Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of ) ) Space Exploration Holdings, LLC ) RM-11855 ) Petition for Revision of ) Section 25.261 of the Commission’s Rules )

REPLY COMMENTS OF O3B LIMITED

Of Counsel: Suzanne Malloy Karis Hastings Vice President of Regulatory Affairs SatCom Law LLC O3b Limited 1317 F Street, NW, Suite 400 1129 20th Street, NW, Suite 1000 Washington, DC 20004 Washington, DC 20036 (202) 599-0975 (202) 813-4026

June 30, 2020

SUMMARY

O3b’s pioneering position in building a network that provides capable, reliable connectivity to customers around the globe showcases the success of Commission policies for non-geostationary orbit (“NGSO”) systems and underscores the importance of continuing to adapt the NGSO regulatory framework to support the industry’s evolution and growth. In 2014,

O3b began offering service to customers in the United States and worldwide with its Ka-band

NGSO system. O3b is continuing to connect historically under- and unconnected populations with the next-generation mPOWER system of high-throughput, low-latency satellites, and is seeking authority to further expand its system to add satellites and capabilities.

Given the exponential growth in NGSO system interest in the years since O3b’s operations commenced, O3b agrees that the time is ripe for the Commission to begin a rulemaking to define spectrum sharing rights between NGSO systems authorized in different processing rounds, according superior rights to earlier round systems while providing opportunities for new entrants and system expansion. O3b has developed a comprehensive framework that builds on the existing Commission rules to achieve these goals. In contrast, the sharing proposal put forward by SpaceX is incomplete and would discourage coordination between parties. Suggestions by other parties for merging processing rounds or relying on ITU priority to determine relative spectrum rights fundamentally conflict with established

Commission policies and must also be rejected.

The plain language of Section 25.261(c)(1) allowing choice of “home spectrum” based on network deployment order should remain unchanged. The rule accomplishes its intended purpose, encouraging prompt deployment and protecting service continuity, and changing the standard now would undermine the certainty on which operators and investors have relied. The

i record conclusively shows that the purported “spectrum efficiency” metric SpaceX advocates is blatantly self-serving, would impede sharing, and would require the Commission to commit resources to refereeing disputes.

Finally, the Commission should refrain from dictating that NGSO systems share beam pointing information. Such a mandate would raise significant confidentiality concerns and is simply infeasible given the dynamic NGSO operating environment.

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TABLE OF CONTENTS

SUMMARY ...... i I. O3B’S SHARING APPROACH FOR SYSTEMS FROM DIFFERENT PROCESSING ROUNDS BEST PROMOTES THE PUBLIC INTEREST ...... 2 A. The O3b Default Spectrum Sharing Proposal Provides Regulatory Certainty and Supports New Entry ...... 2 B. The SpaceX Sharing Proposal and Alternatives Suggested by Other Parties Are Fundamentally Flawed ...... 5 II. THE COMMISSION SHOULD RETAIN ITS HOME SPECTRUM PROVISION, WHICH ENCOURAGES PROMPT SERVICE TO CUSTOMERS ...... 8 III. THE RECORD CONFIRMS THAT REQUIRING SYSTEMS TO SHARE BEAM POINTING INFORMATION IS INFEASIBLE AND UNNECESSARY...... 11 IV. CONCLUSION ...... 13

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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of ) ) Space Exploration Holdings, LLC ) RM-11855 ) Petition for Revision of ) Section 25.261 of the Commission’s Rules )

REPLY OF O3B LIMITED O3b Limited (“O3b”) submits this reply to the comments of other parties regarding the above-captioned petition for rulemaking filed by Space Exploration Holdings, LLC (“SpaceX”) proposing new and revised regulatory provisions to address spectrum sharing among non- geostationary orbit (“NGSO”) fixed-satellite service (“FSS”) systems.1 O3b agrees that the

Commission should commence a rulemaking exploring NGSO sharing issues, but neither the

SpaceX proposals nor alternatives offered by commenters would achieve Commission objectives. In order to incentivize coordination, provide certainty to support investment, promote competition, and reward the delivery of service to customers, the Commission should use the approach outlined by O3b as the basis for a sharing structure that would foster the Commission’s public interest goals. The Commission should also reject changes to its home spectrum selection policy and decline to mandate that NGSO systems share beam location information.

