DA 08-1659

July 14, 2008

**Robert M. Franklin, Trustee, and Inmarsat plc Seek FCC Consent To the
Transfer of Control of Stratos Global Corporation and Its Subsidiaries
from an Irrevocable Trust To Inmarsat plc**

**IB Docket No. 08-143**

**PLEADING CYCLE ESTABLISHED**

**Petitions to Deny Due: August 13, 2008**

**Oppositions Due: August 25, 2008**

**Replies Due: September 2, 2008**

**I. INTRODUCTION**

Robert M. Franklin, Trustee (Mr. Franklin or Trustee), and Inmarsat plc
(Inmarsat, and together with Mr. Franklin, Applicants) have filed a
series of applications (collectively, Application) pursuant to sections
214 and 310(d) of the Communications Act of 1934, as amended
(Communications Act),[^1] seeking approval of the indirect transfer of
control of Stratos Global Corporation (Stratos Global) and its
wholly-owned subsidiaries (collectively, "Stratos Subsidiaries," and
together with Stratos Global, "Stratos Licencees") that hold licenses
and authorizations from the Commission from an irrevocable trust, for
which Mr. Franklin is the trustee, to Inmarsat.

Stratos Global provides mobile satellite service (MSS), fixed satellite
service (FSS) and terrestrial communications using, among other things,
capacity that it purchases from various satellite operators, including
Inmarsat.

The proposed transaction is the second part of a two-part process that
began with the 2007 filing of an application seeking Commission approval
of the transfer of the stock of Stratos Global to an irrevocable trust
(Trust) established under the laws of Canada. The Trust was established
by CIP Canada Investment Inc. (CIP Canada), a wholly-owned subsidiary of
CIP UK Holdings Limited (CIP UK), which, in turn, is a wholly-owned
subsidiary of Communications Investment Partners Limited (CIP).

By Memorandum Opinion and Order released December 7, 2007, the
Commission approved the transfer of the stock of Stratos Global from its
then shareholders to the Trust, which now holds the stock for the
benefit of CIP Canada.[^2] Under the terms of the Trust, the Trustee has
the authority to vote the Stratos Global stock and, subject to his
fiduciary obligations, thereby to control Stratos Global.

Inmarsat did not acquire Stratos Global directly because another
Inmarsat subsidiary, Inmarsat Global Ltd. (Inmarsat Global), has
contractual restrictions that will expire in April, 2009, that forbid
Inmarsat Global from owning or controlling Stratos or any other
distributor of Inmarsat services. Inmarsat did, however, provide the
financing for the transaction through a wholly-owned subsidiary,
Inmarsat Finance III Limited (Inmarsat Finance). In the first step of
this transaction, Inmarsat Finance entered into a "Facilities Agreement"
under which it provided capital for CIP Canada's acquisition of the
Stratos Global stock. In turn, CIP granted Inmarsat Finance a "Call
Option" to acquire the stock of CIP UK, which is exercisable over a
17-month period beginning in April 2009 and ending on December 31, 2010.
Inmarsat, thus, has an irrevocable right to acquire Stratos Global after
the contractual restrictions on Stratos Global have expired. Until at
least April, 2009, the shares of Stratos Global will be held by the
Trust, which gives the Trustee both *de jure* and *de facto* control of
Stratos, to ensure compliance with Inmarsat Global's contractual
obligations.

**II. THE PARTIES**

**A. The Transferor -- the Trustee**

The transferor under the proposed transaction is Mr. Franklin, a citizen
of Canada, who is the Trustee under the Trust. The Commission's 2007
Memorandum Opinion and Order approved his serving as the Trustee.

**B. Stratos Global**

In the United States, Stratos Global provides MSS, FSS, and VSAT (very
small aperture terminal) satellite services, using satellite capacity
that it acquires from other entities. With respect to MSS, Stratos
resells satellite services of satellite operators such as Globalstar,
Inmarsat, Iridium, and MSV. Stratos holds FCC licenses for Inmarsat
mobile earth terminals, but does not own or operate any MSS gateway
earth stations in the United States. Stratos provides VSAT services by
reselling the services of several providers of FSS systems, such as
Intelsat and SES, and using a number of U.S. VSAT hubs that are licensed
to Stratos. Further, Stratos operates a terrestrial microwave network in
the Gulf of Mexico, which it primarily uses to serve offshore oil and
gas drilling platforms. Finally, Stratos provides local exchange,
competitive access, and interexchange telecommunications services in
Louisiana and Texas, also primarily to oil and gas industry customers.

