Globalstar Inc (GSAT)

[E E Euthanasia]

excerpts from the Globalstar 10/14/16 Ex Parte filing in response to Microsoft 9/12/16 Ex Parte Filing:
https://ecfsapi.fcc.gov/file/101414430178/Globalstar%20Ex%20Parte%20Letter%20with%20Exhibits%20A%20&%20B%20-%2010.14.2016.pdf

GLOBALSTAR

October 14, 2016

Marlene H. Dortch, Secretary
Federal Communications Commission
445 Twelfth Street, SW
Washington, DC 20554

Re: Written Ex Parte: Terrestrial Use of the 2473-2495 MHz Band for Low-Power Mobile Broadband Networks – IB Docket No. 13-213

Dear Ms. Dortch:

Globalstar, Inc. (“Globalstar”) hereby submits into the record the attached responses of Roberson and Associates, LLC (“Roberson and Associates”) and AT4 wireless (“AT4”), to the ex parte filing by Microsoft Corporation (“Microsoft”) regarding the alleged effects of Terrestrial Low Power Service (“TLPS”) at 2473-2495 MHz on Xbox 360S game system operations.1 As Roberson and Associates explains in its response,2 Microsoft’s test results contain such blatant methodological flaws that they should be disregarded by the Commission. Further, the results contained in AT4’s report3 confirm that it is only under the most unrealistic and extreme testing scenarios that Microsoft could show any impact of TLPS on Xbox operations, much less an impact that could actually cause a perceptible degradation in an Xbox user’s gaming experience.

As has been conclusively tested and demonstrated over a multi-year process, under the Commission’s proposed rules in this proceeding, TLPS will be fully compatible with unlicensed operations within the ISM band at 2400-2483.5 MHz. Microsoft’s filing regarding transmissions occurring in the Xbox 360S system presents nothing to challenge these conclusions.

While Microsoft claims to show that TLPS will have a negative impact on Xbox 360S system performance, its tests appear to have been expressly designed to generate such harmful effects. Microsoft’s test environment, arrangement of equipment, and choice of operating parameters are all highly unrealistic and unrepresentative of real-world operating scenarios. As a result, Microsoft’s data is biased, unreliable, and should be accorded no weight in this proceeding. In its report, Roberson and Associates identifies the following glaring flaws in Microsoft’s testing methodology:

[...]

Throughout this multi-year proceeding, Globalstar in association with Roberson and Associates and AT4 have established repeatedly that TLPS will be a good neighbor to unlicensed operations in the ISM band at 2400-2483.5 MHz. Whether documenting a near doubling of wireless throughput on a Chicago university campus or the near doubling of the number of students able to use a school’s wireless network in Washington, D.C., Globalstar has shown that the consumer benefits achievable by adding TLPS are undeniable and important to solving the connectivity gaps in our nation’s classrooms.

In the end, Microsoft claims that there simply is not enough room in the upper 10.5 MHz of the ISM band to accommodate its Xbox customers’ gaming needs and the myriad of different uses consumers could otherwise make of an additional 22 MHz channel. Thus, Microsoft demands that the Commission side with the incumbent and sacrifice any additional consumer benefits that would otherwise be achieved with more intensive, competitive use of the spectrum. Yet, Microsoft’s own test results confirm that making such a stark choice between incumbent and aspiring uses of the spectrum is simply not necessary due to the entirely unrealistic utilization rates and test set-up assumptions required for Microsoft to show any impact on its Xbox 360S operations. Outside of Microsoft’s lab and inside our nation’s homes, consumers would have the wireless capacity to stream HD videos and complete on-line tutorials over Channel 14 while simultaneously engaging in wireless recreational pursuits. Indeed, the Commission could significantly alleviate existing congestion issues and narrow the “homework gap” affecting students across the United States all without any impact on Xbox.