1 Space Exploration Holdings, LLC, Petition for Revision of Section 25.261 of the Commission’s Rules to Increase Certainty in Spectrum Sharing Obligations Among Non-Geostationary Orbit Fixed-Satellite Service Systems, RM-11855, filed Apr. 30, 2020 (the “SpaceX Petition”).

I. O3B’S SHARING APPROACH FOR SYSTEMS FROM DIFFERENT PROCESSING ROUNDS BEST PROMOTES THE PUBLIC INTEREST

The record reflects broad agreement regarding the pro-consumer principles that should drive development of a default spectrum sharing regime, and the regulatory adjustments proposed by O3b are tailored to advance those principles. Accordingly, the Commission should use the O3b approach as the basis for its rulemaking proposals and dismiss requests by SpaceX and others for rule changes that would disincentivize coordination and hamper competition.

A. The O3b Default Spectrum Sharing Proposal Provides Regulatory Certainty and Supports New Entry

O3b’s sharing proposal, which builds on existing standards, encourages all parties to work together to reach coordination agreements, and provides stability for early round systems, is uniquely suited to further the Commission’s policy objectives.2 The Commission’s 2017 decision adopting the current regulatory framework emphasized that “coordination among

NGSO FSS operators in the first instance offers the best opportunity for efficient spectrum sharing.” 3 In the event no coordination between two systems is in place, the Commission specified that the operators must split the spectrum when the increase in the relevant system’s noise temperature, ΔT/T, exceeds six percent.4 The Commission determined that this six percent

ΔT/T metric, which is used internationally to determine when coordination is required among geostationary orbit satellites, “is the best method for characterizing the situations in which there

2 See Comments of O3b Limited, RM-11855, filed June 15, 2020 (“O3b Comments”) at 2 n.4. Unless otherwise indicated, all citations herein are to comments filed in RM-11855 on June 15, 2020. 3 Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related Matters, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 7809 (2017) (“NGSO Order”) at 7825, ¶ 48. 4 Id., ¶ 49. 2 is potential for interference between NGSO FSS systems.”5 The Commission made clear that this sharing methodology was limited to systems authorized in the same round and expressly rejected proposals to use ITU date priority to determine spectrum access rights.6

The O3b sharing approach is a natural evolution of this current structure, using the same six percent ΔT/T band-splitting trigger but adding a provision for situations involving systems authorized in different processing rounds.7 Specifically, O3b proposes using a multiplier of three to assign a greater share of the spectrum to earlier round systems than to later round systems in a band-splitting scenario.

This multiplier achieves the balance the Commission described in the NGSO Order, by recognizing “both the need to protect existing expectations and investments and provide for additional entry.”8 By awarding a larger share of spectrum to earlier applicants, O3b’s proposed rule promotes the goal of the processing round regime: providing “a measure of certainty” for early round systems “in lieu of adopting an open-ended requirement to accommodate all future applicants.”9 As commenters emphasize, this guarantee of defined protection against later filings is an essential element of the processing round framework.10

5 Id. 6 Id., ¶ 50. 7 O3b Comments at 8-9. 8 NGSO Order, 32 FCC Rcd at 7825, ¶ 50. 9 Id. at 7829, ¶ 61. 10 See Comments of Telesat Canada (“Telesat Comments”) at 5 (“Processing rounds would be meaningless if they did not afford protection against harmful interference from those participating in later rounds.”); Comments of Kepler Communications, Inc. (“Kepler Comments”) at 7 (“Of course, the very nature of the processing round framework implies a guarantee of some level of protection for members of an earlier processing round from those of a later.”). 3

Critically, however, the approach also continues to incentivize good-faith coordination, which parties recognize represents the best means of sharing spectrum.11 As Karousel explains:

Because the stakes of spectrum-splitting are so high, section 25.261 establishes strong incentives for operators whose systems may experience in-line events to reach privately negotiated coordination agreements. Informed, system-specific agreements can almost always improve on the draconian result that the default spectrum-splitting rule would otherwise impose.12

Amazon complains that the six percent ΔT/T threshold for spectrum splitting is too conservative but does not suggest – much less justify – an alternative value.13 Moreover,

Amazon ignores the substantial benefit of employing a strict limit as a trigger for band splitting: it motivates operators to pursue and complete coordination. Coordinating parties are free to choose and apply any mutually agreeable standard for unacceptable interference and may select one that is considerably more relaxed than the six percent ΔT/T trigger specified in

Section 25.261 if it meets their operational requirements.14 As a result, the Commission’s use of a more conservative standard does not constrain discussions between operators, it simply encourages them to come to the negotiating table and coordinate in good faith.