Three of the Stratos Licensees, Stratos Offshore Services Company
(Stratos Offshore), Stratos Communications, Inc. (Stratos
Communications), and Stratos Mobile Networks, Inc. (Stratos Networks)
(all Delaware corporations), are wholly-owned subsidiaries of a fourth
Stratos Licensee, Stratos Holdings, Inc. (Stratos Holdings) (a Delaware
corporation). Stratos Holdings is a wholly-owned subsidiary of Stratos
Wireless Inc. (Stratos Wireless) (a Canadian corporation) which, in
turn, is a wholly-owned subsidiary of Stratos Global (also a Canadian
corporation). Stratos Global's corporate headquarters are in Bethesda,
Maryland.

**C. CIP**

CIP is a limited partnership organized under the laws of the British
Virgin Islands to hold shares of Stratos Global. CIP is a professional
investment company that focuses on investments in satellite service
companies. The five Directors and sole equity holders of CIP are Hans
Lipman (a Dutch citizen), Eric de Jong (a Dutch citizen), Hans van
Moorsel (a Dutch citizen), Eric Le Proux (a French citizen), and Victor
Horcacitas (a dual U.S. and Mexican citizen). Each holds a 20 percent
equity and voting interest in CIP.

CIP has established two holding companies to effectuate the proposed
transaction: CIP UK (a private limited company incorporated under the
laws of England and Wales); and CIP Canada (a Canadian company). CIP
Canada is wholly owned by CIP UK, which, in turn, is wholly owned by
CIP.

**D. Inmarsat Entities**

Inmarsat is a public company organized under the laws of England and
Wales that was created in 2005 as a result of the privatization of
INMARSAT, the International Maritime Satellite Organization.[^3]
Applicants state that Inmarsat's shares are widely held and that at
least 89 percent of the equity interests in Inmarsat are owned, and
approximately 88 percent of the voting power in Inmarsat is controlled,
by individuals who are citizens of, or entities whose principal place of
business is, the United States or another World Trade Organization (WTO)
Member country.

Inmarsat Global, also organized under the laws of England and Wales, is
a subsidiary of Inmarsat that operates a global MSS satellite system
that, through its distributors, offers a variety of mobile satellite
services. Applicants state that, at present, Inmarsat Global is
contractually restricted from selling its services directly to end
users, or from owning or controlling a company that distributes its
services. Applicants state that Inmarsat Global's current distribution
agreements, which contain this restriction, will expire in April, 2009.

Inmarsat Finance, a company incorporated under the laws of England and
Wales, is a special-purpose company that was established by Inmarsat for
this transaction to provide debt financing to CIP to fund the
acquisition of Stratos.

**III. THE TRANSACTION**

In December, 2007, the Commission authorized the transfer of control of
Stratos Global to the Trust. The Trust currently holds the shares of
Stratos Global for the benefit of CIP Canada. Mr. Franklin, the Trustee,
currently exercises the voting power represented by the Stratos Global
shares.

As noted above, CIP granted the lender in this transaction, Inmarsat
Finance, an option to acquire the shares of CIP UK. Applicants state
that Inmarsat Finance has decided to exercise its option and intends to
consummate the proposed transaction on, or shortly after, April 15,
2009, subject to receiving necessary regulatory approvals. Applicants
further state that, upon such exercise, the Trust will terminate and CIP
Canada will become the holder of the shares (and the associated voting
power) of Stratos Global. Inmarsat will then indirectly own and control
CIP UK, CIP Canada and Stratos Global.[^4] Applicants state that, in
this way, the proposed transaction will effectuate an indirect transfer
of control of Stratos Global to Inmarsat.

**IV. THE APPLICATION**

The Application consists of ten individual applications and documents as
follows:

-   Four FCC Forms 312 seeking consent for the transfer of Stratos
    Global's VSAT, FSS and MSS earth station Authorizations;

-   Two FCC International applications under Section 214 seeking consent
    to transfer Stratos Global's various international section 214
    Authorizations;

-   Two FCC Domestic 214 applications seeking consent to transfer
    Stratos Global's domestic section 214 authority;

-   One FCC Form 603 seeking consent to transfer Stratos Global's
    various terrestrial radio licenses; and

-   One FCC Form 44 seeking consent to transfer Stratos Global's
    Authorization as an Accounting Authority.

