Attachment Exhibits

This document pretains to SES-MFS-20110224-00194 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2011022400194_871182

FCC Form 312                                                                     Exhibit 1

         RESPONSE TO QUESTION 34: FOREIGN OWNERSHIP EXHIBIT

        Glentel Corp. (“Glentel”), a U.S. corporation, is wholly-owned by Glentel U.S.
Corp. (“Glentel US”), a U.S. corporation. Glentel US is, in turn, wholly-owned by
Glentel Inc., a publicly-held Canadian corporation whose shares are traded on the
Toronto Stock Exchange. The principal shareholder of Glentel Inc. is TCG International
Inc., which is a closely-held Canadian company, all of whose shareholders are
Canadian. Pursuant to the rules and policies established in the Commission’s Foreign
Participation Order, 12 FCC Rcd 23891 (1997), Order on Reconsideration, 15 FCC Rcd
18158 (2000), the “home market” of Glentel Inc. and TCG International Inc. is Canada,
which is a member of the World Trade Organization.

       In a grant (see Report No. TEL-00821; DA 04-2520, rel. Aug. 12, 2004) of a petition
for declaratory filed by Glentel (FCC File No. ISP-PDR-20030502-00014), the
Commission permitted the indirect foreign ownership of Glentel by Glentel Inc. and its
Canadian shareholders, including TCG International Inc., in an amount up to and
including 100%. The ruling also provided that Glentel could acquire up to and
including an additional, aggregate 25% indirect equity and/or voting interest from
other foreign individuals and entities without seeking further Commission approval
under Section 310(b)(4), subject to conditions. Glentel’s ownership remains within the
foreign ownership levels authorized by the Commission in 2004.


FCC Form 312                                                                                          Exhibit 2

             RESPONSE TO QUESTION 36: DISMISSAL OF APPLICATION

      Glentel Corp. (“Glentel”) has not had any FCC station authorization or license
revoked, nor has the Commission ever denied a Glentel application for an initial,
modification, or renewal of FCC station authorization, license, or construction permit.
The Commission did dismiss without prejudice a Glentel application for blanket
authority to operate up to 50,000 mobile earth terminals on a common carrier basis. The
dismissal was based on the direct ownership restrictions of Section 310(b)(3) the
Communications Act of 1934, as amended.1 After modifying its ownership structure,
Glentel re-filed the application and it was granted.

     Glentel is providing this information in response to Question 36 out of an
abundance of caution.




1In the Matter of Glentel Corp. For Blanket Authorization to operate up to 50,000 mobile satellite earth terminals
(E990349) though Canadian-licensed satellite MSAT-1 at 106.5 degrees W.L. in frequency bands 1530-1559 MHz
and 1631.5–1660.5 MHz throughout the Continental United States, United States Territories, Alaska, and Hawaii,
Memorandum Opinion and Order, DA 02-1509 (rel. Jun. 28, 2002).


FCC Form 312                                                                 Exhibit 3

        RESPONSE TO QUESTION 42: NON-U.S. LICENSED SATELLITES

       In this application, Glentel Corp. (“Glentel”) seeks to modify its mobile earth
terminal (“MET”) license by adding SkyTerra 1, located at 101.3° W.L., as a point of
communication, and by reflecting a change in the orbital location of MSAT-2, which
already is an authorized point of communication, to 103.3° W.L. SkyTerra 1 and MSAT-
2 are US-licensed satellites.

        The Commission also already has authorized Glentel’s METs to communicate
with MSAT-1, which is a Canadian-licensed satellite. Glentel is not seeking any changes
to this authority.



Document Created: 2011-02-24 12:26:36
Document Modified: 2011-02-24 12:26:36

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