PUBLIC NOTICE Federal Communications Commission 445 12th St., S.W. Washington, D.C. 20554 News Media Information 202 / 418-0500 Internet: http://www.fcc.gov TTY: 1-888-835-5322 DA 07-2257 Released: May 30, 2007 Stratos Global Corp. and Robert M. Franklin, Trustee, Seek FCC Consent to the Indirect Transfer of Control of Stratos Global’s Wholly-Owned, FCC-Authorized Subsidiaries from Stratos to an Irrevocable Trust WC Docket No. 07-73 PLEADING CYCLE ESTABLISHED Petitions to Deny Due: June 29, 2007 Oppositions Due: July 9, 2007 Replies Due: July 16, 2007 I. INTRODUCTION Stratos Global Corp. (Stratos Global) and Robert M. Franklin, Trustee (Trustee), have filed Applications pursuant to sections 214 and 310(d) of the Communications Act of 1934, as amended (Communications Act),1 seeking approval of the transfer of control of Stratos Global and its wholly- owned subsidiaries (the “Stratos Subsidiaries”) that hold authorizations from the Commission (Stratos Licensees and, together with Stratos Global and the Stratos Global Subsidiaries, “Stratos”) from the current shareholders of Stratos Global to an irrevocable trust (Trust) for which Mr. Franklin is the Trustee. Stratos provides mobile satellite service (MSS), fixed satellite service (FSS) and terrestrial communications using, among other things, capacity that it purchases from various satellite operators. The Trust, to which Stratos would be transferred, is established under the laws of Canada by CIP Canada Investment Inc. (CIP Canada), a wholly-owned subsidiary of CIP UK Holdings Limited (CIP UK), which, in turn, is a wholly-owned subsidiary of Communications Investment Partners Limited (CIP). CIP, a professional investment company, is making the proposed investment in Stratos Global through its subsidiaries and the Trust. The beneficiary of the Trust, and therefore the beneficial owner of Stratos Global, will be CIP Canada. Upon completion of the proposed transaction, the Trustee will have full autonomy to vote the Stratos Global shares, subject to his fiduciary obligations to the beneficiary. Current Stratos management will continue to operate the Stratos business, subject to the Trustee’s control and oversight through exercise of his voting rights in the Stratos Global shares. 1 47 U.S.C. §§ 214, 310(d). 2 The proposed transaction will be financed indirectly by Inmarsat Finance III Limited (Inmarsat Finance), a wholly-owned subsidiary of Inmarsat plc (Inmarsat). Another Inmarsat subsidiary, Inmarsat Global Ltd. (Inmarsat Global), has contractual restrictions that expire in April, 2009, that prevent Inmarsat Global from owning or controlling Stratos or any other distributor of Inmarsat services. CIP has granted Inmarsat Finance a call option to acquire the stock of CIP UK, which is exercisable over a 17- month period beginning in April 2009 and ending on December 31, 2010; thus, Inmarsat has an irrevocable right to acquire Stratos Global after the contractual restrictions on Stratos Global have expired. Until April 2009, the shares of Stratos Global will be held by the Trust to give the Trustee both de jure and de facto control of Stratos, so as to comply with Inmarsat Global’s contractual obligations. II. THE PARTIES A. The Transferor - Stratos Global Applicants represent that Stratos Global is a public company, traded on the Toronto Stock Exchange, and is widely held, primarily by Canadian and U.S. shareholders. Stratos Global’s corporate headquarters and principal place of business is Bethesda, Maryland. The Stratos Licensees are wholly- owned subsidiaries of Stratos Holdings, Inc., a Delaware corporation, which is a wholly-owned subsidiary of Stratos Wireless, Inc., a Canadian corporation, which, in turn, is a wholly-owned subsidiary of Stratos Global, also a Canadian corporation. Stratos provides MSS, FSS and terrestrial communications services. In the United States, Stratos provides MSS, FSS and VSAT (very small aperture terminal) satellite services, using satellite capacity that it acquires from other entities. With respect to MSS, Stratos resells satellite services for satellite operators such as Globalstar, Inmarsat, Iridium and MSV. Stratos holds FCC licenses for Inmarsat mobile earth terminals, but does not own or operate any MSS gateway earth stations in the United States. Stratos provides VSAT services by reselling the services of several providers of FSS systems, such as Intelsat and SES, and using a number of U.S. VSAT hubs that are licensed to Stratos. Further, Stratos operates a terrestrial microwave network in the Gulf of Mexico, which it primarily uses to serve offshore oil and gas drilling platforms. Finally, Stratos provides local exchange, competitive access, and interexchange telecommunications services in Louisiana and Texas, also primarily to oil and gas industry customers. B. The Transferee - The Trustee Applicants state