**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

+------------------------------+-------+------------------------------+
| In the Matter of             | **)** | File No.                     |
|                              |       | SES-LIC-19980415-00436       |
| OuterLink, Inc.              | **)** |                              |
|                              |       |                              |
| Application For a Blanket    | **)** |                              |
| Authorization To Operate     |       |                              |
| 20,000 Mobile Earth          | **)** |                              |
| Terminals in the 1530-1559   |       |                              |
| MHz and 1638.5-1642 MHz      | **)** |                              |
| Frequency Bands (E980203)    |       |                              |
|                              | **)** |                              |
|                              |       |                              |
|                              | **)** |                              |
|                              |       |                              |
|                              | **)** |                              |
|                              |       |                              |
|                              | **)** |                              |
|                              |       |                              |
|                              | **)** |                              |
+------------------------------+-------+------------------------------+

**ORDER AND AUTHORIZATION**

**Adopted: June 28, 2002 Released: July 2, 2002**

By the Deputy Chief, Satellite Division, International Bureau:

**I.** **Introduction**

1.  By this Order and Authorization, we grant OuterLink, Inc.[^1]
    (OuterLink) blanket authority, subject to certain conditions, to
    operate up to 20,000 mobile earth terminals (METs), on a
    non-interference basis, to provide mobile satellite service (MSS) in
    the United States via the U.S.-licensed satellite, AMSC-1, at 101º
    W.L. in portions of the L-band spectrum.[^2] Grant of this
    application will facilitate increased competition in the MSS market,
    providing U.S. consumers and users with innovative and improved
    mobile data communications service offerings at lower prices.

**II. Background**

2.  On April 15, 1998, OuterLink filed an application requesting blanket
    authority to operate up to 20,000 full duplex[^3] METs throughout
    the United States via the U.S.-licensed AMSC-1 satellite using
    frequencies coordinated and in use by the Inmarsat Ventures plc
    (Inmarsat)[^4] satellite system.[^5] AMSC-1 satellite is owned and
    operated by Mobile Satellite Ventures Subsidiary, LLC (MSV).[^6]
    OuterLink's proposed METs will use wide-band direct sequence spread
    spectrum (DSSS) multiple access, operating on frequency bands
    1638.5-1642 MHz (transmit) and 1530-1559 MHz (receive). DSSS is a
    co-frequency spread spectrum technique designed to widely disperse
    signal energy that lowers transmitted power spectral density and
    thus intersystem interference potential. OuterLink says the METs
    will be used to provide mobile packet data service, on a non-common
    carrier basis, to land vehicles, maritime vessels, aircraft and
    certain fixed installations throughout the continental United
    States. According to OuterLink, the METs are capable of transmitting
    bursts or packets, typically 30 milliseconds in duration. Each MET
    will consist of transmit and receive communications antennas, a
    Global Positioning System (GPS) receive antenna, the transceiver
    with internal GPS Engine, and user interface ports, including both
    discrete sensor ports and serial data ports to interface with
    keyboard/display devices, external microprocessors or sensors.[^7]
    OuterLink is currently authorized to conduct commercial trial's
    using 20,000 METs, under special temporary authority (STA). Pursuant
    to STA, OuterLink is required to provide test data demonstrating the
    ability and performance characteristics of its METs, *e.g.,*
    preemption time and prioritization scheme of the downlink channel to
    implement priority and preemption of their normal traffic to
    accommodate aeronautical safety service requirements.[^8]

3.  Petitions to deny OuterLink's application were filed by Globalstar
    L.P. (Globalstar)[^9] and Space System License, Inc. and Iridium LLC
    (collectively Iridium).[^10] An informal objection was filed by
    Inmarsat. [^11] The National Telecommunications and Information
    Administration (NTIA) submitted comments on OuterLink's
    proposal.[^12]

