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N.B. page/slide 14 in the Annual Meeting of Stockholders (May 16, 2017) presentation
Worldwide Spectrum Applications (Non-satellite uses)
Most Especially with respect to the ("under the radar") L & C Bands --
which have been devoid of "attention"/"possibilites"/"potential" (viz.:
for 5G development and IoT) -- as nearly all attention (i.e. value) been
primarily focused on just/only the S Band spectrum allocation/license !
http://www.globalstar.com/en/ir/docs/Annual_Meeting_of_Stockholders_5.15.17.pdf
Bloomberg: Globalstar Said to Work With Advisers to Explore Potential SaleCompany won FCC.
$GSAT $STRP $DISH #SpectrumIsKing Globalstar Said to Work With Advisers to Explore Potential SaleCompany won FCC.. pic.twitter.com/W7IzU54ufl
— David D. Tawil (@DavidDTawil) May 12, 2017
the parallels here are JUST UNCANNY, except GSAT's got WORLDWIDE HARMONIZED SPECTRUM!
http://www.wsj.com/articles/how-telecom-speculator-howard-jonas-made-billions-from-verizon-at-t-1494525703
Globalstar April 28, 2017 Burkenroad Conference Presentation
http://www.globalstar.com/en/ir/docs/Globalstar_Presentation_Burkenroad_Reports_FINAL.PDF
Odeon Thinks Softbank is the New Straight Path (STRP) Bidder; Pounds the Table on Globalstar (GSAT)
April 25, 2017 9:07 AM
Odeon analyst Jahanara Nissar believes Softbank is the new bidder for Straight Path Communications (NYSE: STRP), which she said "speaks to the value of Spectrum."
Commenting on why she thinks its Softbank, she notes:
1. For one, the bidder is “International”.
2. My thinking is that Softbank/S have strategized beyond TMUS – like many news articles have suggested and has its eyes on possibly becoming a significant consolidator of Spectrum. Sprint has a lot of 2.5Ghz (infact the most 2.5Ghz held by any US carrier) and 2.5Ghz is good for 5G and STRP’s spectrum is for 5G backhaul – like Lego its can all starts to fit together with STRP’s spectrum.
3. Also keep in mind that Masa has raised a $100B fund to acquire assets like spectrum and this falls squarely into that plan.
As a result of the bidding war for Straight Path, she is also" pounding the table" on Globalstar (NYSE: GSAT), citing:
1. Softbank has been rumored to be one of the parties talking to GSAT to provide dollars for the capital raise they are likely to do in the June time frame. if Softbank or another high quality strategic/financial player make a capital contribution it will be a needle mover for GSAT.
2. Also, GSAT has been absent from M&A conversations as it’s airwaves were not yet approved by the FCC – That is no longer the case. Players involved in the Broadcast Auction were barred from talking directly to each other for 1 year at least. That quiet period ends April 27th at 6PM! Any mention of GSAT should take the stock meaningfully higher with a 20% short Interest. (higher if you adjust for the CEO’s full ownership) – The squeeze could be painful!
3. Last night TMUS bragged that it now has Spectrum to cover “every single inch” in the US, leaving its competitors gaping. GSAT’s spectrum does not solve a carriers 5G problem but it certainly plays heavily into Small Cell Densification which helps 4G coverage. The unlimited plans have only just started to kick in and Spectrum & VZ”s LTE network has already slowed by 14%!
re: April 27th Quiet Period and What government agency imposed this quiet period, why did they do it, and who did it apply to?
