PUBLIC NOTICE![](media/image1.png){width="0.6541666666666667in"
height="0.6604166666666667in"}

FEDERAL COMMUNICATIONS COMMISSION

445 TWELFTH STREET, S.W.

WASHINGTON, D.C. 20554

News media information 202/418-0500 Fax-On-Demand 202/418-2830 Internet:
http://www.fcc.gov ftp.fcc.gov

DA 04-1873

Released: June 25, 2004

**COMSAT GENERAL CORPORATION, LOCKHEED MARTIN GLOBAL TELECOMMUNICATIONS
LLC, COMSAT NEW SERVICES, INC.,**

**INTELSAT LLC, AND INTELSAT MTC LLC,**

**SEEK FCC CONSENT TO ASSIGN LICENSES AND AUTHORIZATIONS**

**AND A DECLARATORY RULING ON FOREIGN OWNERSHIP**

**PLEADING CYCLE ESTABLISHED**

**IB Docket No. 04-235**

**Petitions Due: July 26, 2004**

**Oppositions Due: August 5, 2004**

**Replies Due: August 10, 2004**

I.  **introduction**

COMSAT General Corporation ("COMSAT General"), Lockheed Martin Global
Telecommunications, LLC ("LMGT"), and COMSAT New Services, Inc. ("CNSI")
(collectively, "COMSAT General Businesses" or "Assignors") and Intelsat
LLC and Intelsat MTC LLC (together, "Assignees," and collectively with
COMSAT General Business, the "Applicants") have filed a series of
applications pursuant to sections 214, 308, and 310(d) of the
Communications Act of 1934, as amended (the "Act")[^1] and a petition
for declaratory ruling under section 310(b)(4) of the Act.[^2] In the
applications, the Applicants seek Commission approval for assignment of
various licenses and authorizations from the COMSAT General Businesses
to Intelsat LLC and Intelsat MTC LLC, which result from an Asset
Purchase Agreement entered into by and among the Applicants. These
applications pertain to special temporary authority and licenses for
earth stations, a geostationary satellite space station, a private land
mobile radio license, and an international section 214 authorization.
Intelsat LLC and Intelsat MTC LLC also request a declaratory ruling that
their indirect foreign investment is consistent with the public
interest.

II. **THE PARTIES**

COMSAT General and LMGT are wholly-owned subsidiaries of Lockheed Martin
Corporation. CNSI is a wholly-owned subsidiary of COMSAT Corporation,
which is a wholly-owned subsidiary of LMGT.

The COMSAT General Businesses sell integrated service packages,
combining resale of satellite capacity with value-added services such as
bandwidth management and host nation agreement management. They purchase
satellite capacity from Intelsat and other satellite operators. Their
customers include commercial and government users.

Intelsat LLC and Intelsat MTC LLC are both indirect wholly-owned
subsidiaries of Intelsat (Bermuda), Ltd., which is in turn wholly-owned
by Intelsat, Ltd.

Intelsat is a global provider of satellite communications services,
supplying voice, video and data communications. It owns and operates a
global system that provides space segment capacity used for a wide array
of communications services, including voice, video, data, and Internet
connections. Intelsat's fleet of satellites offers service in more than
200 countries, serving customers that range from large
telecommunications carriers and broadcasters to corporate networks and
Internet service providers.

III. **Description of Transaction**

Intelsat LLC and Intelsat MTC LLC seek authority to acquire certain
assets from the COMSAT General Businesses pursuant to an Asset Purchase
Agreement entered into by the Applicants on May 11, 2004. Under the
proposed assignment, Intelsat LLC will purchase a private land mobile
radio license, a geostationary satellite space station license, and six
satellite earth station licenses. Intelsat MTC LLC will purchase
authorizations and licenses for earth stations and an international
section 214 authorization.

IV. **PUBLIC INTEREST SHOWING**

The Applicants state that the approval of the assignments will serve the
public interest. They state specifically that the proposed transaction
will enhance Intelsat's ability to provide end-to-end satellite
communications to its customers. According to the application,
incorporating the COMSAT General Businesses' assets, customer base and
expertise into Intelsat's businesses will allow them to offer their
customers a greater range of end-to-end solutions to meet their
international communications needs. In addition, the combination will
yield economies of scale and scope, enhancing Intelsat's ability to
provide quality innovative service. The Applicants further state that
because the proposed assignments will allow Intelsat to better provide
the end-to-end, integrated services that its rivals currently offer to
their customers, the assignments will further U.S. policy under the
ORBIT Act.[^3]

Applicants state that the proposed assignments will have no adverse
effect on competition. They state that Intelsat faces competition for
both commercial and government customers from a number of other global
providers of satellite capacity, and that there is strong competition in
the earth station market. The Applicants conclude that the proposed
assignments will not give Intelsat any power to foreclose or otherwise
harm the international telecommunications market.