**V. SECTION 214 AUTHORIZATIONS**

**A. International Authorizations**

The following applications for consent to the transfer of control of
international section 214 authorizations to Inmarsat plc have been
assigned the file number listed below:

**[File No.]{.underline}** **[Authorization Holder]{.underline}**
**[Authorization Number]{.underline}**

ITC-T/C-20080618-00276 Stratos Holdings, Inc.

**International Facilities-Based and Resale Services Authorizations:**

ITC-214-20000426-00773

(Associated with ITC-MOD-

2004-0624-00241)

ITC-214-19980828-00591

ITC-214-19980326-00205

ITC-214-19980121-00028

ITC-214-20010220-00657

ITC-MOD-20040624-00241

**Mobile Network Authorizations:**

ITC-214-19981214-00859

ITC-214-19970924-00580

ITC-214-19970804-00455

ITC-214-19970627-00356

ITC-214-19961003-00481

ITC-214-19980130-00053

ITC-214-19910301-00010\*

(Formerly ITC-90-088)

ITC-214-19901030-00011\*

(Formerly ITC-91-012)

ITC-214-19910615-00009\*

(Formerly ITC-91-157)

ITC-214-19911206-00008\*

(Formerly ITC-92-058)

ITC-214-19911206-00007\*

(Formerly ITC-92-059)

ITC-214-19921026-00124\*

(Formerly ITC-93-013)

ITC-214-19921026-00123\*

(Formerly ITC-93-014)

ITC-214-19910201-00255\*

(Formerly ITC-93-141)

ITC-214-19931001-00254\*

(Formerly ITC-93-142)

ITC-214-19930511-00253\*

(Formerly ITC-93-188)

ITC-214-19950526-00034\*

(Formerly ITC-95-359)

ITC-214-19951001-00033\*

(Formerly ITC-95-565)

ITC-214-19951001-00032\*

(Formerly ITC-95-569)

ITC-214-19960101-00012\*

(Formerly ITC-96-041)

\* The above File Numbers for the section 214 authorizations marked with
an \* are new numbers assigned under the IBFS system. The former number
for each such authorization is shown below the new number.

**Offshore Services Authorizations:**

ITC-T/C-20080618-00275 Stratos Offshore Services Company
ITC-214-19991220-00815

ITC-214-19980914-00636

Applicants request streamlined processing for both of the above
Applications. Applicants assert that the Applications qualify for
streamlined processing because Inmarsat is not affiliated with any
foreign carrier and because the licensee in each of the Applications,
*i.e.,* Stratos Holdings (ITC-T/C-20080618-00276) and Stratos Offshore
(ITC-T/C-20080618-00275), qualifies, and post transaction, will continue
to qualify, for a presumption of non-dominance under section 63.10(a)(3)
of the Commission's rules, because the foreign carrier that each is
affiliated with has less than a 50 percent share of the local access
markets in the relevant geographical markets.[^5] Applicants also argue
that the Applications qualify for streamlined processing because neither
Stratos Holdings nor Stratos Offshore is or will be affiliated with any
dominant U.S. carrier whose international switched or private-line
services it seeks to resell, *see* 47 C.F.R. § 63.12(c)(2).[^6]

In light of the multiple applications before the Commission in this
transaction, however, and the public interest review associated with
them, we conclude, pursuant to sections 63.12 (c) and (d) of the
Commission's rules, that neither of the above international section 214
Transfer of control Applications will be subject to streamlined
treatment.[^7]

> **B.** **Domestic Authorization**

Applicants filed two applications for consent to transfer control of the
domestic section 214 authority of Stratos Communications and Stratos
Offshore from Robert Franklin, Trustee to Inmarsat. The first is for
Stratos Communications, Inc., an indirect subsidiary of Stratos Global,
which provides nationwide mobile satellite services where the
originating and terminating points may both be in the United States. The
second is for Stratos Offshore Services Company, a Stratos
Communications, Inc. affiliate, which provides wireline services in the
United States, primarily in the Gulf of Mexico region.