**III. Discussion**

[Petitions to deny]{.underline}

4.  Globalstar objects to OuterLink's proposal on two grounds. First,
    Globalstar argues that MSV's current operations in the lower L-band
    does not afford MSV sufficient capacity to support the 20,000 METs
    specified by OuterLink in its application because the special
    temporary authority limited MSV to operate only 15,100 METs.[^13]
    Second, Globalstar contends that OuterLink's application violates
    the so-called "freeze" the Commission placed on the filing of
    applications to use the lower L-band frequencies, pending adoption
    of regulatory policies for the provision of service in the lower
    L-band. Iridium raises the same objections. In addition, Iridium
    contends that OuterLink does not provide sufficient information to
    permit Iridium to determine whether OuterLink's operation in the
    1638.5-1642 MHz band would cause harmful out-of-band interference to
    the Iridium satellite system operating in the 1621.35-1626.5 MHz
    band. Consequently, Iridium asks that grant of OuterLink's
    application be conditioned on completion of coordination with
    Iridium.

5.  At the time Globalstar and Iridium filed their objections, no U.S.
    space station had regular authority to operate in the lower L-band.
    The Commission also had not adopted rules and policies governing the
    use of frequencies in the lower L-band.[^14] MSV was authorized to
    use spectrum in the lower L-band coordinated for the U.S.-licensed
    satellite system, on a temporary basis.[^15]

6.  On February 7, 2002, the Commission released the *Lower L-band
    Report and Order* establishing licensing rules and policies
    governing use of the lower L-band. In view of this action, issues
    related to the scope of MSV's authority and the so-called "freeze"
    are moot. [^16]

7.  Regarding out-of-band interference, we find no need to impose a
    condition on OuterLink to coordinate with Iridium. Rather, we have
    imposed a condition to ensure that OuterLink's METs operate in a
    manner consistent with the Commission's out-of-band emissions
    requirements.[^17] Moreover, in the event that Iridium actually
    experiences harmful interference from out-of-band emissions caused
    by OuterLink, we expect the parties to attempt to resolve the
    matter. If a mutually acceptable solution is not possible, the
    Commission will then intervene.[^18]

[Inmarsat's Informal objection]{.underline}

8.  OuterLink points out that in tests conducted in 1997, that led to
    its grant of temporary authority in the lower L-band, OuterLink's
    proposed use of DSSS technique would reduce the potential for
    interference to the Inmarsat system.[^19] More recently, in a letter
    filed April 3, 2002, OuterLink submits that recent tests affirm the
    1997 test results. OuterLink further points out that in response to
    the April 2002 test results, Inmarsat informed the Commission that
    Inmarsat did not oppose OuterLink's continued operations in the
    lower L-band. OuterLink notes that after nearly four years of its
    system's operation, there have been no complaints of harmful
    interference, nor does it anticipate the situation will change after
    OuterLink places its proposed 20,000 METs into operation. [^20]

9.  Inmarsat takes a different view of OuterLink's current operation.
    Inmarsat opposes the grant of OuterLink's application, unless and
    until the OuterLink service is coordinated between Inmarsat and MSV.
    Inmarsat says it is concerned that the grant of OuterLink's
    application would give Outerlink authority to object to interference
    caused by Inmarsat. This, says Inmarsat, would be inconsistent with
    the current state of coordination between Inmarsat and MSV. Inmarsat
    states that when OuterLink filed its application in 1998, Inmarsat
    was assured that OuterLink's services would not interfere with
    Inmarsat's system. Based on these assurances, Inmarsat says it
    provided limited consent to allow OuterLink to operate using
    spectrum in the lower L-band assigned for Inmarsat's use. Inmarsat
    adds, however, that at no time did it agree to OuterLink's
    operations being protected from any interference that might be
    caused by Inmarsat's system. Inmarsat states that it specifically
    acknowledged Outerlink's possible vulnerability to interference from
    Inmarsat, and thus, Inmarsat reserved the right to withdraw its
    consent at any time.[^21]