see:
http://investorshub.advfn.com/boards/read_msg.aspx?message_id=130045103
INTERESTING: Apple Hires Top Google Satellite Executives for New Hardware Team
http://www.bloomberg.com/news/articles/2017-04-21/apple-hires-top-google-satellite-executives-for-new-hardware-team
Odeon GSAT Desk Note:
Odeon Desk Note - $GSAT #spectrumisking Timing has been everything on the name. We think it is important to own.. pic.twitter.com/NmbcleaM27
— David D. Tawil (@DavidDTawil) April 19, 2017
As FCC quiet period ends [April 27th], expect M&A talks to get LOUD
http://www.thestreet.com/slideshow/14086365/1/as-fcc-quiet-period-ends-expect-m-amp-a-talks-to-get-loud.html
Globalstar files license mod for TDLTE (w/generic parameters, no specific deployment plan)
Globalstar files license mod for TDLTE (w/generic parameters, no specific deployment plan) https://t.co/UZIFlnHKZM $GSAT
— Tim Farrar (@TMFAssociates) April 11, 2017
AT&T's Straight Path buy highlights value of high-band spectrum, analysts say
http://www.fiercewireless.com/wireless/at-t-s-straight-path-buy-highlights-value-high-band-spectrum-analysts
N.B. The Prohibited Communications Rule vis-a-vis Forward Auction Assignment Phase Has Concluded Announcement of 2017-03-30 13:06:10
#MoffettNathanson hosting a lunch meeting with Globalstar management in Boston on April 6th
#SpectrumIsking #CraigMoffett
#MoffettNathanson hosting a lunch meeting with Globalstar $GSAT management in Boston on April 6th #SpectrumIsking #CraigMoffett
— David D. Tawil (@DavidDTawil) March 28, 2017
Unofficial Satellite 2017 Notes from Summit Ridge Group (48 pages):
Executive Summary
Satellite 2017 made clear the industry is in the midst of massive change. Vertical integration, massively falling prices, reusable launch vehicles, digital satellite payloads, cheaper customer equipment, IoT, and 5G dominated discussions. While some of these had been discussed previously, it’s clear they have now descended upon the industry. Recent new events are likely drove the increased attention on data security issues.
There should be no more question about whether satellite pricing was stabilizing. Discussions abounded about how to lower pricing was needed in consumer markets to grow demand. There was widespread acknowledgement that satellite bandwidth price is falling more generally. Almost as if to drive in the point, Hughes ended any doubts by unveiling its new Jupiter service that halved pricing per unit of capacity.
In satellite manufacturing cost per unit of throughput is falling – new benchmark metric for new systems is $1 million per Gbps of throughput. Manufactures are scrambling meet increase customer expectations with software defined payloads, streamlined manufacturing processes etc. Debate about optimal HTS satellite life in the face of rapid evolution came to the forefront. Concerns that others in the value chain, including launch providers and ground equipment manufacturers, are not matching this level of cost/performance improvement.
Pressure to lower prices across the value chain may lead to increased vertical integration as the investments one area, particularly user terminals, disproportionally benefit service providers. Indeed, the two leaders in consumer broadband, ViaSat and Hughes are both vertically integrated. Other announcements including the Hughes/Panasonic Aviation/SES joint venture in aviation and the Intelsat investment in Kymeta were additional examples of vertical integration. This is marked change from the Euroconsult conference this fall. At that time, the notion of investment in customer applications and hardware as being necessary to stimulate demand to fill HTS capacity was only barely breached. Now it has spilled into the open.
Speaking of Intelsat, no one seems to understand how OneWeb benefits from the Intelsat match except that it helps SoftBank that has significant direct and indirect control over OneWeb. Support on the regulatory front does not make sense. But the Intelsat/OneWeb merger was not an isolated deal. Telesat is also moving towards launching a LEO constellation and SES has already deployed its O3B system. In general, the synergies between GEO and LEO operators are not clear. Should FSS operators become more vertically integrated with their distribution partners, this could change. Perhaps it’s only a matter of time?
[...]
http://summitridgegroup.com/unofficial-satellite-2017-notes-summit-ridge-group/
Charlie Ergen on DISH call asked about GSAT Here is what he had to say:
see
#LicensedSpectrumIsKing Charlie #Ergen on $DISH call was asked about $GSAT. He is what he had to say:"Not as.. pic.twitter.com/LxionNBO0M
— David D. Tawil (@DavidDTawil) March 10, 2017
PLEASE N.B. that any deal making partner discussions are also most likely influenced -- and thus are being held inabeyance/mitigated -- by/until the eventual conclusion of the 600 MHz Broadcast Incentive Auction -- the finishing of which will dictate the lifting of the anti-collusion period "cone of silence" that presently prevails, viz.:
http://www.fcc.gov/document/auction-1000-prohibited-communication-guidance
The Best "Guess" is we not likely to find out who won their respective spectrums until mid-April and this will likely extend the anti-collusion period towards the end of April...
ERGO/in the meantime, just gotta continue to sit tight/be patient (as this LONG shareholder is/has been/continues to be) and let "nature continue take its inevitable course".