Applicants assert that these transactions are entitled to presumptive
streamlined treatment under sections 63.02(b)(1)(ii) of the
Commission\'s rules because Inmarsat and its subsidiaries do not provide
domestic telecommunications services in the United States pursuant to
section 214.[^8] Applicants also assert that these transactions are
entitled to presumptive streamlined treatment under section
63.03(b)(2)(i) because neither Stratos Communications, its affiliates,
nor Inmarsat will have market share in the domestic interstate,
interexchange market of ten percent or greater, will not provide
competitive telephone exchange services in markets served by a dominant
local exchange carrier that is a party to this transaction and operate
in a fully competitive environment.[^9]

In light of the multiple applications before the Commission in this
transaction, however, and the public interest review associated with
them, we conclude, pursuant to section 63.03(c) of the Commission's
rules, that Applicants' domestic section 214 transfer of control
Applications are not subject to streamlined treatment.[^10]

**VI. SECTION 310(d) APPLICATIONS**

**A. Part 25-Satellite Earth Station, VSAT, and Space Station
Authorization Applications**

The following applications for consent to the assignment and transfer of
control of satellite earth station, VSAT, and space station
authorizations from Robert Franklin (Trustee) to Inmarsat plc have been
assigned the file numbers listed below:

**[File No.]{.underline}** **[Licensee]{.underline}** **[Call
Sign(s)]{.underline}**

**Mobile Earth Terminal Authorizations:**

SES-T/C-20080618-00818 Stratos Communications, Inc. E010050

E010049

E010048

E010047

E000180

E050429

**Fixed Satellite Service (FSS) Authorizations:**

SES-T/C-20080618-00821 Stratos Offshore Services Company E010263

E070189

**Very Small Aperture Satellite (VSAT) Authorizations:**

SES-T/C-20080618-00820 Stratos Offshore Services Company E950149

**Earth Station on Board Vessels (ESV) Authorizations:**

SES-T/C-20080618-00819 Stratos Offshore Services Company E980235

E070114

**B. Part 90-Wireless Licenses**

The following application for consent to the transfer of wireless
service licenses from Robert M. Franklin (Trustee) to Inmarsat plc has
been assigned the file number listed below:

**[File No.]{.underline}** **[Licensee]{.underline}** **[Lead Call
Sign]{.underline}**

0003453455 Stratos Offshore Services Company KD41151

**VII. APPLICATION FOR ASSIGNMENT OF ACCOUNTING AUTHORITY STATUS**

Pursuant to section 3.20 of the Commission's rules,[^11] Applicants
filed an Application for Certification as an Accounting Authority (FCC
Form 44). Applicants note that one of the Stratos Licensees, Stratos
Mobile Networks, Inc., is currently certified by the Commission as an
Accounting Authority in the maritime mobile and maritime
mobile-satellite radio services, holding Accounting Authority
Identification Code (AAIC) No. US09.[^12] Maritime Mobile and Maritime
Mobile-Satellite communications refer to communications exchanged
between two vessels on the high seas or between a vessel and a land
radio station. An Accounting Authority is an entity, licensed by a
government, that settles accounts for mobile radio stations on vessels
licensed by that government, that is, the entity to which a foreign
maritime mobile radio station operator may send the bill for the
vessel's mobile communications. The Accounting Authority sends the bill
to the vessel operator and remits such vessel's payment to the foreign
station operator.

Applicants note that they do not, by this application, seek to assign,
or otherwise encumber, Stratos Mobile's Accounting Authority status, but
seek only to update the ownership and control information in the
Commission's files with respect to that Accounting Authority
certification. Applicants note that section 3.51 of the Commission's
rules requires Accounting Authorities to notify the Commission "in
advance of any proposed transfer of control of an accounting authority's
firm or organization by any means, to another entity."[^13] Applicants
note that notification is required because, under the proposed
transaction, control of the ultimate parent corporation of Stratos
Mobile, Stratos Global Corporation, is changing from the trustee Robert
M. Franklin to Inmarsat plc, a company formed under the laws of England
and Wales. Applicants assert that this change to Stratos Mobile's
ultimate parent corporation will have no impact on day-to-day Accounting
Authority functions currently performed by Stratos Mobile.