that the Trust is organized under the laws of Canada solely to hold the shares of Stratos Global upon completion of this proposed transaction. The Trustee is Robert M. Franklin, a Canadian citizen. Mr. Franklin has served on the board of several corporations.2 C. CIP CIP is a limited partnership organized under the laws of the British Virgin Islands to hold shares of Stratos Global. CIP is a professional investment company that focuses on investments in satellite service companies. The five Directors and sole equity holders of CIP are Hans Lipman (a Dutch citizen), Eric de Jong (a Dutch citizen), Hans van Moorsel (a Dutch citizen), Eric Le Proux (a French citizen) and Victor Horcacitas (a dual U.S. and Mexican citizen). Each holds a 20 percent equity and voting interest in CIP. 2 Mr. Franklin served as chairman of Glenayre Electronics Limited, a telecommunications hardware and software company from 1990-93; as a director of Call-Net Enterprises, Inc., a Canadian competitive carrier from 2002-2005; and as Chairman of Placer Dome, Inc., a Canadian mining company, from 1993-2006. Mr. Franklin currently serves as a director of Barrick, an international gold mining company. 3 CIP has established two holding companies to effectuate the proposed transaction: CIP UK (a private limited company incorporated under the laws of England and Wales); and CIP Canada (a Canadian company). CIP Canada is wholly owned by CIP UK, which, in turn, is wholly owned by CIP. D. Inmarsat Entities Inmarsat Finance, a company incorporated under the laws of England and Wales, is a special- purpose company that was established by its direct parent company, Inmarsat, to provide debt financing to CIP to fund the acquisition of Stratos. Inmarsat Global, also incorporated under the laws of England and Wales, operates a global MSS satellite system that, through its distributors, offers a variety of mobile satellite services. Inmarsat was created by the INMARSAT Convention in 1979 as an inter-governmental organization to develop a global maritime satellite system. Inmarsat privatized in 1999 by converting to a private UK company headquartered in London. In 2005, Inmarsat became a public company, listed on the London Stock Exchange. Inmarsat’s shares are widely held, and no shareholder owns 10 percent or more of the company. Applicants state that, in aggregate, more than 85 percent of Inmarsat’s shares are owned by citizens of or entities organized under the laws of countries that are members of the World Trade Organization (WTO). Applicants state that, at present, Inmarsat Global is contractually restricted from selling its services directly to end users, or from owning or controlling a company that distributes its services. Applicants further state that Inmarsat Global’s current distribution agreements, which contain this restriction, will expire in April, 2010. III. THE TRANSACTION The agreement entered into between CIP UK, CIP Canada and Stratos Global, provides that CIP Canada will purchase all the shares of Stratos Global through a Plan of Arrangement under the Business Corporations Act of Canada. The Plan of Arrangement requires approval both by an Ontario court and by 66 2/3 percent of votes cast at a special meeting of the shareholders. Upon completion of the transaction, the shares of Stratos Global will be held by the Trust. The Trust, which is irrevocable, was formed to give the Trustee de jure and de facto control of Stratos. The Trust will exercise all voting rights in the Stratos Global stock. The Trust Agreement expressly prohibits any communication between the CIP entities or the Inmarsat entities and the Trustee regarding the operation of Stratos. Applicants state that the Trustee has no familial ties or business relationships with CIP, apart from the Trust, or with Inmarsat. The Trustee may be removed only upon a finding by an independent party that the Trustee is in breach of his fiduciary obligations, or if the Trustee is adjudged to be incompetent by a court. Applicants further state that Inmarsat Finance will finance the transaction, pursuant to a “loan facility” under which CIP UK may draw up to $250 million to fund the cost of CIP Canada’s acquisition of Stratos. Additional funds will be available for CIP Canada’s refinancing of Stratos’s existing senior debt facility or its funding of the tender offer for Stratos’s outstanding bonds required to be made following completion of the transaction. The Applicants represent that the loan facility has a ten-year term with an interest rate of 5.75 percent through December 31, 2010, and 11.5 percent thereafter. Applicants note that interest on the loan is to be on a “paid in kind” basis until April 14, 2009. Applicants further note that the loan is unsecured until April 14, 2009 (when a security package subordinated to the existing Stratos indebtedness will be put into place), except that, in the event of a default, Inmarsat Finance can require CIP UK to divest its shares in CIP Canada and to pay the net proceeds to Inmarsat Finance. Thus, Applicants assert that, even as a creditor of CIP UK, Inmarsat will not be able to take control over the management and affairs of Stratos until April 2009 and that, even then, could do so only with prior permission from the Commission. 