourian at 1 9. " MSV Petition at i

narrowband carriers and were in the ITU Master Registry.""" However, just last year, the Bureau granted two MSV applications to operate in the L—band —— one for a replacement satelite at 101° W.L. and one for a new satellite (e., a satellite not contemplated bythe Mexico City MoU) at 63.5° W.L." MSV ignores the fact that neither of these satelltes habeen coordinated in the past, and one of satelites uses carriers that are 25 times wider than those on the Inmarsat 4F2 satellite."" Rather than delaying action on either MSV application pending the completion of a new L—band coordination agreement, both applications were granted on a "non—harmful interference basis to other mobile—satelliteservice systems operating in the L—band.""" Indeed, since the UK (the administration licensing the Inmarsat system) and Canada (home ofthe ultimate corporate parent of SkyWave) are WTO Members, the U.S. has an obligation to do the same in this case.!" !* MSV Petition at 10. © See In the Matter ofMobile Satellie Ventures Subsidiary LLC, DA 05—50 (rel. Jan. 10, 2005) (‘MSF 63.5° W.L. Order"); In the Matter ofMobile Satellite Ventures Subsidiary LLC, DA 05—1492 (rel. May 23, 2005) (CISV 101° W.L. Order"). !* See File No. SAT—AMD—20031118—00335 at Appendix A, p.23. "* See MSV 63.5° W.L. Order at § 39; MSV 101° WL. Order a 59. "* See TMI Market Access Order, 14 FCC Red. at 20813 (rejecting the attempt of AMSC to preclude other L—band systems from serving the U.S. until AMSC had completed coordination of 20 MHz of spectrim because doing so "would be inconsistent with U.S. market access commitments in the WTO Agreement‘); Amendment ofhe Commission‘s Regulatory Policies to Allow Non—US: Licensed Sateltes Providing Domestic and International Service in the United States, 12 FCC Red. 24094, 24104(1997) ("DISCO I1") (recognizing the US commitment "to provide market access o all basic telecommunications services and nationaltreatment to service suppliers of WTO members®).

C. SkyWave Should Not Be Prevented From Using Any Available Inmarsat Spectrum MSV argues that "interference" will result from "Inmarsat‘s continued use of spectrum that it agreed to return to MSV and MSV Canada.""" Implicily, MSV seeks to exclude SkyWave from operating over this "disputed" spectrum when providing existing Inmarsat services to its customers using the Inmarsat 4F2. The Bureau must reject MSV‘s request. Indeed, as Inmarsat has pointed out, if the Bureau were to restrict operations over this disputed spectrum, it would be tantamount to the reinstatement and modification ofthe expired 1999 L~ band spectrum coordination agreement t."" However, this is not the forum to adopt a new coordination agreement and policy for the L—band. The Inmarsat D—+ METs in the SkyWave Application should be free t use all of the L—band frequencies used by Inmarsat, subject tothe outcome of any international coordination.. IfMSV has a dispute over the current distribution and coordination of L—band spectrum, it should bring this dispute with Inmarsatin accordance with the agreed—upon procedures for international coordination, not in this application proceeding."" Despite MSV‘s suggestion otherwise, the Commission has not previously limited eperators tothe spectrum last coordinated for their use under an expired coordination agreement. The 2001 /nmarsat Market Access Order is clear: "In the absence of a continuing annual L—band operator—to—operator coordination agreement, operations of METs in the 1525« ‘‘ MSV Petition at 12. "* See Opposition of Inmarsatat 9—10,filed in File Nos. SES—LFS—20050930—01352, SES— AMD—20051111—01564, and ITC—214—20051005—00395 (Dec. 7, 2005) ("Inmarsat Opposition"). ‘ Despite what MSV may imply, the Bureau acknowledges in the MSP 63.5° I.L. Order and MSV 101° W.L. Order that "informal® arrangements now govern the coordination of L—band spectrum, not the 1999 coordination agreement...See MSF 63.5° I.L. Order at 1 23; MSY 107° W.L. Order t § 34. * See MSV Petition at 13.

