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Features of the original document layout such as columns, tables, line and letter spacing, pagination, and margins will not be preserved in the text version. If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. For the reasons discussed below, we deny OPM's Petition. At the time Highland Cellular bid in Auction 22, it held an attributable interest in 25 MHz of cellular spectrum that had significant overlap of the geographic area covering BTA35. In the OPM Order, we rejected OPM's claim that Highland Cellular was ineligible under the spectrum cap rule to bid on BTA35.