Federal Communications Commission DA 12-1674
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of Application of 
GEC PARTNERS LLP
For Renewal of License of Common Carrier Fixed 
Point-to-Point Station WPOM239
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File No. 0004106053
ORDER ON RECONSIDERATION
Adopted:  October 17, 2012 Released:  October 18, 2012
By the Deputy Chief, Broadband Division, Wireless Telecommunications Bureau:
I. INTRODUCTION
1. In this Order on Reconsideration, we grant GEC Partners LLP’s (“GEC”) petition for 
reconsideration of the Wireless Telecommunications Bureau’s (“Bureau”) dismissal of GEC’s application 
to renew its license to operate Station WPOM239 because GEC failed to timely respond to a Notice of 
Return asking GEC to provide additional information in its associated Construction Notification. While 
the original dismissal was correct, we find that it is in the public interest to reinstate GEC’s application to 
renew Station WPOM239 and thus allow GEC to continue to provide fixed wireless services.
II. BACKGROUND
2. GEC operates 39 GHz Common Carrier Fixed Point-to-Point Station WPOM239 in a 
Rectangular Service Area in the San Antonio, Texas area.1 On January 27, 2010, GEC timely filed an 
application to renew Station WPOM2392 and its associated substantial service showing as required under 
Section 101.17 of the Commission’s Rules, which requires licensees to demonstrate substantial service at 
license renewal.3
3. On May 18, 2012, the Bureau sent a Notice of Return to GEC and to the licensee’s 
contact, Russell H. Ritchie, at 1010 West University Drive, Suite 4¸Mesa, AZ 85201, which is the address 
of record on file for both GEC and Mr. Ritchie.4 The Notice of Return asked GEC to provide more 
detailed information on the number and lengths of links and the coordinates of both transmit and receive 
sites within 60 days (July 17, 2012) or GEC’s Renewal Application would be dismissed.  GEC did not 
respond to the Notice of Return.  
  
1 GEC Partners LLP, Petition for Reconsideration (filed Sept. 7, 2012) (“Petition”).
2 File No. 0004106053 (filed Jan. 27, 2010) (“Renewal Application”).
3 47 C.F.R § 101.17(a).
4 Notice of Return, Ref. 5374343 (May 18, 2012) (“Notice of Return”).
Federal Communications Commission DA-12-1674 
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4. On August 7, 2012, the Bureau sent a Notice of Dismissal to GEC and Mr. Ritchie at the 
address of record informing them that the Bureau dismissed GEC’s application without prejudice because 
GEC had not responded to the Notice of Return by July 17, 2012.5
5. On September 7, 2012, GEC asked the Bureau to reconsider its decision dismissing 
GEC’s application to renew Station WPOM239.  GEC stated that the 1010 West University Drive address 
is not the current address for GEC and the Notice of Return was never received.6 It indicated that it 
became aware that its license to operate Station WPOM239 was cancelled when GEC staff, working on 
Station WPOM239’s facilities, reviewed the Commission’s database, and discovered that the Bureau had 
dismissed the Renewal Application.7 GEC admits that it neglected to keep its contact information up-to-
date, but argues that in over a quarter of a century of interacting with the Commission, a lapse of this kind 
had never occurred.8 In addition, Mr. Ritchie, the principal primarily responsible for Station WPOM239, 
was out of the country when a routine review would have revealed a problem.9 GEC further argues that 
cancellation and forfeiture of the license is disproportional to the underlying facts regarding status of the 
links and the public interest in using the spectrum for broadband supported service.10 GEC attached to its 
Petition the information requested in the Notice of Return.11
6. On October 10, 2012, GEC asked leave to supplement its Petition with new information 
explaining how it had failed to update its contact information. 12 GEC stated that before Mr. Ritchie left 
the country on a two-year mission for his church, he relocated GEC’s office.13 Then on May 11, 2010, he 
and his partner, Mr. Kipp, updated the contact information for the licenses held by GEC.14 According to 
GEC, Mr. Ritchie and Mr. Kipp updated 20 of the 23 licenses held by GEC, which appeared on two pages 
of the Commission’s Universal Licensing System (“ULS”) database.15 Neither Mr. Ritchie nor Mr. Kipp 
noticed the three additional licenses on the third page of the ULS, which included the license for Station 
WPOM239.16 The contact information for the other two licenses listed on page three was updated on 
September 7, 2012.17
III. DISCUSSION
7. Under Section 1.106(f) of the Commission’s Rules, a “petition for reconsideration and 
any supplement thereto shall be filed within 30 days from the date of public notice of the final 
  