11 See, e.g., SpaceX Petition at 10 (“Because operators themselves are best positioned to understand the capabilities of their systems and business objectives, successful coordination ensures the most efficient use of shared spectrum.”); Comments of ViaSat, Inc. (“ViaSat Comments”) at 8 (“mutual cooperation among NGSO FSS operators offers the best opportunity for efficient spectrum sharing”). 12 Comments of Karousel, LLC (“Karousel Comments”) at 3. 13 Comments of Kuiper Systems LLC (“Amazon Comments”) at 6 & Annex. 14 For example, parties to a coordination negotiation may want to incorporate relevant ITU standards, such as Recommendation ITU-R S.2131 mentioned by Viasat, or options referenced by AST, Recommendation ITU‐R S.1323‐2 and RR No. 22.5L. See Comments of Viasat, Inc. (“Viasat Comments”) at 4; Comments of AST&Science LLC (“AST Comments”) at 4. SES agrees that these documents may serve as valuable resources in considering system-specific effects on spectrum efficiency and signal availability but notes that none represents a comprehensive substitute for the Commission’s six percent ΔT/T trigger. 4

O3b’s goal is to never be in a position where it must relinquish any portion of the spectrum in use by its system, and the O3b proposed framework is designed to harness the desire to avoid band-splitting in order to drive coordination. Thus, the O3b framework protects investments and expectations while promoting coordination among operators.

B. The SpaceX Sharing Proposal and Alternatives Suggested by Other Parties Are Fundamentally Flawed

Neither the original SpaceX plan for systems from different processing rounds to share spectrum nor other approaches put forth by commenters would achieve the benefits of O3b’s proposal. As the O3b Comments explain, SpaceX advocates implementation of a standard interference-to-noise (“I/N”) level for a new entrant to be “deemed coordinated” with an authorized system, but fails to specify what that level would be or to explain what happens if the new system cannot demonstrate compliance with the limit, rendering the proposal incomplete.15

More significantly, by allowing a new entrant to be “deemed coordinated” with legacy systems based on a unilateral I/N showing,16 the SpaceX approach would deter, not encourage, coordination.17

Amazon’s suggestion that the Commission should merge processing rounds and implement lopsided protection obligations18 directly conflicts with established Commission policies. O3b and others have already conclusively rebutted Amazon’s claims that despite applying almost three years after the first Ku/Ka-band processing round window closed it should

15 O3b Comments at 9-10; see also Viasat Comments at 3-4 (the I/N standard suggested by SpaceX is “difficult to address because it is a vague concept, and not a fully-formed proposal”). 16 SpaceX Petition at Exhibit A. 17 See O3b Comments at 9-10. 18 Amazon Comments at ii, 7-9. 5 be granted equal status to timely applicants,19 and the Commission has rightfully responded by indicating that the Amazon application will be considered as part of the second round.20

Amazon’s processing round merger proposal is an obvious effort to resurrect its prior failed arguments and should similarly be rejected.

For example, O3b has previously demonstrated that Amazon’s assertion that the departure of first-round NGSO applicants LeoSat and Boeing effectively “makes room” for new entrants is fallacious.21 And Amazon itself recognizes that combining rounds is not an option if the number of active systems previously authorized makes it infeasible to accommodate additional entrants on a coequal basis.22 Yet Amazon does not consider that this is already the case given the substantial number of first-round systems deploying spacecraft and the thousands of additional satellites that are being requested in the second round.

Amazon also continues to ignore the Commission’s clear statement that the purpose of processing rounds is “ to establish a sharing environment among NGSO systems, to provide a measure of certainty in lieu of adopting an open-ended requirement to accommodate all future applicants.”23 By depriving earlier round applicants of this certainty, Amazon’s processing round