A World Without Wi-Fi Looks Possible as Unlimited Plans Rise
http://www.bloomberg.com/news/articles/2017-03-09/a-world-without-wi-fi-looks-possible-as-unlimited-plans-catch-on
$GSAT Markit Short Interest at 98.51mm ... borrow rates at 80%-90%
$GSAT Markit Short Interest at 98.51mm ... borrow rates at 80%-90% #SpectrumIsKing
— David D. Tawil (@DavidDTawil) February 9, 2017
MANY THANKS for these Most Relevant/Highly Informative FB GSAT Investors Groups postings/transplantings -- PLEASE keep 'em coming! :D
Globalstar Overview January 2017 Presentation (32 page PDF)
http://www.globalstar.com/en/ir/docs/GlobalstarOverviewPresentation.pdf
via
http://globalstar.com/spectrum
Globalstar to Reconfigure its NGSO MSS space stations on or shortly after January 22, 2017
http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Number/%3D/SESMOD2017011200029&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number
for the details: under "Document Menu" on the above, click on [ATTACHMENTS MENU] and then select "Attachment Question 43" which will then display a 10 page PDF document that explains the Reconfiguration:
NOTIFICATION OF REPOSITIONING OF NGSO SPACE STATIONS
at http://licensing.fcc.gov/myibfs/download.do?attachment_key=1164402
be sure to view EXHIBIT B at the end -- showing a diagram/picture of the "Representative 24-Satellite Constellation Footprint with user elevation mask at 5 degrees above the horizon"
GSAT "Markit Short Interest currently at 85.08mm shares. Borrow getting tighter. My buddy just yanked 10mm shrs #ShortsHaveNoMoreBullets"
$GSAT Markit Short Interest currently at 85.08mm shares. Borrow getting tighter. My buddy just yanked 10mm shrs #ShortsHaveNoMoreBullets
— David D. Tawil (@DavidDTawil) January 10, 2017
WRONG! vis-a-vis "19,997 more free connections on the way..."
clearly you have NOT READ The R&O, viz. [excerpt from page 26]:
fcc.gov/document/report-and-order-approving-revised-globalstar-proposal
Commissioner's Pai and O'Rielly's statements can be also be found/read/downloaded here.
WRONG! Thermo, NOT Terrapin, is CEO's Company.
http://www.thermoco.com
http://www.thermocapitalpartners.com
[...]
Prospectus Supplement No. 7: 15,234,283 shares offered to Terrapin
GLOBALSTAR, INC. 15,234,283 SHARES OF COMMON STOCK
This Prospectus Supplement No. 7 supplements the prospectus supplement No. 6 dated November 30, 2016, as supplemented by the prospectus supplement No. 5 dated October 24, 2016, as supplemented by the prospectus supplement No. 4 dated June 28, 2016, as supplemented by the prospectus supplement No. 3 dated February 26, 2016 and the prospectus supplement No. 2 dated August 31, 2015 and the prospectus supplement No. 1 dated August 10, 2015. This prospectus supplement should be read in conjunction with the prospectus and the previous prospectus supplements, and is qualified in its entirety by reference to the prospectus and the previous prospectus supplements, except to the extent that the information presented herein supersedes the information contained in the prospectus or the previous prospectus supplement. This Prospectus Supplement No. 7 is not complete without, and may not be delivered or utilized, except in connection with the prospectus, including any amendments or supplements thereto.
Unless the context otherwise indicates, references in this prospectus supplement to the “accompanying prospectus” refer to the prospectus dated July 30, 2015, as supplemented by the prospectus supplement dated August 10, 2016, the prospectus supplement No. 2 dated August 31, 2015, the prospectus supplement No. 3 dated February 26, 2016, the prospectus supplement No. 4 dated June 28, 2016, the prospectus supplement No 5 dated October 24, 2016 and the prospectus supplement No. 6 dated November 30, 2016.
Pursuant to this prospectus supplement and the accompanying prospectus, we are offering 15,234,283 shares of our voting common stock to Terrapin Opportunity, L.P., or Terrapin, pursuant to a Common Stock Purchase Agreement between us and Terrapin dated as of August 7, 2015, which we refer to as the Purchase Agreement, at a price of approximately $0.85 per share. The total purchase price for the shares is $13.0 million. We will receive net proceeds from the sale of these shares of approximately $12.95 million, after deducting our estimated offering expenses of approximately $50,000 in connection with this offering.
This prospectus supplement and the accompanying prospectus also cover the resale of these shares by Terrapin to the public. Terrapin is an “underwriter” within the meaning of Section 2(a)(11) of the Securities Act of 1933, as amended, or the Securities Act, and any profits on the sales of shares of our common stock by Terrapin and any discounts, commissions or concessions received by Terrapin may be deemed to be underwriting discounts and commissions under the Securities Act.