Applicants assert that Stratos Mobile does not currently expect to
change the way it administers its Accounting Authority function as a
result of the proposed transaction. Applicants assert that Stratos
Mobile will continue to perform all settlement operations for U.S.
licensed vessels through its office in Bethesda, Maryland (USA).

**VIII. PETITION FOR DECLARATORY RULING UNDER SECTION 310(b)(4)**

The Applicants request a declaratory ruling, pursuant to section 310
(b)(4) of the Communications Act, that it would serve the public
interest to allow up to 100 percent indirect non-U.S. ownership of the
Stratos Subsidiaries of Stratos Global that hold Commission
authorizations and Stratos Global.[^14]

Applicants note that in its 2007 *Stratos Order,* the Commission
approved up to 100 percent foreign ownership of Stratos Global by
Inmarsat, Inmarsat Finance, CIP UK, and CIP Canada; and stated that, if
Inmarsat Finance were to exercise its option to acquire CIP UK---thereby
indirectly acquiring Stratos Global---the Commission would review
Inmarsat's foreign ownership again.[^15] With the current Application,
Inmarsat provides updated information on its ownership and requests the
Commission to find that the proposed foreign ownership of Stratos Global
after the completion of this transaction to be consistent with the
public interest.

According to the Applicants, after consummation of the proposed
transaction, 100 percent of the stock of Stratos Global will be owned by
CIP Canada (a Canadian corporation). CIP Canada is wholly owned by CIP
UK, which will become a wholly-owned subsidiary of Inmarsat Finance,
which, in turn is wholly owned by Inmarsat plc. Applicants state that
each of CIP UK, Inmarsat Finance and Inmarsat plc is a company formed
under the laws of England and Wales. Applicants further state that each
of the entities in the organizational structure between the Stratos
Licensees and up to and including Inmarsat plc will hold 100 percent of
the equity and voting interests of the entity below it. Moreover,
Applicants state that the principal place of business of all these
entities will be in the United States, Canada or the United Kingdom.

As noted above, Applicants state that at least 89 percent of the equity
interests in Inmarsat are owned, and approximately 88 percent of the
voting power in Inmarsat is controlled, by individuals who are citizens
of, or entities whose principal places of business are, in the United
States or another WTO Member country. According to the Applicants, the
following four shareholders hold more than ten percent of the stock of
Inmarsat: (1) Harbinger Capital Partners Master Fund I, Ltd a Cayman
Islands fund (20 percent); (2) Harbert Fund Advisors, Inc., A U.S.
corporation (29 percent); (3) Lansdowne Partners Limited, a company
organized in England and Wales (11 percent); and (4) Lehman Brothers
(International) Europe, a company organized in England and Wales (11
percent).

Applicants state that the CIP and its subsidiaries, and the CIP
principals are all either entities organized under the laws of or are
citizens of Canada, the Netherlands, the British Virgin Islands, England
and Wales, Mexico or France, all of which are Members of the WTO. As a
result, Applicants argue that the presumption in the Commission's
Foreign Participation Order[^16] that foreign ownership by entities from
WTO Member countries in excess of the section 310(b)(4) benchmark will
serve the public interest should apply to this Application as well.
Thus, Applicants argue that the proposed ownership of the Stratos
Licensees is fully consistent with Commission precedent and asks the
Commission to find the proposed ownership to be in the public interest.
The petition for declaratory ruling has been assigned the file number
ISP-PDR-20080618-00013.

**IX. EX PARTE STATUS OF THIS PROCEEDING**

Pursuant to section 1.1200(a) of the Commission's rules,[^17] the
Commission may adopt modified or more stringent *ex parte* procedures in
particular proceedings if it finds that the public interest so requires.
We announce that this proceeding will be governed by permit-but-disclose
*ex parte* procedures that are applicable to non-restricted proceedings
under section 1.1206 of the Commission's rules.[^18]

We direct parties making oral *ex parte* presentations to the
Commission's statement re-emphasizing the public's responsibility in
permit-but-disclose proceedings and are reminded that memoranda
summarizing the presentation must contain the presentation's substance
and not merely list the subjects discussed.[^19] More than a one- or
two-sentence description of the views and arguments presented is
generally required.[^20] Other rules pertaining to oral and written
presentations are set forth in section 1.1206(b) as well.[^21] We urge
parties to use the Electronic Comment Filing System (ECFS) to file *ex
parte* submissions.[^22]

