REPLY OF CTIA
CTIA hereby files this Reply to the Opposition and Response of The Boeing Company (“Boeing”) and the Opposition of the Satellite Industry Association (“SIA”) with respect to the above-captioned application.1 CTIA, with a number of other parties, sought denial of the Boeing Application to launch and operate a non-geostationary-satellite orbit (“NGSO”) satellite system providing fixed-satellite service (“FSS”) in the 37.5-42.5 GHz, 47.2-50.2 GHz, and 50.4-52.4 GHz frequency bands.2 CTIA argued that that the Boeing Application undermined the framework envisioned by the Commission for next-generation (“5G”) terrestrial mobile broadband networks; that Boeing’s litany of waiver requests effectively sought pre-judgment, by the International Bureau acting alone, of issues addressed to the full Commission in the ongoing Spectrum Frontiers proceeding; and that the Boeing Application failed to make any showing of consumer demand or otherwise justify the 10 gigahertz of bandwidth it seeks. The Boeing Opposition does not directly address any of the issues raised by CTIA. Instead, Boeing only addresses peripheral issues with little relevance to the core administrative and policy issues implicated by the Boeing Application. For these reasons, the Boeing Application should be denied.
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