4 Applicants state that CIP has granted Inmarsat Finance an irrevocable call option to acquire CIP UK for consideration of $750,000. Applicants further state that the call is exercisable over a 17-month period beginning in April, 2009, and ending December 31, 2010. The exercise price for the call will be between $750,000 and $1,000,000, depending upon when the option is exercised. Unless and until it exercises the call (and obtains regulatory approval), Inmarsat may not acquire any equity interest in Stratos or influence its management. Subject to regulatory approval, the Trust will automatically terminate on April 14, 2009, unless Stratos shares have not been transferred out of the Trust by that date. Applicants state that there are three routes by which this may occur. First, Inmarsat Finance could exercise the call option to acquire CIP UK, at which time the Trustee will transfer the shares to CIP Canada. Second, if Inmarsat Finance does not exercise the call option, CIP Canada may acquire the shares. Third, if neither of these events has occurred because governmental approvals cannot be obtained, the Trustee will arrange for an investment bank to sell the shares through an auction. IV. THE APPLICATION The Application consists of eleven individual applications and documents as follows: · Four FCC 312 Forms seeking consent for the transfer of Stratos Global’s VSAT, FSS and MSS earth station Authorizations; · Three FCC 214 Forms seeking consent for transfer of Stratos Global’s various international section 214 Authorizations; · Two FCC Domestic 214 applications seeking consent to transfer Stratos Global’s domestic section 214 authority; · One FCC Form 603 seeking consent to transfer Stratos Global’s various terrestrial radio licenses; and · One FCC Form 44 seeking consent to transfer Stratos Global’s Authorization as an Accounting Authority. V. SECTION 214 AUTHORIZATIONS A. International Authorizations The following applications for consent to the transfer of control of international section 214 authorizations to Robert Franklin (Trustee) have been assigned the file number listed below: International Facilities–Based and Resale Services: File No. Authorization Holder Authorization Number International Facilities-Based and Resale Services: ITC-T/C-20070405-00136 Stratos Communications, Inc. ITC-214-19980828-00591 ITC-214-19980326-00205 ITC-214-19980121-00028 ITC-214-20010220-00657 ITC-MOD-20040624-00241 5 Mobile Networks: ITC-T/C-20070405-00133 Stratos Mobile Networks, Inc. ITC-214-19981214-00859 ITC-214-19970924-00580 ITC-214-19970804-00455 ITC-214-19970627-00356 ITC-214-19961003-00481 ITC-214-19980130-00053 ITC-214-19910301-00010* (Formerly ITC-90-088) ITC-214-19901030-00011* (Formerly ITC-91-012) ITC-214-19910615-00009* (Formerly ITC-91-157) ITC-214-19911206-00008* (Formerly ITC-92-058) ITC-214-19911206-00007* (Formerly ITC-92-059) ITC-214-19921026-00124* (Formerly ITC-93-013) ITC-214-19921026-00123* (Formerly ITC-93-014) ITC-214-19910201-00255* (Formerly ITC-93-141) ITC-214-19931001-00254* (Formerly ITC-93-142) ITC-214-19930511-00253* (Formerly ITC-93-188) ITC-214-19950526-00034* (Formerly ITC-95-359) ITC-214-19951001-00033* (Formerly ITC-95-565) ITC-214-19951001-00032* (Formerly ITC-95-569) ITC-214-19960101-00012* (Formerly ITC-96-041) * The above File Numbers for the section 214 authorizations marked with an * are new numbers assigned under the IBFS system. The former number for each such authorization is shown below the new number. Offshore: ITC-T/C-20070405-00135 Stratos Offshore Services Company ITC-214-19991220-00815 ITC-214-19980914-00636 Applicants request streamlined processing for all three of the above Applications. Applicants assert that the Applications qualify for streamlined processing because the licensee in each of the Applications, i.e., Stratos Mobile (ITC-T/C-20070405-133), Stratos Offshore (ITC-T/C-20070405- 00135), and Stratos Communications (ITC-T/C-20070405-00136), qualifies for a presumption of non- dominance under section 63.10(a)(3) of the Commission’s rules, because the foreign carrier that each is affiliated with has less than a 50 percent share of the local access markets in the relevant geographical 6 markets.3 Alternatively, Applicants assert that the Applications qualify for streamlined processing because none of the three licensees is affiliated with any dominant U.S. carrier whose international switched or private-line services it seeks to resell, see 47 