5 Notice of Dismissal, Ref. No. 5422739 (Aug. 7, 2012).  The Bureau gave public notice of the dismissal of the 
Renewal Application on August 8, 2012.  See Wireless Telecommunications Bureau Site-by-Site Action, Report No. 
7974, Public Notice (Aug. 8, 2012) at 10.
6 Petition at 1.
7 Id.
8 Id. at 2.
9 Id.
10 Id.
11 Id. at Attachment.
12 GEC Partners LLP, Petition for Leave to File Supplement to Petition for Reconsideration (filed Oct. 10, 2012). 
13 GEC Partners LLP, Supplement to Petition for Reconsideration (filed Oct. 10, 2012) (“Supplement”) at 2.
14 Id. at 2.
15 Id.
16 Id.
17 See File Nos. 0005383568, 0005383569 (filed Sep. 7, 2012).
Federal Communications Commission DA-12-1674 
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Commission action . . . .”18 Section 1.106(f), however, also gives us discretion to consider a late-filed 
supplement to a timely filed petition if a petitioner presents sufficient justification to do so.19  In this case, 
we grant GEC’s request because it shows GEC’s failure to update its contact information for Station 
WPOM239 resulted from an inadvertent error.  Moreover, the information in the Commission’s ULS 
database confirms GEC’s statements that it updated the 20 licenses on the first two pages of the ULS 
database on May 11, 2010 and overlooked the last three licenses on the third, and last page, of the 
database, which included the license for Station WPOM239.20
8. Although GEC timely filed its application to renew Station WPOM239, we conclude that 
the dismissal of GEC’s Renewal Application was proper.  Under Section 1.934(c) of the Commission’s 
rules, we may dismiss GEC’s Renewal Application because GEC failed to respond to our Notice of 
Return on or before July 17, 2012, the date indicated in the Notice of Return.21 Generally, the Bureau 
sends a Notice of Return to applicants when additional information is necessary for the Bureau to process 
the application.  Moreover, Notices of Return plainly state that “[i]f you do not file an amendment to your 
application within 60 days of the date on the top of this letter, your application will be dismissed.”22 In 
this case, the Notice of Return requested that GEC provide more detailed information on the number and 
lengths of links and the coordinates of both transmit and receive sites on or before July 17, 2012.  GEC 
did not do so and thus its Renewal Application was properly dismissed.
9. The pertinent question before us, however, is whether to reinstate GEC’s Renewal 
Application on reconsideration.  While there is precedent for refusing to reinstate renewal applications 
when an applicant fails to offer a justification for failing to respond to a return letter,23 based upon the 
totality of the circumstances involved in this case, we believe the public interest would best be served by 
granting the GEC’s Petition and reinstating its Renewal Application.  Although GEC did not timely 
respond to the Notice of Return, it has otherwise been diligent in complying with the Commission’s 
rules.24 It timely filed its Renewal Application with construction information.  Moreover, by showing that 
it had updated the contact information of 20 of its 23 licenses, it showed that its failure to update the 
contact information for Station WPOM239 was an inadvertent error.  Under these specific circumstances, 
while we expect GEC to exercise greater care in the future, we do not believe that GEC should lose its 
license for this isolated failure.  Moreover, because GEC is using Station WPOM239 to provide wireless 
service, we find that it is in the public interest to grant its Petition.
IV. CONCLUSION AND ORDERING CLAUSES
10. The decision to dismiss GEC’s Renewal Application was correct.  However, based upon 
the information provided in the Petition for Reconsideration, we have decided to reinstate GEC’s 
Renewal Application.  Accordingly, we grant GEC’s Petition for Reconsideration.
  
18 47 C.F.R. § 1.106(f).
19 47 C.F.R. § 1.106(f).
20 See File Nos. 0005383568, 0005383569 (filed Sep. 7, 2012).
21 47 C.F.R. § 1.934(c).  Under Section 1.934(c) of the Commission’s Rules, an application may be dismissed when 
the applicant fails “to respond substantially within a specified time period to official correspondence or requests for 
additional information.”
22 See Notice of Return.
23 See RAM Technologies, Inc., Order on Reconsideration, 16 FCC Rcd 10919 (WTB PS&PWD 2001).
24 See Somerville Independent School District, Order on Reconsideration, 27 FCC Rcd 6063 (WTB BD 2012) 
(renewal application reinstated despite failure to respond to notice of return where two notices of return had been 
sent around the same time and licensee had otherwise been diligent in complying with the Commission’s rules).
Federal Communications Commission DA-12-1674 
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11. Accordingly, IT IS ORDERED that pursuant to Sections 4(i) and 405 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 405, and Sections 1.106 of the 
Commission’s rules, 47 C.F.R. §§ 1.106 the Petition for Reconsideration filed by GEC Partners LLP, on 
September 7, 2012 IS GRANTED.
12. IT IS FURTHER ORDERED, pursuant to Sections 4(i) and 309 of the Communications 
Act of 1934, as amended, 47 U.S.C. § 154(i), 309, and Section 1.949 of the Commission’s rules, 47 
C.F.R. § 1.949, that the Broadband Division SHALL REINSTATE AND PROCESS the application filed 
by GEC Partners LLP (File No. 0004106053) in accordance with this Order on Reconsideration and the 
Commission’s rules and policies.
13. These actions are taken under designated authority pursuant to Sections 0.131 and 0.331 
of the Commission’s Rules, 47 C.F.R. §§ 0.131, 0.331.
FEDERAL COMMUNICATIONS COMMISSION
John J. Schauble
Deputy Chief, Broadband Division
Wireless Telecommunications Bureau