19 See, e.g., Reply of SES Americom, Inc. and O3b Limited, File No. SAT-LOA-20190704- 00057, filed Nov. 25, 2019 (“SES Reply”) at 4-14. See also Reply of Space Exploration Holdings, LLC, File No. SAT-LOA-20190704-00057, filed Nov. 25, 2019 (“SpaceX Reply”), at 12-21; Telesat Canada Petition to Dismiss Without Prejudice or Hold in Abeyance, File No. SAT-LOA-20190704-00057, filed Oct. 28, 2019, at 2-6; WorldVu Satellites Limited Ex Parte Notice, File No. SAT-LOA-20190704-00057, filed Jan. 24, 2020, at 3-4. 20 See Cut-Off Established for Additional NGSO FSS Applications or Petitions for Operations in the 10.7-12.7 GHz, 12.75-13.25 GHz, 13.8-14.5 GHz, 17.7-18.6 GHz, 18.8-20.2 GHz, and 27.5- 30 GHz Bands, Public Notice, DA 20-325 (Mar. 24, 2020) at 1-2. 21 See SES Reply at 6-8; SpaceX Reply at 3-10. 22 Amazon Comments at 8. 23 NGSO Order, 32 FCC Rcd at 7829, ¶ 61. 6 merger approach would directly conflict with this explicit policy, devaluing the investment of parties like O3b that have built facilities and developed business plans in reliance on a stable interference environment.

Amazon’s proposal that early round applicants seeking to expand their systems in later processing rounds should be burdened with greater sharing obligations vis-à-vis operators in later processing rounds24 is similarly self-serving and at odds with Commission objectives. Amazon entirely fails to explain why established systems that have already deployed and are providing service should be constrained in their ability to evolve and expand their constellations in successive processing rounds.

Finally, the Commission must reject OneWeb’s proposal that spectrum sharing rights be defined solely based on ITU filing priority.25 The NGSO Order explicitly determined that such an approach would violate Commission principles because it give a single “winner” operational certainty “in wide swaths of spectrum without offering any certainty to a multitude of other proposals in the same bands.”26 The adverse effects of such a regime identified by the

Commission include delaying service to customers, unduly chilling investment by operators seeking to compete with the ITU priority holder, and undermining incentives for the system with priority to accommodate other operators.27 OneWeb provides no reason for the Commission to revisit its prior conclusion that using ITU priority to determine sharing rights would be contrary to the public interest.

24 Amazon Comments at 9. 25 See Opposition of OneWeb (“OneWeb Opposition”) at 1-2. 26 NGSO Order, 32 FCC Rcd at 7825, ¶ 50. 27 Id. 7

II. THE COMMISSION SHOULD RETAIN ITS HOME SPECTRUM PROVISION, WHICH ENCOURAGES PROMPT SERVICE TO CUSTOMERS

The record before the Commission demonstrates that the current language of

Section 25.261(c)(1), which awards the right to select home spectrum during a band-splitting event to the first system to launch a satellite and commence service, continues to further critical public interest goals by incentivizing timely system deployment and preserving service continuity. The Commission should reject proposals to rewrite the rule that would thwart these key policy rationales and destroy the regulatory certainty on which parties have relied.

O3b’s history of initiating service to the United States and around the globe in 2014, years before any of the current set of Ka-band NGSO FSS applications had even been filed, provides a concrete demonstration that the existing home spectrum selection provision has accomplished precisely what it was designed to do − encourage speedy delivery of service to customers. A number of commenters agree that by basing frequency selection rights on launch order, the current rule effectively advances Commission policies in favor of competition, spectrum efficiency, and expedited initiation of service to users.28 Changing the rule now would disrupt the expectations of O3b and others. In fact, revising the regulatory framework retroactively could trigger fundamental due process concerns.29

Challenges by some commenters to the Commission’s longstanding and effective policy simply ignore relevant precedent. For example, Amazon’s suggestions that parties could attempt to game the existing framework30 are wholly speculative, and the Commission has already

28 See Telesat Comments at 15; Comments of Kepler Communications Inc. (“Kepler Comments”) at 6; OneWeb Opposition at 6. 29 See Opposition of Theia Holdings A, Inc. (“Theia Opposition”) at 5-6 & n.16. 30 Amazon Comments at 9. 8 considered and rejected arguments that the mere possibility that systems could attempt to manipulate the provision justifies modifying the first-to-launch rule.31

Numerous parties echo O3b’s objections to the SpaceX proposal to replace the current text of Section 25.261(c)(1) with a purported efficiency standard for assigning home spectrum selection rights,32 noting that the SpaceX approach has nothing to do with efficiency, and instead appears to be tailored to confer preferential benefits on SpaceX. Commenters observe that the