C.F.R. § 63.12(c)(2).4 In light of the multiple applications before the Commission in this transaction and the public interest review associated with them, however, we conclude, pursuant to sections 63.12 (c) and (d) of the Commission’s rules, that all three of the above international section 214 Transfer of Control Applications transfer of control Application are not subject to streamlined treatment.5 B. Domestic Authorization The following applications for consent to the transfer of control of domestic section 214 authority of Stratos Global Corporation and Stratos Offshore Services Company have been assigned the following docket number: Docket Number: Authorization Holder WC Docket No. 07-73 Stratos Communications, Inc. Stratos Offshore Services Company Applicants filed two Applications for consent to transfer control of the domestic section 214 authority of Stratos Global Corporation and Stratos Offshore Services Company from Stratos Communications, Inc. to Robert Franklin, Trustee. Stratos Communications, Inc., an indirect subsidiary of transferor, Stratos Global Corporation, provides nationwide mobile satellite services where the originating and terminating points may both be in the United States; Stratos Offshore Services Company, a Stratos Communications, Inc., affiliate, provides wireline services in the United States, primarily in the Gulf of Mexico region. Applicants assert that these transactions are entitled to presumptive streamlined treatment under section 63.02(b)(1)(ii) of the Commission's rules because the proposed transactions involve only the transfer of assets to a trust and the Trustee, Robert Franklin, is not a telecommunications provider.6 Alternatively, Applicants assert that these transactions are entitled to presumptive streamlined treatment under section 63.02(b)(2)(i) because the Applicants and their affiliates will have a market share in the interstate, interexchange market of less than 10 percent, provide competitive telephone exchange service in markets served by a dominant local exchange carrier not party to the transaction, and are not dominant with respect to any service.7 In light of the multiple applications before the Commission in this transaction and the public interest review associated with them, however, we conclude, pursuant to section 63.03(c) of the Commission’s rules, that Applicants’ domestic section 214 transfer of control Applications are not subject to streamlined treatment.8 3 See 47 C.F.R. § 63.10(a)(3) (2006). 4 See 47 C.F.R. § 63.12(c)(2) (2006). 5 See 47 C.F.R. § 63.12(c) and (d) (2006). 6 See 47 C.F.R. § 63.03(b)(1)(ii) (2006). 7 See 47 C.F.R. § 63.03(b)(2)(i) (2006). 8 See 47 C.F.R. § 63.03(c) (2006). 7 VI. SECTION 310(d) APPLICATIONS A. Part 25-Satellite Earth Station, VSAT, and Space Station Authorization Applications The following applications for consent to the assignment and transfer of control of satellite earth station, VSAT, and space station authorizations to Robert Franklin (Trustee) have been assigned the file numbers listed below: File No. Licensee Call Sign(s) SES-T/C-20070404-00440 Stratos Offshore Services Company E950151 E010263 SES-T/C-20070404-00441 Stratos Communications, Inc. E010050 E010049 E010048 E010047 E000180 SES-T/C-20070404-00442 Stratos Offshore Services Company E950150 E950149 E960147 E950136 E950135 SES-T/C-20070404-00443 Stratos Offshore Services Company E980235 B. Part 90-Wireless Licenses The following application for consent to the assignment and transfer of control of wireless service licenses to Robert Franklin (Trustee) has been assigned the file number listed below: File No. Licensee Lead Call Sign 00029617379 Stratos Offshore Services Company WPNA687 VII. APPLICATION FOR ASSIGNMENT OF ACCOUNTING AUTHORITY STATUS Pursuant to section 3.20 of the Commission’s rules,10 Applicants filed an Application for Certification as an Accounting Authority (FCC Form 44). Applicants note that one of the Stratos 9 By amendment filed April 27, 2007, Applicants amended this application to add 31 additional call signs for microwave licenses to be transferred to the Trust. These 31 licenses were included in an assignment of licenses from Chevron USA Inc., Sola Communications, L.L.C., and Devon Energy Corporation (the Chevron Assignment) to Stratos Offshore, to which the Commission consented on March 3, 2007. Applicants state that they filed the pending Transfer of Control application on April 5, 2007, after the Commission’s consent to the assignment but before the transaction could be consummated. As a result, Applicants note that they could not include the 31 licenses in the Application. Now that the Chevron Assignment transaction has been completed, the Applicants have added the additional call signs. 10 47 C.F.R. § 3.20 (2006). 