V.  **PETITION FOR DECLATORY RULING UNDER SECTION 310(b)(4)**

The Assignees request a declaratory ruling that their indirect foreign
investment is consistent with the public interest standard under section
310(b)(4) of the Act[^4]

(File Number ISP-PDR-20040528-00005). Intelsat LLC and Intelsat MTC LLC
are both indirect wholly-owned subsidiaries of Intelsat (Bermuda), Ltd.,
and in turn Intelsat, Ltd., both of which are incorporated under the
laws of Bermuda. Bermuda is a World Trade Organization ("WTO") member
country.

In 2000, the Commission reviewed and approved the indirect foreign
ownership of Intelsat LLC, in the *Intelsat LLC Licensing Order.*[^5]
The Commission has also approved indirect foreign ownership in other
Intelsat subsidiaries on several occasions. Most recently, the
International Bureau granted Intelsat North America, LLC, a wholly-owned
subsidiary of Intelsat LLC, a section 310(b)(4) ruling.[^6]

According to the petition, Intelsat MTC LLC was specifically created for
the purpose of holding various assets, licenses, and authorizations to
be acquired through the proposed assignments. The Assignees state that
there have been no significant changes to the foreign ownership of
Intelsat, Ltd. since the *Intelsat/Loral Order*. They state that
Lockheed Martin Corporation, a U.S. company, is Intelsat's largest
minority shareholder with more than 20 percent of the total Intelsat,
Ltd. shares. The remaining ownership interests in Intelsat, Ltd. remain
widely dispersed among more than 220 entities, representing more than
145 nations. They further state that entities from WTO member countries
hold approximately 94 percent of Intelsat shares, and that indirect
foreign government ownership is approximately 30 percent.

VI. **SECTION 310 APPLICATIONS**

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A.  **Part 25 -- Satellite Communications**

The following file numbers have been assigned to the earth and space
station applications:

  ----------------------- ---------------------------- ---------------------------- ---------------------
  **[File                 **[Assignor]{.underline}**   **[Assignee]{.underline}**   **[Call
  Number]{.underline}**                                                             Sign]{.underline}**

  ----------------------- ---------------------------- ---------------------------- ---------------------

+---------------------+--------------------+---------------+----------+
| SES                 | Lockheed Martin    | Intelsat MTC  | E960186  |
| -ASG-20040528-00744 | Global             | LLC           |          |
|                     | T                  |               | E960187  |
|                     | elecommunications, |               |          |
|                     | LLC                |               |          |
+---------------------+--------------------+---------------+----------+
|                     |                    |               |          |
+---------------------+--------------------+---------------+----------+
| SES                 | Comsat General     | Intelsat LLC  | E970053  |
| -ASG-20040528-00750 | Corp.              |               |          |
+---------------------+--------------------+---------------+----------+
|                     |                    |               |          |
+---------------------+--------------------+---------------+----------+
| SES                 | Comsat General     | Intelsat LLC  | E980015  |
| -ASG-20040528-00751 | Corp.              |               |          |
|                     |                    |               | E980016  |
|                     |                    |               |          |
|                     |                    |               | E980019  |
|                     |                    |               |          |
|                     |                    |               | E980217  |
|                     |                    |               |          |
|                     |                    |               | E990303  |
+---------------------+--------------------+---------------+----------+
|                     |                    |               |          |
+---------------------+--------------------+---------------+----------+
| SAT                 | Comsat General     | Intelsat LLC  | MARISAT  |
| -ASG-20040528-00109 | Corp               |               | F2       |
+---------------------+--------------------+---------------+----------+

B.  **Part 90 \--Private Land Mobile License**

The following file number has been assigned to the Private Land Mobile
Radio Service assignment application:

**.**

  ----------------------- ---------------------------- ---------------------------- ---------------------
  **[File                 **[Assignor]{.underline}**   **[Assignee]{.underline}**   **[Call
  Number]{.underline}**                                                             Sign]{.underline}**

  ----------------------- ---------------------------- ---------------------------- ---------------------

  --------------------- --------------------- --------------- -----------
  0001743676            COMSAT General        Intelsat LLC    WPYJ473
                        Corporation                           

  --------------------- --------------------- --------------- -----------

**V. INTERNATIONAL Section 214 Authorization**

The following file number has been assigned to the international section
214 authorization application:

  ----------------------- ---------------------------- ---------------------------- -----------------------
  **[File                 **[Assignor]{.underline}**   **[Assignee]{.underline}**   **[Authorization
  Number]{.underline}**                                                             Number]{.underline}**

  ----------------------- ---------------------------- ---------------------------- -----------------------

  ------------------------ --------------------- ------------ ------------------------
  ITC-ASG-20040528-00235   Lockheed Martin       Intelsat MTC ITC-214-19961230-00657
                           Global                LLC          
                           Telecommunications,                
                           LLC                                

  ------------------------ --------------------- ------------ ------------------------

**VI. GENERAL INFORMATION**

The assignment applications filed by the Applicant have 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 these applications will
not be taken earlier than thirty-one days following the date of this
Public Notice.[^7]

Interested parties must file petitions to deny no later than **July 26,
2004**. Oppositions to such pleadings must be filed no later than
**August 5, 2004**. Replies to such pleadings must be filed no later
than **August 10, 2004**. All filings concerning matters referenced in
this Public Notice should refer to **IB Docket No. 04-235**, as well as
the specific file numbers of the individual applications or other
matters to which the filings pertain.