For these additional reasons, Globalstar urges the Commission to adopt the final order placed on circulation in this proceeding in May and bring this multi-year proceeding to a successful conclusion. 5

Respectfully submitted,

/s/ L. Barbee Ponder

cc: Julius Knapp

ATTACHMENT OF/FROM:

Roberson and Associates

Analysis of Xbox 360S Compatibility Tests Reported in Microsoft Ex Parte Filing

Prepared for Globalstar, Inc., by:

Roberson and Associates, LLC Schaumburg, Illinois 60173

Authors:

Kenneth J. Zdunek, Ph.D.
Michael Needham
Nat Natarajan, Ph.D.

Date: October 14, 2016

Analysis of Xbox 360S Compatibility Tests Reported in Microsoft Ex Parte Filing

Summary

Microsoft Corporation submitted an FCC Ex Parte filing dated September 12, 2016 containing test results which allegedly demonstrate that if the Commission grants Globalstar permission to operate TLPS, then “a broad cross-section of U.S. consumers will lose functionality of their current gaming devices.” A Roberson and Associates team of technical experts has reviewed Microsoft’s filing and concludes that this sweeping statement is not supported, and that the reported tests are flawed and fail to support the claim that TLPS will adversely impact the functionality of Xbox 360S or other gaming consoles.

The tests of the Xbox 360S are flawed because: 1) the contrived test environment and physical configuration of devices do not represent a real-world operating scenario for gaming devices and concurrent Wi-Fi operations; 2) the test devices and operating parameters used for Wi-Fi and TLPS are not representative of actual equipment in the field or typical operating parameters for such equipment – in particular, simultaneous 100% duty cycle and near equal power levels for all IEEE channels in a consumer environment is a use-case that is not encountered in the real-world; 3) the tests were conducted on the Microsoft Xbox 360S, a device introduced in 2005 and no longer sold. Despite being in the marketplace for a long time, there is no evidence presented that the performance of this one device is representative of the large number of other gaming devices in use.

The transmitted power levels of the Wi-Fi and TLPS devices are described in a conflicting manner; we believe this is likely a technical error and it is likely that the transmitted TLPS power level was significantly higher than the Wi -Fi power levels, unfairly biasing the results against TLPS. Significantly, the actual relative received power levels of the desired Xbox 360S signals and undesired Wi-Fi and TLPS emissions at the Xbox 360S receiver were not specified and therefore cannot be used to ensure that normalized signal power levels were resident on the user termin als. The bandwidth of the modified (non-production) Ruckus access point used for TLPS transmissions was not measured and not shown to be representative of the characteristics of a device that would meet FCC requirements and could be legally sold and operated in the real world. The antenna characteristics, test tool and protocol of the Wi-Fi devices operating on channels 1, 6 and 11 were not specified. Further, the distance between the Wi-Fi devices directly and the distances between the Wi-Fi devices and the Xbox 360S devices were not specified; however, the images demonstrate that the devices were extremely close to one another and do not represent even worst -case real- world network deployments.

Finally, the example of text transmission with errors, allegedly chosen to represent the same type of error rate as produced with Xbox 360S button pushes with simultaneous Wi-Fi and TLPS, is misleading and adds nothing to the issue of TLPS compatibility with gaming devices. The example is not representative of any realistic operating scenario that exists in the unlicensed band, since real -time gaming device “button pushes” do not use the same transmission protocol used for text, which employs error correction and retransmission. Missed real-time button pushes cannot be equated to bit errors in a text data stream.

[...]

Conclusion

Based on the analysis above, the tests reported by Microsoft: a) are fundamentally flawed, b) provide no useful results, and c) cannot be relied on as valid demonstration of the impact of TLPS on the Xbox 360S in the real world. Further, the results cannot be generalized to apply to other gaming systems.

view all filings in the FCC Globalstar TLPS Proceeding 13-213 Docket at:

https://www.fcc.gov/ecfs/search/filings?proceedings_name=13-213&sort=date_disseminated,DESC