8 Licensees, Stratos Mobile Networks, Inc., is currently certified by the Commission as an accounting authority in the maritime mobile and maritime mobile-satellite radio services, holding Accounting Authority Identification Code (AAIC) No. US09.11 Maritime Mobile and Maritime Mobile-Satellite communications refer to communications exchanged between two vessels on the high seas or between a vessel and a land radio station. An accounting authority is an entity, licensed by a government, that settles accounts for mobile radio stations on vessels licensed by that government, that is, the entity to which a foreign maritime mobile radio station operator may send the bill for the vessel’s mobile communications. The accounting authority sends the bill to the vessel operator and remits such vessel’s payment to the foreign station operator. Applicants note that they do not, by this application, seek to assign, or otherwise encumber, Stratos Mobile’s accounting authority status, but seek only to update the ownership and control information in the Commission’s files with respect to that accounting authority certification. Applicants note that section 3.51 of the Commission’s rules requires accounting authorities to notify the Commission “in advance of any proposed transfer of control of an accounting authority’s firm or organization by any means, to another entity.”12 Applicants note that notification is required because, under the proposed transaction, the ultimate parent corporation of Stratos Mobile, Stratos Global Corporation, is going from a publicly traded corporation to one that is privately held. Applicants assert that Stratos Mobile does not currently expect to change the way it administers its Accounting Authority function as a result of the proposed transaction. Applicants assert that Stratos Mobile will continue to perform all settlement operations for U.S. licensed vessels through its office in Bethesda, Maryland (USA). VIII. PETITION FOR DECLARATORY RULING UNDER SECTION 310(b)(4) The Applicants have filed, pursuant to section 310 (b)(4) of the Communications Act, a petition for a declaratory ruling that it is in the public interest for the Stratos Licensees to be controlled by a Canadian Trust with a Canadian Trustee, with up to 100 percent foreign ownership.13 According to the Applicants, after consummation of the proposed transaction, the stock of Stratos will be owned by a Canadian Trust (whose Trustee is a citizen and resident of Canada). Further, the direct and indirect beneficiaries of the Trust will be CIP Canada (a Canadian corporation), which is wholly owned by CIP UK (a private company incorporated under the laws of England and Wales), which in turn is a wholly-owned subsidiary of CIP (a British Virgin Islands corporation). Applicants state that CIP is a new investment company whose initial (and only proposed current) investment will be in Stratos. CIP is owned by five principals, each of whom holds a 20 percent equity and voting interest. These are Hans Lipman (a Dutch citizen and resident), Eric Johannes Werner de Jong (a Dutch citizen and resident), J.J.M. (“Hans”) van Moorsel (a Dutch citizen and resident), Eric Marie Alain Le Proux de la Riviere (a French citizen and resident), and Victor Horcasitas Rivas (a dual U.S. and Mexican citizen, whose primary residence is Spain). Finally, Applicants note that financing for the proposed transaction will come from Inmarsat Finance III Limited, a subsidiary of a widely-held, publicly traded company, Inmarsat, that is incorporated under the laws of England and Wales. Applicants state that the Trustee, CIP and its subsidiaries, and the CIP principals are all either organized under the laws of or are citizens of Canada, the Netherlands, the British Virgin Islands, 11 See Notification of Approval as an Accounting Authority, DA 04-758 (rel. March 23, 2004). 12 47 C.F.R. § 3.51 (2006). 13 47 U.S.C. § 310(b)(4). 9 England and Wales, Mexico or France, all of which are Members of the WTO. As a result, Applicants argue that the presumption in the Commission’s Foreign Participation Order14 that foreign ownership in excess of the section 310(b)(4) benchmark will serve the public interest applies to this Application. Further, Applicants assert that, because this is CIP’s first investment in the communications industry, and because the Trustee has no other cognizable interests in the telecommunications industry, the transaction raises no competitive concerns. The petition for declaratory ruling has been assigned the file number ISP- PDR-20070405-00006. IX. EX PARTE STATUS OF THIS PROCEEDING Pursuant to section 1.1200(a) of the Commission’s rules,15 the Commission may adopt modified or more stringent ex parte procedures in particular proceedings if it finds that the public interest so requires. We announce that this proceeding will be governed by permit-but-disclose ex parte procedures that are applicable to non-restricted proceedings under