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	<title>Comments on: Extend and pretend&#8230;</title>
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	<link>https://tmfassociates.com/blog/2012/03/15/extend-and-pretend/</link>
	<description>Satellites, spectrum and other stuff</description>
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		<title>By: TMF Associates MSS blog &#187; Is the FCC&#8217;s NPRM designed to fail?</title>
		<link>https://tmfassociates.com/blog/2012/03/15/extend-and-pretend/comment-page-1/#comment-845</link>
		<dc:creator>TMF Associates MSS blog &#187; Is the FCC&#8217;s NPRM designed to fail?</dc:creator>
		<pubDate>Wed, 21 Mar 2012 21:54:19 +0000</pubDate>
		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=3224#comment-845</guid>
		<description>[...] avoid the looming financial crunch at the end of the second quarter of 2012, when LightSquared must repay a roughly $300M loan to its [...]</description>
		<content:encoded><![CDATA[<p>[...] avoid the looming financial crunch at the end of the second quarter of 2012, when LightSquared must repay a roughly $300M loan to its [...]</p>
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		<title>By: timfarrar</title>
		<link>https://tmfassociates.com/blog/2012/03/15/extend-and-pretend/comment-page-1/#comment-844</link>
		<dc:creator>timfarrar</dc:creator>
		<pubDate>Sat, 17 Mar 2012 14:58:38 +0000</pubDate>
		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=3224#comment-844</guid>
		<description>I don&#039;t think a spectrum swap is a realistic option, not least because otherwise LS would have couched their &quot;demand&quot; differently. Also the DoD is not going to do anything (in terms of a swap) to keep LS alive, and the White House want this to go away before the election. The best way to do that is for the FCC to have the International Bureau rule as per the Public Notice and then LS have to submit a Petition for Reconsideration to the full Commission, and have it ruled on, before they can file suit in Federal court. There is no deadline for the FCC to act on this Petition so this would certainly stymie LightSquared&#039;s legal threats against the government until the end of the year.

With respect to the situation after termination of the Cooperation Agreement (prior to completion of the Phase 1A payments) it remains uncertain whether the allocations would go back to the situation before the whole rebanding started, or whether LS would have some added spectrum contiguity compared to what they did before. However, it is clear that LS have to give up some amount of spectrum to Inmarsat in a default situation, which could further impair any possible contiguity in the lower L-band. LS are all but certain to commence legal action against Inmarsat, once Inmarsat terminate the Cooperation Agreement for default in April.</description>
		<content:encoded><![CDATA[<p>I don&#8217;t think a spectrum swap is a realistic option, not least because otherwise LS would have couched their &#8220;demand&#8221; differently. Also the DoD is not going to do anything (in terms of a swap) to keep LS alive, and the White House want this to go away before the election. The best way to do that is for the FCC to have the International Bureau rule as per the Public Notice and then LS have to submit a Petition for Reconsideration to the full Commission, and have it ruled on, before they can file suit in Federal court. There is no deadline for the FCC to act on this Petition so this would certainly stymie LightSquared&#8217;s legal threats against the government until the end of the year.</p>
<p>With respect to the situation after termination of the Cooperation Agreement (prior to completion of the Phase 1A payments) it remains uncertain whether the allocations would go back to the situation before the whole rebanding started, or whether LS would have some added spectrum contiguity compared to what they did before. However, it is clear that LS have to give up some amount of spectrum to Inmarsat in a default situation, which could further impair any possible contiguity in the lower L-band. LS are all but certain to commence legal action against Inmarsat, once Inmarsat terminate the Cooperation Agreement for default in April.</p>
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		<title>By: Argo4288</title>
		<link>https://tmfassociates.com/blog/2012/03/15/extend-and-pretend/comment-page-1/#comment-843</link>
		<dc:creator>Argo4288</dc:creator>
		<pubDate>Sat, 17 Mar 2012 13:39:58 +0000</pubDate>
		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=3224#comment-843</guid>
		<description>I think the effect of end of the Cooperation Agreement has been underestimated.  The end of the agreement will certainly end LightSquared&#039;s ability to offer terrestrial service, but I think it also depresses the value of their spectrum going forward and certainly makes their spectrum less attractive for a possible spectrum swap.

Prior to the Cooperation Agreement, the L band spectrum was composed of numerous small slices of spectrum interwoven.  There were no large contiguous blocks of spectrum.  I am quite certain that LightSquared only owned portions of the 2x10 MHz blocks in the lower L band.

Any further thoughts on this?</description>
		<content:encoded><![CDATA[<p>I think the effect of end of the Cooperation Agreement has been underestimated.  The end of the agreement will certainly end LightSquared&#8217;s ability to offer terrestrial service, but I think it also depresses the value of their spectrum going forward and certainly makes their spectrum less attractive for a possible spectrum swap.</p>
<p>Prior to the Cooperation Agreement, the L band spectrum was composed of numerous small slices of spectrum interwoven.  There were no large contiguous blocks of spectrum.  I am quite certain that LightSquared only owned portions of the 2&#215;10 MHz blocks in the lower L band.</p>
<p>Any further thoughts on this?</p>
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