We issued these shares to Terrapin on or about December 19, 2016. Our common stock is traded on the NYSE MKT under the trading symbol “GSAT.” On December 20, 2016, the last reported sales price for our common stock was $1.43 per share...SNIP
https://www.sec.gov/Archives/edgar/data/1366868/000136686816000203/terrapinprospectussuppleme.htm
Cowen Sees Another 3x Upside in GlobalStar (GSAT) if TLPS Proposal is Approved
http://www.streetinsider.com/Analyst+Comments/Cowen+Sees+Another+3x+Upside+in+GlobalStar+%28GSAT%29+if+TLPS+Proposal+is+Approved/12354959.html
Globalstar back in play as FCC considers revised proposal
http://www.fiercewireless.com/tech/globalstar-back-play-as-fcc-considers-revised-proposal
AWESOME ***MUST READ*** Kevin G. Rooney November 25, 2016 TLPS Proceeding (9 page) Ex Parte "speaking Truth to power" filing (posted 11/28/16):
https://ecfsapi.fcc.gov/file/112534618325/Ex%20Parte%2013-213%20Nov%2025.pdf
https://www.fcc.gov/ecfs/search/filings?proceedings_name=13-213&sort=date_disseminated,DESC
Ex Parte vis-a-vis November 2, 3 & 4, 2016 FCC meetings (posted 11/7/16)
LAWLER, METZGER, KEENEY & LOGAN, LLC
1717 K STREET, NW SUITE 1075 WASHINGTON, D.C. 20006
REGINA M. KEENEY
PHONE (202) 777-7700 FACSIMILE (202) 777-7763
November 4, 2016
Via Electronic Filing
Marlene H. Dortch, Secretary
Federal Communications Commission
445 Twelfth Street, SW
Washington, DC 20554
Re: Ex Parte Notice: Terrestrial Use of the 2473-2495 MHz Band for Low-Power Mobile Broadband Networks – IB Docket No. 13-213
Dear Ms. Dortch:
On November 2, 2016, L. Barbee Ponder IV, General Counsel & Vice President, Regulatory Affairs, for Globalstar, Inc. (“Globalstar”), Tim Taylor, Vice President of Finance, Business Operations & Strategy, for Globalstar, and I met with Edward “Smitty” Smith, Legal Advisor to Chairman Tom Wheeler, regarding the Commission’s proposed rules in the above- captioned proceeding.1
On November 3, 2016, I spoke by telephone separately with Mr. Smith and Julius Knapp, Chief Engineer of the Office of Engineering and Technology, regarding this proceeding.
On November 4, 2016, Mr. Ponder, Mr. Taylor, Steve Berman of Lawler, Metzger, Keeney & Logan, LLC, and I spoke by telephone with Mr. Knapp regarding this rulemaking. During this meeting and these calls, Globalstar’s representatives discussed ways to reach an expeditious outcome in this rulemaking.
If the Commission promptly adopts appropriate rules in this proceeding, such action will serve the public interest by enabling an innovative new broadband service at 2.4 GHz and adding significantly to the nation’s broadband spectrum inventory.
____________________
1 Terrestrial Use of the 2473-2495 MHz Band for Low-Power Mobile Broadband Networks; Amendments to Rules for the Ancillary Terrestrial Component of Mobile Satellite Service Systems, Notice of Proposed Rulemaking, 28 FCC Rcd 15351 (2013).
Ms. Marlene Dortch November 4, 2016 Page 2
Pursuant to section 1.1206(b)(2) of the Commission’s rules, 47 C.F.R. § 1.1206(b)(2), this ex parte notification is being filed electronically for inclusion in the public record of the above-referenced proceeding.
Respectfully submitted,
/s/ Regina M. Keeney
Regina M. Keeney
cc: Edward “Smitty” Smith
Julius Knapp
https://ecfsapi.fcc.gov/file/1104775705042/Globalstar%20Ex%20Parte%20Notice%20110416.pdf
https://www.fcc.gov/ecfs/search/filings?proceedings_name=13-213&sort=date_disseminated,DESC
CC excerpts vis-a-vis TLPS & liquidity issues:
Jay Monroe - Chairman & CEO
... At the outset of today's call, I'd like to provide an update on the FCC proceeding. As most of you fully understand and appreciate, a successful approval remains our number one priority and together with our team of advisors, we are unrelentingly focused on this process daily. Recently, we submitted a full-term Ex Parte, responding to the latest interference report filed by Microsoft in September. I encourage everyone to read our technical report carefully. It fully details the flawed methodology used which renders Microsoft's conclusions completely unreliable.