10. Since 1998, Inmarsat states that it has been providing services to
    customers, including the U.S. Navy, from a satellite at 98º W.L.
    orbital location, which has increased the potential of mutual
    interference effects by 20dB. Nevertheless, says Inmarsat, OuterLink
    has continued to offer its service in the same portion of the lower
    L-band. Inmarsat also observes that OuterLink has complained on a
    number of occasions about interference from Inmarsat's operations,
    despite the fact that OuterLink has been authorized to operate in
    the lower L-band on a temporary, non-interference basis. Moreover,
    Inmarsat says it anticipates that the use of its spectrum by the
    U.S. Navy and other customers will steadily increase, making
    interference to OuterLink's terminals more likely. Further, Inmarsat
    says it is concerned that if OuterLink's application is granted,
    OuterLink may attempt to use the license to claim protection from
    Inmarsat's operations and thereby limit Inmarsat's use of its
    assigned spectrum to the detriment of Inmarsat's service to its
    customers, including the U.S. Navy. Consequently, Inmarsat suggests,
    that OuterLink modify its service to use spectrum that MSV has
    coordinated with Inmarsat in the North America coverage area.
    Otherwise, Inmarsat asks that OuterLink's application be denied, or
    alternatively, that any grant of authority be expressly conditioned
    on OuterLink not being entitled to claim any protection from
    interference caused by Inmarsat's operations.[^22]

11. In response to Inmarsat's concerns, OuterLink suggested three
    conditions on the grant of its application.[^23] Inmarsat, in turn,
    responded with a letter indicating it would no longer object to the
    grant of OuterLink's application, subject to the following
    conditions:

1\. OuterLink cannot claim protection from interference from earth
stations communicating with Inmarsat satellites and operating in the
1638.5-1642.0 MHz band unless and until OuterLink's service is
coordinated between Inmarsat and MSV.

> 2\. In the absence of a coordination agreement between Inmarsat and
> MSV, OuterLink must provide its service on a non-interference basis.
>
> 3\. In light of its continued commitment not to cause interference to
> Inmarsat, OuterLink should continue to be held to its prior obligation
> not to interfere with Inmarsat's system in the 1638.5-1642.0 MHz band.
>
> 4\. OuterLink's license should be subject to the terms of any
> agreements between Inmarsat and MSV regarding the coordination of
> spectrum in the L-band as they currently exist and as they may be
> modified by future negotiations.[^24]

Inmarsat states that OuterLink has agreed to these conditions.[^25] We
have reviewed the concerns raised by Inmarsat and OuterLink in this
regard and have imposed conditions similar to those agreed to by
Inmarsat and OuterLink to address these concerns.

[Priority and Preemptive Access]{.underline}

12. We also note that NTIA has reviewed OuterLink's proposal and has
    raised concerns about whether the DSSS co-frequency spread spectrum
    operations OuterLink proposes are fully compatible with Inmarsat's
    Global Maritime Distress and Safety System (GMDSS). US Footnote 315
    to the Table of Frequency Allocations to Section 2.106 of the
    Commission's rules provides for real-time access and priority
    preemption capability for maritime mobile service and distress and
    safety communications.[^26] NTIA suggests that OuterLink's
    compatibility with the Inmarsat system requires further validation
    to ensure that its operation will not interfere with important
    safety-related communications services. Consequently, NTIA
    conditions its approval upon requiring that the license be limited
    to a period of three years. To address NTIA's concerns, we will
    impose a three-year license period. In addition, we will impose
    additional conditions on OuterLink's operation of the METs to ensure
    that its system does not cause harmful interference to other
    operating systems.

```{=html}
<!-- -->
```
IV. **Conclusion**

```{=html}
<!-- -->
```
13. We find that OuterLink has demonstrated that its operations will
    comport with the Commission's requirements and that it is qualified
    to hold the blanket earth station authorizations requested.
    Consequently, we grant OuterLink's' application, subject to the
    conditions set forth below, authorizing OuterLink to provide MSS
    service in the United States over the AMSC-1 satellite using
    frequencies coordinated and in use by the Inmarsat satellite system.
    We also deny the petitions to deny filed by Globalstar and Iridium.