Under the Commission's current procedures for the submission of filings
and other documents,[^8] submissions in this matter may be filed
electronically (*i.e.*, though ECFS) or by hand delivery to the
Commission's Massachusetts Avenue location.

-   **If filed by ECFS**,[^9] comments shall be sent as an electronic
    file via the Internet to http://www.fcc.gov/e-file/ecfs.html. In
    completing the transmittal screen, commenters should include their
    full name, Postal Service mailing address, and the applicable docket
    number. Parties may also submit an electronic comment by Internet
    e-mail. To get filing instructions for e-mail comments, commenters
    should send an e-mail to ecfs@fcc.gov, and should include the
    following words in the body of the message, "get form \<your e-mail
    address\>." A sample form and directions will be sent in reply.

-   **If filed by paper**, the original and four copies of each filing
    must be filed 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). The Commission\'s contractor, Natek, Inc., 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 mail, Express Mail, and Priority Mail should be
    addressed to 445 12th Street, S.W., Washington, D.C. 20554. All
    filings must be addressed to the Commission\'s Secretary, Office of
    the Secretary, Federal Communications Commission.

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:

(1) the Commission\'s duplicating contractor, Best Copy and Printing,
Inc., at <fcc@bcpiweb.com> or (202) 488-5563 (facsimile);

(2) JoAnn Lucanik, Satellite Division, International Bureau, at
JoAnn.Lucanik@fcc.gov, or (202) 418-0748 (facsimile);

(3)  Jeanette Spriggs, Satellite Division, International Bureau, at
Jeanette.Spriggs@fcc.gov, or (202) 418-0748 (facsimile);

(4)  Kathleen Campbell, Satellite Division, International Bureau, at
Kathleen.Campbell@fcc.gov, or (202) 418-0748 (facsimile);

\(5\) David Krech, Policy Division, International Bureau, at
David.Krech@fcc.gov or (202) 418-1460 (facsimile);

\(6\) Jennifer Gorny, Policy Division, International Bureau, at
Jennifer.Gorny@fcc.gov or (202) 418-1460 (facsimile);

(7) Jeff Tobias, Public Safety and Critical Infrastructure Division,
Wireless Telecommunications Bureau, at Jeff.Tobias@fcc.gov, or (202)
418-2643 (facsimile); and,

(8) Neil Dellar, Transaction, Team, 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 are also available electronically through
the Commission's ECFS, which may be accessed on the Commission's
Internet website at http://www.fcc.gov. Alternate formats of this public
notice (computer diskette, large print, audio recording, and Braille)
are available to persons with disabilities by contacting Brian Millin at
(202) 418-7426 (voice), (202) 418-7365 (TTY), or send an e-mail to
access@fcc.gov.

For further information, contact JoAnn Lucanik, Satellite Division,
International Bureau, at (202) 418-0719 or David Krech, Policy Division,
International Bureau, at (202) 418-1460.

**-FCC-**

[^1]: 47 U.S.C. §§ 214, 308, 310(d).

[^2]: 47 U.S.C. § 310(b)(4).

[^3]: Open-Market Reorganization Act for the Betterment of International
    Telecommunications Act, Pub. L. No. 106-180, 114 Stat. 48 (*Orbit
    Act*).

[^4]: 47 U.S.C. § 310(b)(4).

[^5]: *Applications of Intelsat LLC for Authority to Operate, and to
    Further Construct, Launch, and Operate C-band and Ku-band Satellites
    that Form a Global Communications System in Geostationary Orbit*,
    Memorandum Opinion and Order, 15 FCC Rcd 15460, 15483, paras. 44-55
    (*Intelsat LLC Licensing Order*).

[^6]: *Loral Satellite, Inc. (Debtor-in-Possession) and Loral SpaceCom
    Corporation (Debtor-in-Possession), Assignors and Intelsat North
    America, LLC, Assignee, Applications for Consent to Assignments of
    Space Station Authorizations and Petition for Declaratory Ruling
    Under Section 310(b)(4) of the Communications Act of 1934, as
    Amended*, Order and Authorization, 19 FCC Rcd 2404, 2415 (IB 2004)
    (*Intelsat/Loral Order*).

[^7]: *See* 47 U.S.C. § 309(b).

[^8]: *See* Implementation of Interim Electronic Filing Procedures for
    Certain Commission Filings, *Order*, 16 FCC Rcd. 21,483 (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. 22,165 (2001); Reminder: Filing Locations for Paper Documents
    and Instructions for Mailing Electronic Media, *Public Notice*, 18
    FCC Rcd. 16,705 (2003).

[^9]: *See* Electronic Filing of Documents in Rulemaking Proceedings, GC
    Docket No. 97-113, *Report and Order*, 13 FCC Rcd. 11,322 (1998).