**X. GENERAL INFORMATION**

This Application has been found, upon initial review, to be acceptable
for filing. The Commission reserves the right to return any application
if, upon further examination, it is determined to be defective and not
in conformance with the Commission's rules or policies. Final action on
this Application will not be taken earlier than thirty-one (31) days
following the date of this Public Notice.[^23]

Interested parties must file petitions to deny or comments no later than
August 13, 2008. Responses or oppositions to comments and petitions must
be filed no later than August 25, 2008. Replies to such pleadings must
be filed no later than September 2, 2008. All filings concerning matters
referenced in this Public Notice should refer to **DA 08-1659, IB Docket
No. 08-143,** as well as the specific file numbers of the individual
applications or other matters to which the filings pertain.

Under the Commission's procedures for the submission of filings and
other documents,[^24] submissions in this matter may be filed
electronically (*i.e*., though ECFS) or by hand delivery to the
Commission's Massachusetts Avenue location.

-   Electronic Filers:[^25] Comments may be filed electronically using
    the Internet by accessing the ECFS: <http://www.fcc.gov/cgb/ecfs/>.
    In completing the transmittal screen, filers should include their
    full name, U.S. Postal Service mailing address, and the applicable
    docket number. Parties also may submit an electronic comment by
    Internet e-mail. To get filing instructions, filers should send an
    e-mail to ecfs@fcc.gov, and include the following words in the body
    of the message, "get form." A sample form and directions will be
    sent in response.

-   Paper Filers: Parties who choose to file by paper must file an
    original and four copies of each filing.

> Filings can be sent by hand or messenger delivery, by commercial
> overnight courier, or by first-class or overnight U.S. Postal Service
> mail (although we continue to experience delays in receiving U.S.
> Postal Service mail). All filings must be addressed to the
> Commission\'s Secretary, Office of the Secretary, Federal
> Communications Commission.
>
> The Commission\'s contractor will receive hand-delivered or
> messenger-delivered paper filings for the Commission\'s Secretary at
> 236 Massachusetts Avenue, N.E., Suite 110, Washington, D.C. 20002. The
> filing hours at this location are 8:00 a.m. to 7:00 p.m. All hand
> deliveries must be held together with rubber bands or fasteners. Any
> envelopes 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 should be
> addressed to 445 12th Street, S.W., Washington, D.C. 20554.

One copy of each pleading must be delivered electronically, by e-mail or
facsimile, or if delivered as paper copy, by hand or messenger delivery,
by commercial overnight courier, or by first-class or overnight U.S.
Postal Service mail (according to the procedures set forth above for
paper filings), to the Commission\'s duplicating contractor, Best Copy
and Printing, Inc., at fcc@bcpiweb.com or (202) 488-5563 (facsimile).

Additionally, filers may deliver courtesy copies by email or facsimile
to the following Commission staff:

(1) David Strickland, Policy Division, International Bureau, at
<David.Strickland@fcc.gov> or (202) 418-2824 (facsimile);

\(2\) John F. Copes, Policy Division, International Bureau, at
<John.Copes@fcc.gov> or (202) 418-2824 (facsimile);

(3) Karl Kensinger, Satellite Division, International Bureau, a
<Karl.Kensinger@fcc.gov> or (202) 418-0748 (facsimile);

\(4\) Erin McGrath, Wireless Telecommunications Bureau, at
<Erin.McGrath@fcc.gov> or (202) 418-7224 (facsimile);

\(5\) Jodie Donovan-May, Wireline Competition Bureau, at
<Jodie.May@fcc.gov> or (202) 418-1413 (facsimile);

\(6\) Regina Dorsey, Office of Managing Director, at
<Regina.Dorsey@fcc.gov> or (202) 418-2843 (facsimile)

\(7\) Neil Dellar, Office of General Counsel, at <Neil.Dellar@fcc.gov>
or (202) 418-1234 (facsimile).

Copies of the Applications and any subsequently-filed documents in this
matter may be obtained from Best Copy and Printing, Inc., in person at
445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, via
telephone at (202) 488-5300, via facsimile at (202) 488-5563, or via
e-mail at fcc@bcpiweb.com. The Applications and any associated documents
are also available for public inspection and copying during normal
reference room hours at the following Commission office: FCC Reference
Information Center, 445 12th Street, S.W., Room CY-A257, Washington,
D.C. 20554. The Applications also are available electronically through
the Commission's ECFS, which may be accessed on the Commission's
Internet website at http://www.fcc.gov.

