Federal Communications Commission
Washington, D.C. 20554
DA 08-551
March 11, 2008
William K. Coulter, Esq.
DLA Piper US LLP
500 8th Street, N.W.
Washington, DC  20004
Re:  Call Sign E000669
File No. SES-MOD-20080229-00213
Dear Mr. Coulter:
On February 29, 2008, TeleCommunication Systems filed the above-captioned application to 
modify its VSAT network license1 to add an additional terminal-type.  Pursuant to Section 
25.112(a)(1) of the Commission’s rules, 47 C.F.R. § 25.112(a)(1), we dismiss the application as 
defective without prejudice to refiling. 
Section 25.112 of the Commission’s rules, 47 C.F.R. § 25.112, requires the Commission to 
return, as unacceptable for filing, any earth station application that is not substantially complete, 
contains internal inconsistencies, or does not substantially comply with the Commission’s rules.  
TeleCommunication Systems’ application does not comply with the Commission’s rules, which 
renders it unacceptable and subject to dismissal.  The deficiencies are as follows:
The application lists ALSAT-designated satellites as the earth station’s only intended points of 
communication.  Earth station applicants may not use the ALSAT designation in cases where the 
earth station’s power density exceeds the limit in Section 25.212(c) of the Commissions rules, 47 
C.F.R. § 25.212(c).  Applicants proposing operations exceeding this limit must identify specific 
satellites as points of communications.2 In response to item E49 of Schedule B, 
TeleCommunication Systems lists 38.80 dBW/4kHz as the maximum equivalent isotropic 
radiated power (e.i.r.p.) density per carrier for emission 5M00G7D.  Based on this information, 
we calculate the power density at the input of the antenna flange as -8.70 dBW/4kHz (subtracting 
the antenna gain from the e.i.r.p. density). This value exceeds the -14.0 dBW/4kHz power 
density limit in Section 25.212(c).  Thus, TeleCommunication Systems cannot use an ALSAT 
designation and must specifically list all satellites with which the earth station intends to 
communicate.    
Additionally, applicants requesting authority for earth stations that will operate at power density 
exceeding the level in Section 25.212(c) must submit a certification described in Section 
  
1  This network operates in the 11.7-12.2 and 14.0-14.5 GHz frequency bands.
2 Amendment of the Commission’s Regulatory Policies to Allow Non-U.S.-Licensed Space Stations to 
Provide Domestic and International Services in the United States, First Order on Reconsideration, IB 
Docket No. 96-111, 15 FCC Rcd 7207-7210 n.19.
Federal Communications Commission                  DA 08-551 
2
25.220(e)(1) of the Commission’s rules, 47 C.F.R. § 25.220(e)(1) from each target satellite 
operator.  TeleCommunication Systems’ application does not include these certifications.  
In light of the above, pursuant to Section 25.112(a)(1) of the Commission’s rules, 47 C.F.R. § 
25.112(a)(1) and Section 0.261 of the Commission’s rules on delegations of authority, 47 C.F.R. 
§ 0.261, we dismiss TeleCommunication Systems’ application without prejudice of refiling.3
Sincerely,
Scott A. Kotler
Chief, Systems Analysis Branch
Satellite Division
International Bureau
  
3 If TeleCommunication Systems refiles an application identical to the one dismissed, with the exception 
of supplying the corrected information, it need not pay an application fee.  See 47 C.F.R. § 1.1109(d).