**V. Ordering Clauses**

14. Accordingly, IT IS ORDERED that Application File
    No.SES-LIC-19980415-00436 IS GRANTED and OuterLink, Inc. IS
    AUTHORIZED to operate up to 20,000 mobile earth terminals (METs) in
    the frequency bands 1638.5-1642 MHz and 1530-1559 MHz through the
    AMSC-1 space station at 101º W.L. to the extent indicated herein, in
    accordance with the technical specifications set forth in its
    application and its Radio Station Authorization, and consistent with
    the Commission's rules, subject to the conditions set forth below.

15. IT IS FURTHER ORDERED that in the absence of a continuing annual
    operator-to-operator coordination agreement, OuterLink, Inc.'s
    operation in the frequency bands 1638.5-1642 MHz and 1530-1559 MHz
    will be on a non-harmful interference basis. Consequently, in the
    absence of a coordination agreement, OuterLink, Inc. shall not cause
    harmful interference to any other lawfully operating satellite or
    radio facility and shall cease operations upon written notification
    of such interference. Furthermore, OuterLink, Inc. must notify all
    other operators in these frequency bands that it will be operating
    on a non-harmful interference basis. OuterLink, Inc. must also
    notify its customers in the United States that its operations are on
    a non-harmful interference basis.

16. IT IS FURTHER ORDERED that operation of the METs will not be
    protected from the Inmarsat satellites in the 1638.5--1642.0 MHz
    band, unless and until Outerlink's service is coordinated between
    Inmarsat and MSV.

17. IT IS FURTHER ORDERED that OuterLink, Inc., in light of its
    continued commitment not to cause interference to Inmarsat Ventures
    plc, OuterLink, Inc. shall continue to be held to its prior
    obligation not to interfere with Inmarsat Ventures plc in the
    1638.5-1642 MHz band, consistent with the arrangement between
    OuterLink and Inmarsat, described in the letter from John Janka,
    Counsel to Inmarsat, to Thomas S. Tycz, Chief, Satellite and
    Radiocommunication Division, International Bureau, FCC, dated June
    6, 2002. *See also* letter from John Janka, Counsel to Inmarsat, to
    Thomas S. Tycz, Chief, Satellite and Radiocommunication Division,
    International Bureau, FCC, dated April 23, 2002.

18. IT IS FURTHER ORDERED that OuterLink, Inc. must operate its METs in
    a full-duplex mode and have the following minimum set of
    capabilities to ensure compliance with US Footnote 308 to Section
    2.106 of the Commission's rules, 47 C.F.R. § 2.106, and ITU Radio
    Regulations 5.357:

> a\. All MET transmissions shall have a priority assigned to them that
> preserves the priority and preemptive access given to aeronautical
> distress and safety-related communications sharing the band;
>
> b\. Each MET with a requirement to handle maritime distress and safety
> data communications shall be capable of either recognizing message and
> call priority identification when transmitted from its associated Land
> Earth Station (LES) or accepting message and call priority
> identification embedded in the message or call when transmitted from
> its associated LES and passing the identification to shipboard data
> message processing equipment;
>
> c\. Each MET shall be assigned access to a unique technical
> identification number that will be transmitted upon any attempt to
> gain access to a system;
>
> d\. After a MET has gained access to a system the mobile terminal
> shall be under control of a Land Earth Station and shall obtain all
> channel assignments from it;
>
> e\. All METs that do not continuously monitor a separate signaling
> channel shall have provisions for signaling within the communications
> channel;
>
> f\. Each MET shall automatically inhibit its transmissions if it is
> not correctly receiving a separate signaling channel or signaling
> within the communications channel from its associated Land Earth
> Station; and
>
> g\. Each MET shall automatically inhibit its transmissions on any or
> all channels upon receiving a channel-shut-off command on a signaling
> or communications channel it is receiving from its associated Land
> Earth Station.