As explained in our response, the opposition's methodology included an extreme test set up and technical parameters that would never occur in any real-world deployment. On the contrary, when interference testing is conducted using accurate real-world assumptions as we did and we submitted on our Ex Parte and has been confirmed in multiple tests and various environments in the past which are also on the record, it is conclusive that TLPS peacefully coexist with unlicensed operations. We trust that the commission will look past these absurd tests from those with obvious competitive interest and will instead rely on the credible technical work conducted by respected engineers which over the years of analysis and tests has consistently proven that TLPS poses no risk whatsoever to such services as Bluetooth and 2.4 Wi-Fi systems.
The commission should be commended for continuing to move the order forward without being paralyzed by engineering studies submitted by incumbent operators with purely competitive motivations. There has been significant activity on our part recently and for those checking the FCC website [ https://www.fcc.gov/ecfs/search/filings?proceedings_name=13-213&sort=date_disseminated,DESC ], you can expect new Ex Partes to appear shortly. We are committed to working every day to develop a compromise that provides the company with a favorable majority FCC vote resulting in a business model that will produce deployments that intensively uses spectrum for the benefit of all consumers.
There is still work to be done for sure, but I can tell you that neither I, nor our management team are quitters and we will continue to work directly with all involved parties to complete this process. TLPS is rooted in good policy that can provide material benefits to American consumers by increasing broadband options. We are not in contradiction with, but rather in sync with good public policy and are therefore confident that we will forge a solution leading to a successful outcome.
I regret that we will not be able to take questions on the proceeding during the Q&A portion of the call given the sensitive time in the process, but I hope my statements on this subject this afternoon are helpful to understanding the current events. When the proceeding finishes and in ordered issues, we look forward to holding a separate call dedicated to the approval's implications for our business...
Rebecca Clary - VP & CFO
... Although adjusted EBITDA has continued to increase significantly when compared to the prior year, we do not currently project that it will reach the levels required by our facility agreements or in the next 12 months without revenue contribution from sources incremental to our current business operations. However, our facility agreement provide for mechanism referred to as equity share of contributions which permits us to use amounts raised from issuing equity and certain covenant calculation, allowing us to maintain compliance and periods when adjusted EBITDA falls below the required level.
As of September 30, 2016, we were in compliance with all covenants and utilizing the equity share mechanism, we believe we will maintain compliance by using funds from our current Terrapin agreement and other sources not yet fully arranged. Our current sources of liquidity include cash flows from operations, a cash balance of just under $13 million and availability under our common stock purchase agreement with Terrapin of $31.5 million. A longer term source of liquidity includes the $38 million we currently have held in a debt service reserve account which can only be used for principal and interest payments due under the facility.
Projected contractual obligations over the next 12 months consist primarily of debt service payments due in December 2016 and June 2017. These amounts include principal payments due under the facility agreement of $38 million and interest payments due under the facility in subordinated notes of $21 million. We also have contractual obligations related to our second generation ground infrastructure and other ground-related cash obligation, which we expect will be approximately $7 million in aggregates during the next 12 months. We expect to pay half of this during the fourth quarter upon final acceptance of the work completed by Hughes and Ericsson...
http://seekingalpha.com/article/4019348-globalstars-gsat-ceo-jay-monroe-q3-2016-results-earnings-call-transcript?part=single
the 10-Q Quarterly Report -- with all its exhibits -- can be viewed on or downloaded from the SEC's website at:
https://www.sec.gov/Archives/edgar/data/1366868/000136686816000193/0001366868-16-000193-index.htm
CC audio at https://earningscast.com/GSAT/20161103 starts ~5 mins in.
there were NO Questions asked during the Q&A part of the call.
