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Comment Sought on LightSquared Subsidiary LLC Ex Parte Filing

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Released: August 7, 2013


Federal Communications Commission
445 12th St., S.W.

News Media Information 202 / 418-0500


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-1717

August 7, 2013


IB Docket Nos. 12-340, 11-109; IBFS File Nos. SAT-MOD-20120928-00160,-00161; SAT-MOD-

20101118-00239; SES-MOD-20121001-00872; RM-11681; WT Docket No. 12-327

Report No. SPB-253

Comment Date: September 6, 2013
Reply Comment Date: September 23, 2013

On July 15, 2013, LightSquared Subsidiary LLC (LightSquared) filed an ex parte presentation in these
proceedings that is related solely to terrestrial handsets (and does not address the technical matters
associated with terrestrial base stations).1 Specifically, the report provides an "overview of the
assessments" concerning the potential operations of LightSquared's terrestrial wireless handsets in the
1626.5-1660.5 MHz Mobile Satellite Service (MSS) uplink portion of the L-band.2 In particular, the
report provides technical analyses of the potential interaction of LightSquared terrestrial wireless devices
with GPS devices used for general location/navigation, high precision and aviation services.3
LightSquared states that the presentation includes a focused response to questions raised by several
government agencies.4 LightSquared concludes that the presentation provides validation to its proposed
plan for proceeding with the modified deployment of its terrestrial network.5 We seek comment on the
July 15, 2013 Presentation, including its analyses, assessments, and its conclusions.

1 Letter from John P. Janka, Counsel for LightSquared Subsidiary LLC, to Marlene H. Dortch, Secretary, Federal
Communications Commission, IB Docket No. 12-340; IBFS File Nos. SAT-MOD-20120928-00160, -00161, SES-
MOD-20121001-00872 (filed Jul. 15, 2013) (July 15, 2013 Presentation).
2 Id. at 1.
3 See generally id.
4 LightSquared indicates that since early 2012, it has sought a path to resolve the GPS issue and create a new
deployment plan in cooperation with government and military stakeholders. Id. at 1.
5 LightSquared further indicates that it has engaged with government stakeholders to build use cases to properly
evaluate the potential for conflict between its proposed modified operation and those of existing users in other
bands. Id. at 20.


These proceedings, with the exception of RM-11681, shall be treated as "permit-but-disclose"
proceedings in accordance with the Commission's ex parte rules.6 Persons making ex parte presentations
must file a copy of any written presentation or a memorandum summarizing any oral presentation within
two business days after the presentation (unless a different deadline applicable to the Sunshine period
applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the
presentation must (1) list all persons attending or otherwise participating in the meeting at which the ex
presentation was made, and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
already reflected in the presenter's written comments, memoranda or other filings in the proceedings, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be
found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission
staff during ex parte meetings are deemed to be written ex parte presentations and must be filed
consistent with rule 1.1206(b). In proceedings governed by rule 1.49(f) or for which the Commission has
made available a method of electronic filing, written ex parte presentations and memoranda summarizing
oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment
filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt,
searchable .pdf). Participants in these proceedings should familiarize themselves with the Commission's
ex parte rules.
Interested parties must file comments no later than

September 6, 2013

. Replies to such pleadings must
be filed no later than

September 23, 2013.

All filings concerning matters referenced in this Public Notice
should refer to

DA 13-1717, IB Docket Nos. 12-340, 11-109; IBFS File Nos. SAT-MOD 20120928-
00160, -00161; SAT-MOD-20101118-00239; SES-MOD-20121001-00872; RM-11681; WT Docket
No. 12-327

as well as the specific file numbers of the individual applications or other matters to which the
filings pertain.

Electronic Filers: Comments may be filed electronically using the Internet by accessing the

Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission's
Secretary, Office of the Secretary, Federal Communications Commission.

6 All of the proceedings listed in the caption above, with the exception of RM-11681, were designated as "permit-
but-disclose." See Federal Communications Commission Invites Comment on LightSquared Request to Modify its
ATC Authorization
, IB Docket 12-340, Public Notice, DA 12-1863 (Int'l Bur., Nov. 16, 2012); Wireless
Communications Bureau Seeks Comment on Request by OP LLC for Extension or Waiver of the Construction
Deadline Concerning its 1670-1675 MHz Band License
, WT Docket No. 12-237, DA 12-1776 (WTB, Nov. 5,
2012); Comment Deadlines Established Regarding the LightSquared Technical Working Group Report, IB Docket
No. 11-109, DA 11-1133 (Int'l Bur., June 30, 2011); Report No. SAT-00738, Public Notice (Int'l. Bur., Nov. 19,
2010). RM-11681 is exempt from the Commission's ex parte rules. 47 C.F.R. 1.1204(b)(2).

All hand-delivered or messenger-delivered paper filings for the Commission's Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries
must be held together with rubber bands or fasteners. Any envelopes and boxes must be
disposed of before entering the building.

Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.

U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities (braille,
large print, electronic files, audio format), send an e-mail to or call the Consumer &
Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
For further information, contact:
International Bureau: Robert Nelson, at or (202) 418-2341
Office of Engineering and Technology: Ronald T. Repasi, at or (202) 418-0768
Office of Strategic Planning & Policy Analysis: Nicholas Alexander, at or
(202) 418-2173
Wireless Telecommunications Bureau: Charles Mathias, at or (202) 418-7147.
Action by the Chiefs, International Bureau, Office of Engineering and Technology, Office of Strategic
Planning & Policy Analysis and Wireless Telecommunications Bureau.

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