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RESPONSE TO REPLY COMMENTS submitted by FTMSC US, LLC ("FTMSC")

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2006-10-24

This document pretains to SES-STA-20061006-01820 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2006100601820_533192

DLA PIPER OCT 2 6 2005 DLA Piperus LLP 1200 Nneteenth Strent, NW. Satolte Dvi Wastingen 5.0. 200302412 Internationats T202 001 3000 W windlapipercom FILED/ACCEPTED VIA HAND DELIVERY Oc 2 * Zuns Wemuk Coten October 24, 2006 conpaumtmese Tegsclsnermetssoio Marlene H. Dortch Office ofthe Secretary Federal Communications Cm’!‘mis on c/o 236 Massachusetts Avenu 445 12" Street, SW Washington, DC 20554 Re:— FTMSCUS, L C; lesponse to MSV Comments File No. SES—STA os1006—01820 (Call Siz £0s0284 Dear Ms. Dortch: FTMSC US, LLC ( C"), by its undersigned counsel, hereby responds to the Commentsfiled by Mobile Sat Ventures Subsidiary LLC (*MSV*), dated October 13, 2006, in the above—referenced file numi .\ At the outset, FTMSC notes that MSV does not oppose a prompt grant of the underlyii uest which is the subject of its Comments, rather it simply asks for. the clarification incorporation of conditions imposed by the Federal Communications Commissiont mmission") on all other similarly situated Broadband Global Area Network (*BGAN®) appli First, in its Comment ISV asks the Commission, upon grant of the new Special Temporary Authority (STA est by FTMSC ("New STA"),. to terminate the previous STA granted to FTMSC," because the ould be redundant.‘ However, the Commission should not Comments of Mobile Saelit res Subsidiry LLC, File No: SES—STA—20061006—01820 (Call Sign E080285),dared October 13, MSV Commens) See Application of FTMSC U for Special Temporay y, File No. Ss—STA—20061006—01820 (CallSign EOSO284)dared Oct 2006)°FTMSC STA Applcatn). STA of FTMSC, Fil No. SES— 060314—00438, dared July11, 2006 ("Prior STAY) See MSV Comments atp. 2

Marlene H. Dortch October 24, 2006 DLA PIPER Page 2 terminate the Prior STA proposed transaction transferring control of FTMSC is consummated. Itis possible ere may be a lapse between when the new STA is issued and the proposed transaction ie control of FTMSC can be consummated." FTMSC hereby agrees to retum the Prior STA liffmediately upon consummation of the proposed transaction transferring control of FTMSG to new owners. Second, MSV asks the Cofflmission to recognize that the two STAs should not authorize double the number of terming ested by cach STA." FTMSC confirms that it will not utlize both STAs concurrently and t operate more than the number of terminals set forth in each STA separately. Third, MSV argues |Commission should adopt ts proposed "clarified conditions" contained in its Petition for ClirifiGation attached to the MSV Comments as Exhibit A." FTMSC already responded to the issu by MSV in its Petition for Clarification and incorporated them in this docket" Moreovgr, SC is requesting the New STA only because of a proposed change of ownership, not to k a new or different service, and will be returning the Prior STA. The New STA will simply ‘feplace" the Prior STA. As indicated in its STA Applicnlion,' FIMSC agrees to comply 1 of the conditions contained in its Prior STA, which are identical to the conditions containgll in the STAs ofall other authorized BGAN operators." Fourth and finally, M leves that the Commission should establish a firm expiration date of November 30, 2006 New STA, and provide that no further extensions will be granted." The conditions of SC‘s Prior STA, and the New STA (assuming the same Under the proposed transctio 1 of FTMSC will tansfer from France Téldcom S.A.to MobSat SA.S See Amendment of FTMSC US L Application for Tik lt Authoriy, ile No. SES—AMD—20060804—01318 (iled Aug. 4, 2006) See MSV Comments atp.2. 1e Inmarst Ventres Limited ct Oppositonto Pettionfor Claifiation, Fle No. SES—STA—20060310— 00419 eal. June 19,2006) STA Application at 1. See Special Temporay Autho s, File No. ES—STA—20060316—00158; Strtos, File No. SES—STA— 20060310—00419; Telenor, Filg Na¥JSES—STA—20060313—00430; and Briish Telecom, File No. SES—STA— 2n0s0s1s—00445; See MSV Comments atp. 4.

Marlene H. Dortch October 24, 2006 DLA PIPER Page 3 conditions will be adopted), the FCC to terminate it at any time." Thus, there is no purpose to be served by est ing a new condition restricting the provision of services. However, if the Commission ts, FTMSC does not oppose the New STA expiring on the same date as all other BGAN r STAs, and is only asking that it be treated the same as all other BGAN operators Finally, we note that V Comments are not new and were, in fact, incorporated by reference along with all respot our STA requests. Thus, we will not respond to them again here, Please file—stamp and retuth the extra copy of this fling in the pre—addressed, stamped envelope provided for this purpos Kindly refer any questions or comments to the undersigned. Regards, Wlbk. Coull Williem K. Coulter Counsel for FTMSC US, LLC ‘ee Condiion (8)t Prir STA "(this STA may betermiatedomodifed atthInernationalBureau‘s discretion, withouta hearing,if ndfions warent."

CBRTIFICATE OF SERVICE 1, Christine L. Zepka, lTN certify that on this 24th day ofOctober, 2006, 1 caused to be served a true copy ofthe foregbing esponse by first class mail, postage pre—paid (or as otherwise indicated) upon the fol ing: Roderick Porter Gardner Foster International Bureau Interational Bureau Federal Communications Compri Federal Communications Commission 445 12® Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 By Hand By Hand James Ball Andrea Kelly International Bureau International Bureau Federal Communications Compri Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 By Hand By Hand Cassandra Thomas Scott Kotler Interational Bureau International Bureau Federal Communications Compi Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 By Hand By Hand Howard Gribo® Karl Kensinger International Bureau International Bureau Federal Communications Compi Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 By Hand By Hand Stephen Duall John Martin International Bureau n'l'n International Bureau Federal Communications Compi Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 By Hand By Hand wonasnas

Fem Jarmulnck Jennifer A. Manner International Bureau Vice President, Regulatory Affairs Federal Communications Comis n Mobile Satellite Ventures Subsidiary LLC 445 12" Street, S.W. 1002 Park Ridge Boulevard Washington, DC 20554 Reston, Virginia 20191 By Hand Robert Nelson Bruce D. Jacobs International Bureau David S. Konezal Federal Communications Comuis Pillsbury Winthrop Shaw Pittman LLP 445 12" Street, S.W. 2300 N Street, N.W. Washington, DC 20554 Washington, DC 20037—1 128 By Hand Counsel for: Mobile Satellite Ventures Subsidiary LLC Dianne J. Comell John P. Janka Vice President, Government Aftai Jeffiey A. Marks Inmarsat,Inc. Latham & Watkins LLP 1100 Wilson Blvd., Suite 1423 555 11" Street, N.W., Suite 1000 Arlington, VA 22209 Washington, DC 20004 Counsel for: Inmarsat Ventures Limited Anne Grandjacques Juriste / Legal Counsel France Telecom Mobile Satellte Communications 16 Bud du Mont dEst 93161 Noisy le Grand Cedex R France Christine L. Zepka wonosons


Document Created: 2006-10-26 09:19:58
Document Modified: 2006-10-26 09:19:58
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