19. IT IS FURTHER ORDERED that the full duplex METs operating in the
    1525-1530 MHz, 1530-1544 MHz and 1626.5-1645.5 MHz bands shall have
    the following minimum set of capabilities to ensure compliance with
    Footnote 5.353A and the priority and real-time preemption
    requirements imposed by US Footnote 315 to Section 2.106 of the
    Commission's rules, 47 C.F.R. § 2.106 and ITU Radio Regulations
    5.357.

> a\. All MET transmissions shall have a priority assigned to them that
> preserves the priority and preemptive access given to maritime
> distress and safety communications sharing the band;
>
> b\. Each MET with a requirement to handle maritime distress and safety
> data communications shall be capable of either (1) recognizing message
> and call priority identification when transmitted from its associated
> Land Earth Station (LES) or (2) accepting message and call priority
> identification embedded in the message or call when transmitted from
> its associated LES and passing the identification to shipboard data
> message processing equipment;
>
> c\. Each MET shall be assigned access to a unique technical
> identification number that will be transmitted upon any attempt to
> gain access to a system;
>
> d\. After a MET has gained access to a system the mobile terminal
> shall be under the control of a LES and shall obtain all channel
> assignments from it;
>
> e\. All METs that do not continuously monitor a separate signaling
> channel or signaling within the communications channel shall monitor
> the signaling channel at the end of each transmission;
>
> f\. Each MET shall automatically inhibit its transmissions if it is
> not correctly receiving a separate signaling channel or signaling
> within the communications channel from its associated LES;
>
> g\. Each MET shall automatically inhibit its transmissions on any or
> all channels upon receiving a channel-shut-off command on a signaling
> or communications channel from its associated LES; and
>
> h\. Each MET with a requirement to handle maritime distress and safety
> communications shall have the capability within the station to
> automatically preempt lower precedence traffic.

20. IT IS FURTHER OREDERED that, in accordance with US Footnote 308, the
    operation of OuterLink, Inc.'s METs, in the bands 1545-1558.5 and
    1646.5-1660 MHz, is on a secondary basis to U.S. AMS(R)S
    requirements of other U.S.-authorized MSS providers operating in the
    1545-1559 and 1646.5-1660 MHz bands.

21. IT IS FURTHER ORDERED that OuterLink's METs shall comply with the
    out-of-band emission limits set forth in Section 25.216 of the
    Commission's rules. *See Out-of-Band Emission Order,* FCC 02-34
    (rel. May 14, 2002).

22. IT IS FURTHER ORDERED that OuterLink, Inc. is not authorized to
    operate in the 1544-1545 MHz and 1645.5-1646.5 MHz bands that are
    limited in the United States exclusively for use for distress and
    safety communications. *See* C.F.R. Section 2.106nn.727A, 734B.

23. IT IS FURTHER ORDERED that this authorization does not permit
    OuterLink, Inc. to provide commercial mobile radio service (CMRS) to
    end-users, either the public, or such classes of users as to be
    effectively available to a substantial portion of the public, for
    profit and for interconnection with the public switched network. If
    OuterLink, Inc. wishes to provide CMRS, which is classified as a
    common carrier service, it must obtain authority to modify this
    license to permit the provision of common carrier service and must
    obtain any requisite authority under Section 214 of the
    Communications Act, 47 U.S.C. § 214, before providing such service.

24. IT IS FURTHER ORDERED that OuterLink, Inc. must maintain a current
    listing of platform users on which terminals are located, including
    the user/customer phone number and necessary information to
    terminate operation if harmful interference is caused to the Global
    Maritime Distress and Safety System (GMDSS).