1559 and 1626.5—1660.5 MHz bands will be on a non—interference basis until a future operator= to—operator agreement is concluded.""" Subject t a non—harmful interference condition, the Commission has consistently held that MSV, TMI, and others could use the entire range of L— band frequenciesin the absence of a coordination agreement."" There is no reason to treat SkyWave differently now. Ifinterational coordination changes the spectrum available to Inmarsat, SkyWave will modify the operations of ts METs accordingly. Until that time, however, there is no reason to delayapproval of these applications. The Bureau should not permit MSV torestrct the use of L—band spectrum in order to faciltateits plans to offer ancillaryterrestrial component (°ATC®) services. The Commission‘s Rules specify that ATC operations in the L—band are only permitted in bands which have been coordinated for satellte use."" However,the last formal coordination agreement under the Mexico City MOU expired in 1999, Further, in permitting ATC authority for the L—band, the Commission made it clear (and MSV agreed) that a provider could not seek to coordinate spectrum for ATC, as opposed to satellite service needs."" The Bureau must not allow MSV to manipulate spectrum assignments in order t further its goals for ATC. *‘ Inmarsat Market Access Order, 16 FCC Red. at 21712—13. "" See MSV 101° W.L Order at8 34; See_MSY 63.5° W.L. Order at § 23; Inmarsat Market Access Order, 16 ECC Red. at 21712; TMI Market Access Order, 14 FCC Red. at 20814. " See C.F.R. §25.253(a)(4)(‘In a band segment in which the applicant has no rights under a coordination agreement,the applicant may not implement ATC in that band.") * See Flexibilityfor Delivery ofCommunications byMobile Sarellte Service Providers in the 2 GHe Band, the L—band, and the 1.6/2.4 GHz Bands, 18 ECC Red. 1962, 2066—67 (2003) ("[We agree with MSV‘s assertion that parties could not legitimately identify terrestrial ATC usage to justify a larger MSS satellte spectrum assignment.") 1§:

D. Grant of the SkyWave Application Will Not Create Any Technical Interference Issues The existing Inmarsat D+ service has been provided with the current Inmarsat satellte for several years without causing harmful interference, and SkyWave and Inmarsat do not expect anyincrease in interference when these services are provided using the Inmarsat 4F2."" MSV‘s claims regarding possible interference due to technical differences between the Inmarsat 4F2 satelite and previous satellites do not support holding the SkyWave Application in abeyance. Indeed, the technical differences between the Inmarsat 4F2 satellte and carlier L~ band satellites are unlikely to cause harmfulinterference in the L—band. First, MSV claims that the increased number ofregional beams employed bythe Inmarsat 4F2 satellte could cause harmfulinterference in the L—band"* However, as set forth in the Technical Appendix of the SkyWave Appliation and as explained by Inmarsat lsewhere, the Inmarsat 4F2 is more *interference friendly® than the third generation satellte because: (1) its narrower spot beams with steeper anterna side lobes reduce interference to adjacent areas; and (2) ts higher gain spot beams allow the use of terminals that radiate less than one—tenth the power of existing Inmarsat high speed data terminals."" Further, the Inmarsat 4F2 satellite will be located 1.25° further away from MSV. This increased separation will further reduce any interference risk. In the absence of the coordination agreement, the Inmarsat 4F2 is capable of operating on a non—harmful interference basis. * As the Bureau has recognized, current L—band operators have been operating "interference—free" for some time. See MSV63.5° W.L. Order at § 23 (*While the most recent annual operator—to—operator agreement has not been renewed since 1999, the five parties have continued to coordinate their operations informally and have been operating interference—free."); MSV 101° WL. Order at 4 34. * See MSV Petition at 14—15. *‘ See Imarsat Opposition at21—22.