SpaceX proposal, which rewards operators that employ large numbers of satellites at low altitudes, is blatantly self-serving and conflicts with the Commission’s policy of not favoring one system design over another.33 As a result, the approach would allow SpaceX to unfairly leapfrog operators who initiated service well before SpaceX.34 And contrary to what SpaceX alleges, its approach would impede, rather than promote, equitable sharing among NGSO operators by conferring benefits on systems whose designs have a preclusive effect on other spectrum users.35

31 Establishment of Policies and Service Rules for the Mobile Satellite Service in the 2 GHz Band, 15 FCC Rcd 16127 (2000) at 16143, ¶ 29. 32 See O3b Comments at 13-16. 33 See, e.g., Karousel Comments at 7 (SpaceX’s suggested “spectral throughput density” metric “appears to be intended to give SpaceX an unfair advantage,” as it “heavily favors operators, such as SpaceX, that have requested the most bandwidth and are operating at low orbital altitudes”); Viasat Comments at 6 (SpaceX’s approach would “reward the applicant who files for the largest number of satellites when there is no public interest in simply having more satellites”); Kepler Comments at 2 (SpaceX’s suggestions on the home spectrum would give SpaceX an “advantage in the determination of selection order, both now and in future processing rounds”); Theia Opposition at 1 (SpaceX’s proposal “is a transparent attempt to establish preferential treatment for its own satellite system” and “unfairly penalizes operators who use less spectrum, operate smaller constellations, and provide services not focused on consumer broadband”). 34 O3b Comments at 16; Telesat Comments at 3, 15-16. 35 O3b Comments at 14-15; Viasat Comments at 7. 9

SpaceX also ignores the fact that there is no accepted Commission standard for spectrum efficiency – the Commission has expressly concluded that defining a single, objective metric is neither possible nor appropriate.36 Nor would the SpaceX proposal for awarding home spectrum selection rights provide any semblance of regulatory certainty, as SpaceX itself admits that the

Commission would likely be called on to referee disputes.37

Alternative methods of selecting home spectrum put forth by other parties are similarly flawed, as they are unworkable and would imperil service continuity. Viasat contends that home spectrum should be randomly assigned each time band splitting is required,38 and Amazon proposes that during a band-splitting event, the operator causing the lower ΔT/T should select their spectrum first.39 Both these parties also claim that the Commission should retroactively limit the ability of operators to select unencumbered band segments as home spectrum.40

As a threshold matter, these approaches would remove the incentive provided by the current rule to quickly deploy service to users and deprive operators such as O3b who invested in early build-out of the benefits of their pioneering efforts. If home spectrum were assigned randomly, operators with established customer operations would in fact be unduly harmed, as

36 See, e.g., Amazon Comments at 10 & n. 27, citing Federal Communications Commission Spectrum Policy Task Force, Report of the Spectrum Efficiency Working Group (rel. Nov. 15, 2002) at 9. 37 SpaceX Petition at 14-15; see also Karousel Comments at 7 (adopting the SpaceX proposal would require the Commission to “resolve an increasing number of conflicts through a review of operators’ records”). 38 ViaSat Comments at 8. See also Karousel Comments at 7 (proposing that systems be allowed to choose their home spectrum but that conflicts be resolved by random assignment). 39 Amazon Comments at 11. 40 See id. at 12; Viasat Comments at 7. 10 they would have no predictable, consistent access to frequencies for use to maintain service during a band-splitting event.

Relying on a ΔT/T standard as Amazon proposes is also highly problematic. Determining which party is generating a lower ΔT/T in a given instance is administratively challenging and subject to manipulation, as operators could contrive to create artificially low interference levels in an attempt to claim first choice of home spectrum.

Thus, no party has presented a valid rationale for the Commission to abandon the proven public interest benefits of the existing first-to-launch home spectrum selection rule. The

Commission should reject the self-serving SpaceX proposal as well as the Viasat and Amazon alternatives and retain its current policy that rewards expedited service to customers.