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
FierceWirelessTech: Globalstar TLPS proposal still in limbo at FCC
http://www.fiercewireless.com/tech/globalstar-tlps-proposal-still-limbo-at-fcc
September 30, 2016 Globalstar Ex Parte filing vis-a-vis FCC meeting (posted 10/3/16)
LAWLER, METZGER, KEENEY & LOGAN, LLC
1717 K STREET, NW SUITE 1075 WASHINGTON, D.C. 20006
REGINA M. KEENEY
PHONE (202) 777-7700 FACSIMILE (202) 777-7763
September 30, 2016
Via Electronic Filing
Marlene H. Dortch, Secretary
Federal Communications Commission
445 Twelfth Street, SW
Washington, DC 20554
Re: Ex Parte Notice: Terrestrial Use of the 2473-2495 MHz Band for Low-Power Mobile Broadband Networks – IB Docket No. 13-213
Dear Ms. Dortch:
On September 28, 2016, L. Barbee Ponder IV, General Counsel & Vice President, Regulatory Affairs, for Globalstar, Inc. (“Globalstar”), Tim Taylor, Vice President of Finance, Business Operations & Strategy, for Globalstar, Dennis Roberson, President and Chief Executive Officer of Roberson and Associates, LLC, John Dooley of Jarvinian, and I spoke by telephone with Julius Knapp, Chief Engineer of the Commission’s Office of Engineering & Technology, regarding the Commission’s proposed rules in the above-captioned proceeding.1 On this call, we urged that the Commission expeditiously adopt rules in this proceeding to authorize an innovative broadband service, Terrestrial Low Power Service (“TLPS”). Such rules would serve the public interest by adding 22 megahertz to the nation’s broadband spectrum inventory and alleviating congestion in the 2.4 GHz ISM band.
During the call, we discussed Globalstar’s business plans and deployment approach for TLPS, and also addressed a potential framework to permit third parties to obtain opportunistic use of Channel 14 where Globalstar has not deployed TLPS while ensuring that licensed and unlicensed services are not disrupted. This framework should balance carefully the concerns raised by competitors and other parties with the Commission’s goals of encouraging investment, innovation, competition, and efficient use of scarce spectrum.
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1 Terrestrial Use of the 2473-2495 MHz Band for Low-Power Mobile Broadband Networks; Amendments to Rules for the Ancillary Terrestrial Component of Mobile Satellite Service Systems, Notice of Proposed Rulemaking, 28 FCC Rcd 15351 (2013).
Ms. Marlene Dortch September 30, 2016 Page 2
Pursuant to section 1.1206(b)(2) of the Commission’s rules, 47 C.F.R. § 1.1206(b)(2), this ex parte notification is being filed electronically for inclusion in the public record of the above-referenced proceeding.
Respectfully submitted,
/s/ Regina M. Keeney
Regina M. Keeney
cc: Julius Knapp
https://ecfsapi.fcc.gov/file/109302904613307/Globalstar%20Ex%20Parte%20093016.pdf
https://www.fcc.gov/ecfs/search/filings?proceedings_name=13-213&sort=date_disseminated,DESC
Bloomberg: Satellite Industry Is All at Sea
"Satellite operator Inmarsat was founded 40 years ago to let ships communicate with land so rescuers could aid sailors. The maritime business, which still provides half of sales and operating profit, set it apart from rivals who were focused on broadcasting and broadband. As a result, the British company had lower margins than peers but was insulated from the competition and macro-economic storms that buffeted others.
Now, amid the tumult of a capacity glut in the sector, even Inmarsat is getting dragged under water. Advances in high-throughput satellites are bringing more bandwidth online than ever. This oversupply, which might triple capacity by 2020, will pressurize sales and margins for all the big satellite players. Since Eutelsat issued a profit warning in May, investors have punished the sector.
That even Inmarsat, with its one-time maritime fortress, is getting hit shows how far the contagion has spread. It also highlights a less understood change in the satellite business: how the capacity boom obliterates the once clear distinctions between the different satellite companies and the markets in which they operate.
Before, there was clear separation between fixed satellite service providers and mobile. Inmarsat dominated the latter while SES, Eutelsat and Intelsat ruled in fixed. Now, in the scramble to sell new capacity, the different players all encroach on each other's turf"...SNIP
... Blurred Lines...
[...]
... Choppy Waters...
for the rest:
http://bloomberg.com/gadfly/articles/2016-09-26/trouble-at-sea-for-commercial-satellites
notes from the Euroconsult “World Satellite Business Week” conference held in Paris from September 12th to 15th by Armand Musey:
http://summitridgegroup.com/armands-notes-euroconsult-2016-conference/
SpaceX fingers helium as cause of Falcon 9 rocket explosion
a credible supposition as to the cause -- explained in laymen's terms: http://newatlas.com/spacex-falcon-9-explosion-helium/45594/
ERGO, would expect A Very Material Effect (delay) on how soon IRDM's NEXT constellation can be alofted.