People with Disabilities: To request this Public Notice in accessible
formats (computer diskette, large print, audio recording, and Braille)
send an email to <fcc504@fcc.gov> or call the Consumer & Governmental
Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).

For further information, contact John Copes, Policy Division,
International Bureau, at 202-418-1478.

**-FCC-**

[^1]: 47 U.S.C. §§ 214, 310(d).

[^2]: *Stratos Global Corporation, Transferor, Robert M. Franklin,
    transferee, Consolidated Application for Consent to Transfer of
    Control,* Memorandum Opinion and Order and Declaratory Ruling, WC
    Docket No. 07-73, FCC 07-213, 22 FCC Rcd 21328 (2007) (*Stratos
    Order*).

[^3]: INMARSAT was an intergovernmental organization that was created by
    the INMARSAT Convention in 1979 to develop a global maritime
    satellite system to meet the commercial maritime and safety
    communications needs of the United States and other countries. *See
    Comsat Corporation d/b/a* *Comsat Mobile Communications, et al.,*
    Memorandum Opinion, Order and Authorization, FCC 01-272, 16 FCC Rcd
    21661, 21669, ¶ 3 (2001). INMARSAT privatized in 1999 by converting
    to a private U.K. company headquartered in London. In 2005, Inmarsat
    became a public company, Inmarsat plc, listed on the London Stock
    Exchange.

[^4]: Applicants further state that Inmarsat Finance has the ability to
    assign its right to acquire CIP UK shares to another Inmarsat
    subsidiary. Applicants state that, if Inmarsat Finance elects to
    exercise this right, they will file a minor amendment to this
    Application to reflect any such *pro forma* change to the
    transaction structure.

[^5]: *See* 47 C.F.R. § 63.10(a)(3) (2007).

[^6]: *See* 47 C.F.R. § 63.12(c)(2) (2007).

[^7]: *See* 47 C.F.R. § 63.12(c) and (d) (2007).

[^8]: 47 C.F.R. § 63.03(b)(1)(ii) (2007).

[^9]: 47 C.F.R. § 63.03(b)(2)(i) (2007).

[^10]: *See* 47 C.F.R. § 63.03(c) (2007).

[^11]: 47 C.F.R. § 3.20 (2007).

[^12]: *See* Notification of Approval as an Accounting Authority, DA
    04-758 (rel. March 23, 2004).

[^13]: 47 C.F.R. § 3.51 (2007).

[^14]: 47 U.S.C. § 310(b)(4).

[^15]: Petition for Declaratory Ruling at 2, citing *Stratos Order*, 22
    FCC Rcd at 21370-71, ¶ 102.

[^16]: *Rules and Policies on Foreign Participation in the U.S.
    Telecommunications Market,* 12 FCC Rcd 23891.

[^17]: 47 C.F.R. § 1.1200(a) (2007).

[^18]: *Id.* § 1.1206.

[^19]: *See* Commission Emphasizes the Public's Responsibilities in
    Permit-But-Disclose Proceedings, Public Notice, 15 FCC Rcd 19945
    (2000).

[^20]: *See* 47 C.F.R. § 1.1206(b)(2) (2007).

[^21]: *Id.* § 1.1206(b).

[^22]: *See* discussion *infra* Part VI.

[^23]: *See* 47 U.S.C. § 309(b).

[^24]: *See Implementation of Interim Electronic Filing Procedures for
    Certain Commission Filings*, Order, 16 FCC Rcd 21483 (2001); *see
    also* *FCC Announces a New Filing Location for Paper Documents and a
    New Fax Number for General Correspondence*, Public Notice, 16 FCC
    Rcd 22165 (2001); *Reminder: Filing Locations for Paper Documents
    and Instructions for Mailing Electronic Media*, Public Notice, 18
    FCC Rcd 16705 (2003).

[^25]: *See* *Electronic Filing of Documents in Rulemaking Proceedings*,
    GC Docket No. 97-113, Report and Order, 13 FCC Rcd 11322 (1998).