MSV suggests that in the absence of a coordination agreement the "significantly larger aggregate EIRP ("AEIRP®) of Inmarsat 4F2 relative to Inmarsat—3, could cause harmfl intersystem interference... .!"* This claim is also unavailing because the EIRP spectral density of the currentlyauthorized services will be no greater than the EIRP spectral density of those same services provided today on the Inmarsat—3 satellite,which will allowInmarsatto operate the Inmarsat 4F2 satellte within technical envelope ofthe last coordination agreement with msy.® Finally, MSV argues that "Inmarsat itself may suffer greater iterference upon operation of its new satellite to support existing services" because of the higher antenna gain of the Inmarsat 4F2." This claim is also not valid. As set forth in the Technical Appendix of the SkyWave Application and as explained by Inmarsat elsewhere, the global beam on the Inmarsat 4F2 satellite has same receive sensitivity as the global beam on the Inmarsat—3 satellte. Purther, the regional and narrow spot beams on the Inmarsat 4F2 satellite have better receive performance and better side—lobe roll—off than the Inmarsat—3 satellt."".Inmarsat has taken these factors into account and is confident that it can operate Inmarsat 4F2, so thatit is no more susceptible to interference than Inmarsat—3." "" MSV Petition at 14. * See Inmarsat Opposition at 22. * MSV Petition at 16. *‘ See Inmarsat Opposition at 22. * See id. —10—

E. The Inmarsat 4F2 Satellite Is Properly Regarded As A Replacement Satellite Despite what MSV may argue, the Inmarsat 4F2 satellite is properly regarded as a replacement satelie."" Through the Inmarsat 3 satellite at 54° W.L., SkyWave currently provides the Inmarsat D+ service to the continental U.S., Puerto Rico and the U.S. Virgin Islands, Although 1.25¢ further east, the Inmarsat 4F2 at 52.75° W.L. will also serve the continental U.S., Puerto Rico and the U.S. Virgin Islands, as well as operate over the same L— band service link frequencies that are authorized for use on the Inmarsat 3 satellite at 54° W.L. Despite what MSV may imply, SkyWave does not seek FCC authority to use Inmarsat METs in conjunction with the Inmarsat 4F2 satelite in any regions of the U.S. which are not presently served by the Inmarsat3 satellt. Accordingly, the proposed use ofthe Inmarsat 4F2 satellite can be considered a replacement satellite. This was precisely the Bureau‘s treatment of MSV‘s satellte application at 101° W.L.—— the Inmarsat 4F2 satellite should not be treated any differently."" In fact, MSV‘s satellte at 101° W.L. increased its geographic coverage area from the satelliteit replaced by adding parts of South America, but it was still regarded as a replacement satellite by the Bureau."" * See MSV Petition at 19. * See MSV101° W.L Order at\® 13—14. * Compare MSV101°W.L. Order at $ 1 ("The satellite will provide MSS on a common carrier basis within the United States, and between the United States and North America, Central America, the northemn part of South America, and the Caribbean.") with Amendment ofParts2 22, 25 ofthe Commission‘s Rules to Allocate Spectrumfor and to Establish Rules and Policies Pertaining to the Use ofFrequencies in a Land Mobile Satellte Servicefor the Provision of Various Common Carrier Services, Memorandum Opinion and Order and Authorization, 4 FCC Red. 6041, 6053 (1989) ("The proposed beam coverazeareas for the MSS network include the continental United States (CONUS), Alaska, Hawaii, Puerto Rico, Virgin Islands, Canada, parts of Mexico and Central America, including the Gulf of Mexico, and U.S. coastal areas up to 200 miles off—shore.") 3+