25. IT IS FURTHER ORDERED that the METs authorized by this *Order and
    Authorization* must employ short transmission bursts. These bursts
    or packets are typically 30 milliseconds in duration. The maximum
    packet length shall be no longer than 275 milliseconds in duration.
    OuterLink, Inc. must monitor its traffic loading to ensure that the
    total power transmitted in OuterLink's 3.5 MHz channel at any given
    time does not exceed 22 dBW EIRP. The maximum EIRP and EIRP density
    of each MET shall be limited to 14.76 dBW and --14.6 dBW/4kHz,
    respectively.

26. IT IS FURTHER ORDERED that each MET be tunable over the entire range
    of frequencies authorized for Mobile Satellite Ventures Subsidiary,
    LLC downlink transmissions, such that the integrity of AMS(R)S
    spectrum is maintained as a contiguous block of spectrum. Mobile
    Satellite Ventures Subsidiary, LLC/OuterLink, Inc. must provide test
    data demonstrating the ability and performance characteristics of
    the mobile earth terminals, *e.g.,* preemption time, and
    prioritization scheme of the downlink channel to implement priority
    and preemption of their normal traffic to accommodate aeronautical
    safety service requirements.

27. OuterLink, Inc.'s system must not inhibit future changes or
    expansions of GMDSS communications capabilities, including the use
    of different modulation and multiple access schemes or the
    relocation or the use of other Inmarsat satellites for GMDSS.

28. IT IS FURTHER ORDERED that the Petition to Deny in Part of
    Globalstar, L.P. and the Petition to Deny or Defer of Space System
    License, Inc. and Iridium LLC ARE DENIED.

29. IT IS FURTHER ORDERED that this license shall not vest in OuterLink,
    Inc. any right to operate Earth stations or use the assigned
    frequencies beyond the term thereof or in any manner other than
    authorized herein, and neither the licensee nor the rights granted
    thereunder shall be assigned or otherwise transferred in violation
    of the Communications Act.

30. IT IS FURTHER ORDERED that the license term for the METs that are
    authorized by the *Order and Authorization* be for three years.

31. IT IS FURTHER ORDERED that OuterLink, Inc. be afforded thirty days
    to decline this authorization. Failure to respond within this period
    will constitute formal acceptance of the authorization.

> **FEDERAL COMMUNICATIONS COMMISION**
>
> Cassandra C. Thomas

Deputy Chief, Satellite Division

[^1]: OuterLink was formerly named Newcomb Communications.

[^2]: The "L-band" is a general designation for frequencies from 1 to 2
    GHz. In this Order and Authorization, however, the term "L-band"
    denotes only the 1545-1559 MHz and 1646.5-1660.5 MHz frequency band
    ("upper L-band") and the 1525-1530 MHz, 1530-1544 MHz, and
    1626.5-1645.5 MHz frequency bands ("lower L-band"). The United
    States is the only country that distinguishes between the "upper"
    and "lower" L-band.

[^3]: A full-duplex MET can receive a data message while transmitting
    one. Conversely, a half-duplex MET cannot receive and transmit data
    messages simultaneously. It must finish transmitting before it can
    receive an incoming message.

[^4]: Inmarsat, formerly the International Maritime Satellite
    Organization, was an intergovernmental organization created to
    develop a global maritime satellite system to meet commercial
    maritime and safety communications needs of the United States and
    foreign countries.

[^5]: MSV is representing OuterLink in coordinating with Inmarsat and
    other non-US MSS providers operating within the L-band. *See*
    OuterLink Application Exhibit I "Frequency Coordination Report."

[^6]: MSV is part of a Canadian-American joint venture of the former
    U.S. licensee, Motient Services, Inc. (Motient) and the Canadian
    licensee, TMI Communications and Company, LP (TMI). ). *See Motient
    Services Inc. and TMI Communications and Company, LP Assignors,* 16
    FCC Rcd 20,469 (2001). At the time OuterLink filed its application,
    Motient (formerly AMSC Subsidiary Corporation) was the AMSC-1
    licensee. In order to avoid confusion, both AMSC and Motient are
    referred to as MSV in this Order and Authorization.