III. THE RECORD CONFIRMS THAT REQUIRING SYSTEMS TO SHARE BEAM POINTING INFORMATION IS INFEASIBLE AND UNNECESSARY

Lastly, the Commission should reject suggestions by SpaceX and Amazon that operators be required to exchange detailed beam pointing information.41 As the O3b Comments explain, a

Commission mandate to share beam pointing information would be infeasible, negatively impact service, and implicate significant confidentiality concerns.42

Amazon’s assertion that the Commission should compel “continuous information sharing” between systems “sufficiently far in advance” to enable operators to coordinate43 is unrealistic on its face. Each of O3b’s initial tranche of seven mPOWER satellites will be capable of generating 4,000 electronically steered beams to allow dynamic response to customer

41 SpaceX Petition at 1-2, 12; Amazon Comments at i, 5-6. 42 O3b Comments at 17-18. 43 Amazon Comments at i, 6. 11 demand,44 for a total of 28,000 beams. O3b’s global resource manager, which is tasked with assigning capacity in real time to satisfy customer requirements, simply cannot perform that function effectively while simultaneously supplying second-by-second positioning information on all of these beams to third parties, and providing the information “sufficiently far in advance” to allow reaction by another system is out of the question. Importantly, this issue is not unique to

O3b – operators of other systems that rely on dynamic capacity assignment will face the same practical obstacle.45

Even if it were possible, complying with a mandate to share beam pointing information would constrain service to customers and reduce spectral efficiency. The proposed sharing requirements represent a static exchange of information, incompatible with the flexibility that is integral to many NGSO services.46 Operators must be able to repoint beams quickly to meet changing customer needs.47 Beam reassignment is also used to improve spectral efficiency, and delaying beam switching while static information is traded will result in wasted capacity.48

Requiring that real-time beam locations be disclosed would also raise confidentiality concerns. As Viasat observes, beam pointing information reveals “propriety traffic trends that otherwise would not be shared with competitors, and that present security implications with respect to how government customers are utilizing the system.”49 Indeed some O3b government

44 O3b Comments at 17. 45 See OneWeb Opposition at 12 (observing that SpaceX’s suggestion that systems exchange beam pointing information “could prove complicated in practice – such as when beam pointing modifications are very dynamic and may change at very short time intervals”). 46 See Viasat Comments at 3. 47 Id. 48 Id. 49 Id. 12

clients insist on restricting O3b’s own access to sensitive beam location data, and O3b certainly

would not be in a position to disclose such information to other operators.

Moreover, neither SpaceX nor Amazon provides evidence to suggest that wholesale

disclosure of beam location information is critical to achieving coordination between operators.

To the contrary, O3b’s experience in coordination negotiations confirms that more high-level,

less commercially sensitive operating data can be sufficient to allow parties to assess and manage

interference risks. Thus, rather than specifying that beam location data must be exchanged in all

cases, the Commission should continue to allow parties to individual coordination negotiations to

determine which system operational parameters to share in order to advance their discussions.

IV. CONCLUSION

For the foregoing reasons and those set forth in the O3b Comments, the Commission

should use the O3b proposals as the foundation to initiate a rulemaking proceeding to update

NGSO intersystem sharing policies. The Commission should reject changes to its longstanding

framework for determining home spectrum selection rights and decline to impose requirements

to share beam location information.

Respectfully submitted,

O3B LIMITED

By: /s/ Suzanne H. Malloy Of Counsel Vice President, Regulatory Affairs Karis A. Hastings O3b Limited SatCom Law LLC 1129 20th Street, N.W., Suite 1000 1317 F Street, N.W., Suite 400 Washington, D.C. 20006 Washington, D.C. 20004 [email protected] [email protected]

June 30, 2020

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CERTIFICATE OF SERVICE

I hereby certify that on this 30th day of June, 2020, I caused to be served a true copy of the foregoing “Reply Comments of O3b Limited” via electronic mail upon the following:

David Goldman Christopher J. Murphy Space Exploration Technologies Corp. Viasat, Inc. david.goldman@spacex.com [email protected]

William M. Wiltshire Randy Segal Paul Caritj Gary Yeung [email protected] [email protected] [email protected] [email protected] Counsel to SpaceX Counsel to Karousel LLC

Julie Zoller Sallye Clark Andrew Keisner Laura Stefani Mariah Dodson Shuman [email protected] Kuiper Systems LLC [email protected] [email protected] Counsel for AST&Science LLC [email protected] [email protected] Nickolas G. Spina Kepler Communications Inc. Henry Goldberg [email protected] Joseph A. Godles Jonathan L. Wiener Joseph D. Fargnoli [email protected] Theia Holdings A, Inc.

[email protected] [email protected] [email protected] Counsel to Telesat Canada

Ruth Pritchard-Kelly OneWeb ruth@oneweb.net

Brian Weimer Douglas Svor [email protected] [email protected] Counsel to OneWeb

/s/ Suzanne Malloy