Attachment Row 44 response

Row 44 response

LETTER submitted by Row 44, Inc.

Row 44, Inc. Application for Special Temporary Authority

2008-08-22

This document pretains to SES-STA-20080811-01049 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2008081101049_660276

q’ LEVENTHAL SENTER & LERMAN PLLC August 22, 2008 Davio S. Ker E—MAIL (202) 416—6742 DKEIR@LSL—LaWw.cOM BY HAND Marlene H. Dortch, Secretary Office of the Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Row 44, Inc. Application for Special Temporary Authority (ECC File No. SES—STA—20080811—01049; Call Sign E0O80100) Dear Ms. Dortch: This letter responds to the August 13, 2008 correspondence submitted on behalf of ViaSat, Inc. concerning the above—referenced request for STA ("ViaSat Letter"), filed on August 11, 2008. In its application for Special Temporary Authority ("STA"), Row 44 has sought authorization to test on a temporary—fixed basis an Earth station already in use pursuant to an existing STA at Amherst, New Hampshire. See FCC File Nos. SES—STA—20080508—00571 and SES—STA—20080702—00877 (extension granted July 7, 2008). The test is intended to provide important pre—operational technical data concerning the antenna from various locations in the continental U.S. The FCC quickly placed the STA request on Public Notice on August 13, 2008. See FCC Public Notice, Report No. SES—01058, at 6 (released August 13, 2008) (placing the STA application on an expedited 7—day notice period, ending yesterday, August 20, 2008). The ViaSat Letter was filed that same day. ViaSat‘s expressed concerns regarding the STA are entirely derivative of its prior efforts to impede permanent licensing of Row 44‘s Earth terminals, and explicitly rely on these earlier pleadings. See ViaSat Letter at [ 2. ViaSat‘s assertions provide no basis for denial or delay of the requested STA, which is very limited in scope. Indeed, as ViaSat itself seems to acknowledge, most of the arguments it has previously made concerning the underlying application pertain only to mobile operation of the terminals (see ViaSat Letter at [ 3), and thus have no relevance to the operation proposed in the STA. Even to the very limited extent that ViaSat‘s assertions have some bearing in this context, Row 44 has now fully addressed them, as it has all of the questions contained in the FCC‘s August 7, 2000 K STREET, NW, SUITE 600, WASHINGTON, DC 20006—1809 TELEPHONE 202.429—8970 FAX 202.293.7783 WWWLSL—LAW.COM

& Marlene H. Dortch, Secretary August 22, 2008 Page —2— Letter. See Letter from Scott A. Kotler, Chief, Systems Analysis Branch, to David S. Keir, Counsel for Row 44, Inc. (dated August 7, 2008). The IB posed a few targeted questions concerning Row 44‘s proposed operations, and Row 44 has provided a complete and timely response. See Response of Row 44, Inc. to FCC Request for Additional Information, SES— AMD—20080819—01074, filed August 19, 2008. Only one aspect of this response addressed an issue relating to the proposed stationary STA operation —— the total input power and maximum EIRP of the antenna. With the modification of these parameters proposed in the recently—filed amendment, any potential interference concern that is moot. Based on the foregoing and its amended application, Row 44 respectfully requests that the Commission grant its STA application permitting it to conduct limited static testing of a single remote terminal, as described in its application, beginning immediately and continuing for a period of sixty (60) days. ly submitte David S. Keir Counsel to Row 44, Inc. DSK:sak cc: Robert Nelson Fern Jarmulnek Karl Kensinger Andrea Kelly Scott Kotler Sophie Arrington Shahnaz Ghavami Jeanette Spriggs John P. Janka, Counsel to ViaSat, Inc.


Document Created: 2008-08-22 11:35:59
Document Modified: 2008-08-22 11:35:59
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