[^7]: *See* OuterLink Application at 3.

[^8]: OuterLink request for Special Temporary Authority to continue
    conducting commercial trials via AMSC-1 Satellite, 16 FCC Rcd 8389
    (DA 01-664, released April 16, 2001)

[^9]: *See* Globalstar Petition to Deny in Part, filed Oct. 19, 1998.

[^10]: *See* Iridium Petition to Deny or Defer, filed Oct. 19, 1998.

[^11]: *See* Letter from John P. Janka, Counsel to Inmarsat, to Thomas
    S. Tycz, Chief, \[sic\] Satellite and Radiocommunication Division,
    International Bureau, FCC, dated April 23, 2002 (Inmarsat Letter).

[^12]: *See* Memorandum from Jim Vorhies, Acting Program Manager,
    Spectrum Plans, NTIA, to Sylvia Lam, Systems Analysis Branch,
    Satellite Division, International Bureau, FCC, dated Feb. 19, 2002
    (NTIA memorandum).

[^13]: *See AMSC Subsidiary Corporation,* 10 FCC Rcd 10458 (Int'l Bur.
    1995).

[^14]: *See In the Matter of Establishing Rules and Policies for the Use
    of Spectrum for Mobile Satellite Service in the Upper and Lower
    L-band,* Notice of Proposed Rulemaking, 11 FCC Rcd 11675 (1996)
    (*Lower L-band Notice).*

[^15]: *See AMSC Subsidiary Corporation,* 10 FCC Rcd 10458 (Int'l Bur.
    1995).

[^16]: *See In the Matter of Establishing Rules and Policies for the Use
    of Spectrum for Mobile Satellite Service in the Upper and Lower
    L-band,* Report and Order, 17 FCC Rcd 2704 (2002) (*Lower L-band
    Report and Order*).

[^17]: *See Amendment of Part 2 and 25 to Implement the Global Mobile
    Personal Communications by Satellite (GMPCS) Memorandum of
    Understanding and Arrangements; Petition of the National
    Telecommunications and Information Administration to Amend Part 25
    of the Commission's Rules to Establish Emissions Limits for Mobile
    and Portable Earth Stations Operating in the 1610-1660.5 MHz Band,*
    Report and Order and Further Notice of Proposed Rulemaking, FCC
    02-134 (rel. May 14, 2002).

[^18]: *See, e.g., SatCom Systems,* 14 FCC Rcd 20798 (1999), *aff'd sub
    nom. AMSC v. FCC,* 216 F.3d 1154 (D.C. Cir. 2000).

[^19]: *See* OuterLink Application Exhibit I.

[^20]: *See* Letter from Bruce A. Olcott, Counsel to OuterLink, to
    Thomas Tycz, Chief Satellite Division, International Bureau, FCC,
    dated April 3, 2002, citing a letter from Donald M. Kennedy,
    Director of International Regulatory Affairs, Inmarsat, to Thomas
    Tycz, Chief, Satellite and Radiocommunication Division,
    International Bureau, FCC, dated Dec. 19, 2000.

[^21]: *See* Inmarsat Letter, *supra.*

[^22]: *Id.*

[^23]: *See* Letter from Bruce A. Olcott, Counsel to OuterLink, to
    Thomas Tycz, Chief Satellite Division, International Bureau, FCC,
    dated April 3, 2002.

[^24]: *See* Letter from John P. Janka, Counsel to Inmarsat, to Thomas
    S. Tycz, Chief, \[sic\] Satellite and Radiocommunication Division,
    International Bureau, FCC, dated June 6, 2002.

[^25]: *Id.*

[^26]: 47 C.F.R. § 2.106