section 1.1206 of the Commission’s rules.16 We direct parties making oral ex parte presentations to the Commission’s statement re- emphasizing the public’s responsibility in permit-but-disclose proceedings and are reminded that memoranda summarizing the presentation must contain the presentation’s substance and not merely list the subjects discussed.17 More than a one- or two-sentence description of the views and arguments presented is generally required.18 Other rules pertaining to oral and written presentations are set forth in section 1.1206(b) as well.19 We urge parties to use the Electronic Comment Filing System (ECFS) to file ex parte submissions.20 X. GENERAL INFORMATION The applications referenced herein 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 (31) days following the date of this Public Notice.21 Interested parties must file petitions to deny or comments no later than June 29, 2007. Responses or oppositions to comments and petitions must be filed no later than July 9, 2007. Replies to such pleadings must be filed no later than July 16, 2007. All filings concerning matters referenced in this Public Notice should refer to DA 07-2257 and WC Docket No. 07-73, as well as the specific file numbers of the individual applications or other matters to which the filings pertain. 14 Rules and Policies on Foreign Participation in the U.S. Telecommunications Market, 12 FCC Rcd 23891, 15 47 C.F.R. § 1.1200(a) (2006). 16 Id. § 1.1206. 17 See Commission Emphasizes the Public’s Responsibilities in Permit-But-Disclose Proceedings, Public Notice, 15 FCC Rcd 19945 (2000). 18 See 47 C.F.R. § 1.1206(b)(2) (2006). 19 Id. § 1.1206(b). 20 See discussion infra Part VI. 21 See 47 U.S.C. § 309(b). 10 Under the Commission’s procedures for the submission of filings and other documents,22 submissions in this matter may be filed electronically (i.e., though ECFS) or by hand delivery to the Commission’s Massachusetts Avenue location. · Electronic Filers:23 Comments may be filed electronically using the Internet by accessing the ECFS: http://www.fcc.gov/cgb/ecfs/. In completing the transmittal screen, filers should include their full name, U.S. Postal Service mailing address, and the applicable docket number. Parties also may submit an electronic comment by Internet e-mail. To get filing instructions, filers should send an e-mail to ecfs@fcc.gov, and include the following words in the body of the message, “get form.” A sample form and directions will be sent in response. · Paper Filers: Parties who choose to file by paper must file an original and four copies of each filing. Filings can be sent 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). All filings must be addressed to the Commission's Secretary, Office of the Secretary, Federal Communications Commission. The Commission's contractor 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, Express, and Priority mail should be addressed to 445 12th Street, S.W., Washington, D.C. 20554. 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 the Commission's duplicating contractor, Best Copy and Printing, Inc., at fcc@bcpiweb.com or (202) 488- 5563 (facsimile). Additionally, filers may deliver courtesy copies by email or facsimile to the following Commission staff: (1) David Strickland, Policy Division, International Bureau, at David.Strickland@fcc.gov or (202) 418- 2824 (facsimile); 22 See Implementation of Interim Electronic Filing Procedures for Certain Commission Filings, Order, 16 FCC Rcd 21483 (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 22165 (2001); Reminder: Filing Locations for Paper Documents and Instructions for Mailing Electronic Media, Public Notice, 18 FCC Rcd 16705 (2003). 23 See Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and Order, 13 FCC Rcd 11322 (1998). 11 (2) John F. Copes, Policy Division, International Bureau, at John.Copes@fcc.gov or (202) 418-2824 (facsimile); (3) Karl Kensinger, Satellite Division, International Bureau, a Karl.Kensinger@fcc.gov or (202) 418- 0748 (facsimile); (4) Erin McGrath, Wireless Telecommunications Bureau, at Erin.McGrath@fcc.gov or (202) 418-7224 (facsimile); (5) Gail Cohen, Wireline Competition Bureau, at Gail.Cohen@fcc.gov or (202) 418-1413 (facsimile); (6) Regina Dorsey, Office of Managing Director, at Regina.Dorsey@fcc.gov or (202) 418-2843 (facsimile); (7) Neil Dellar, 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 also are available electronically through the Commission’s ECFS, which may be accessed on the Commission’s Internet website at http://www.fcc.gov. People with Disabilities: To request this Public Notice in accessible formats (computer diskette, large print, audio recording, and Braille) send an email to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty). For further information, contact John Copes, Policy Division, International Bureau, at 202-418- 1478. -FCC-