F. The Commission‘s FSS Station Keeping Rule Does Not Apply to MSS Satellites The MSV Petition states thatitis not clearly "settled" whether the Commission‘s Rule, 47 C.FR. §25.210(), requiring FSS satelltes to operate with +/> 0.05° East—West station keeping applies to MSS satellites."® However, the Commission‘s Rule and subsequent decisions are very clear —— Section 25.210() does not apply to MSS satellit. The Commission stated in its 2004 decision concerning the mitigation of orbital debris: "We decline, at this time, to adopt changes to Section 25.210() to specify a longitudinal tolerance of +/—0.05° for all space stations, including MSS and remote sensing space stations.""" Indecd, in fling a Petition for Clarification or Partial Reconsideration of its 101° W... authorization, MSV acknowledged that"there is no rule requiring MSS satellites to operate with a +0.05° East—West station keeping box.""" Section 25.210() is not applicable to the Inmarsat 4F2 satellite, and accordingly, a waiver ofthis rule by SkyWave is not required for the SkyWave Application."" * See MSV Petition at 20. * In the Matter ofMitigation ofOrbital Debris, 19 FCC Red. 11567, 11586 (2004). "* MSV Petition for Clarification or Partial Reconsideration, filed in File No. SAT—LOA— 19980702—00066 et al. (June 22, 2005). This is not an unsettled point of law as MSV argues. As the MSV Petition for Clarification or Partial Reconsideration makes clear, MSV‘s own request for a waiver of Section 25.210() for its replacement satellte at 101° W.L.(and its new satellite at 63.5° W.L..) was filed because when those applications were filed there was a proposal to apply 25.210() to MSS. See id at 2. However, as the 2004 Orbital Debris Mitigation Order makes clear, this proposal to modify 25.210G) was never adopted by the Commission. * If Section 25.210G) were applicable to MSS, which it is not,the Inmarsat 4F2 satellite would be in a better position than MSV to receive such a waiver. Unlike the orbital positions where MSV is authorized to operate, the 52.75° W.L. orbital location for the Inmarsat 4F2 is not nearly as congested, thereby mitigating the need for a strict station keeping rule with a longitudinal tolerance of +0.05%. See MSY 63.5° W.L. Order at 12; MSV 101° W.L. Order at 2021 at3.

111. CONCLUSION Forthe reasons stated above, SkyWave respectfully requests that the Bureau dismiss or deny the MSV Petition and promptly grant the SkyWave Application as set forth thercin. Respectfully submitted, SkyWave Mobile Communications, Corp. Mare A. Paul Brendan Kasper Steptoe & Johnson Lur 1330 Connectiout Avenue, NW Washington, D.C. 20036 (202) 420—3000 Counselfor StyWave Mobile Communications, Cor February 2, 2006

CERTIFICATE OF SERVICE 1, Mare A. Paul, an attomey with the law firm of Steptoe & Johnson LLP, hereby certify that on this 2nd day of February, 2006, served a true copy of the foregoing Opposition by first class mail, postage pre—paid (or as otherwise indicated) upon the following: James Ball® Andrea Kelly* Interational Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12"Street, S.W. Washington, DC 20554 Washington, DC 20554 Cassandra Thomas® Scott Kotler® International Bureau Intemational Burcau Federal Communications Commission Federal Communications Commission 445 12" Street, SW. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Howard GribofP® Karl Kensinger® International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12® Street, S.W. Washington, DC 20554 Washington, DC 20554 Fem Jarmulnek® John Martin® Intemational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12"Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Stephen Duall® Jennifer A. Manner Interational Bureau VicePresident, Regulatory AfTairs Federal Communications Commission Mobile Satellite Ventures Subsidiary LLC 445 12" Street, S.W. 1002 Park Ridge Boulevard Washington, DC 20554 Reston, Virginia 20191 Robert Nelson® Bruce D. Jacobs International Bureau David S. Konezal Federal Communications Commission Pillsbury Winthrop Shaw Pittman LLP 445 12"Street, S.W. 2300 N Street, N.W. Washington, DC 20554 Washington, DC 20037—1128

JoAnn Ekblad* John P. Janka International Bureau Jeffrey A. Marks Federal Communications Commission Latham & Watkins LLP 445 12" Street, S.W. 555 Eleventh Street, N.W., Suite 1000 Washington, DC 20554 Washington, D.C. 20004 Diane J. Comell Viee President, Government Affairs Inmarsat, Inc. 1100 Wilson Blyd, Suite 1425 Arlington, VA 22209 "NM._G @t * by Hand Delivery


Document Created: 2006-02-08 11:59:53
Document Modified: 2006-02-08 11:59:53
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