Attachment ORBCOMM comments sec

This document pretains to SAT-LOA-19941116-00088 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1994111600088_971852

RECEIVED ‘FEB 2 4 1995 Befofe the FEDERAL,ICOMMUNICATIONS COMMISSION COMMUNICATIONS COMMISSION xflashingtort)%n.c. 20554 FEDER%FF\OEOFTHESECRETARY —==*" FEB?' 6 \ copy mt com { SustiSunes Rusit masst Brasi Bd Bs limuce cmga meus) tarsst Resus: Auuaa In the Matter of Q:Q eA Ld FINAL ANALYSIS COMMUNICATIONS File No. 25—SAT—P/LA—95 SERVICES,. INC. <: *# i . 16#5 Application for Authority to Construct, Launch and Operate Non—Voice, Non—Geostationary Mobile—Satellite System in the 137=138 MHz, 148—150 MHz —and 400—401 MHz Bands COMMENTS OF ORBCOMM Orbital Communications Corporation ("ORBCOMM") hereby comments on the Application recently filed by FINAL ANALYSIS COMMUNICATIONS SERVICES, INC. ("Final Analysis”).y In that Application, Final Analysis requests authority to construct, launch and operate a 26 satellite system in the Non—Voice, Non— Geostationary ("NVNG") mobile satellite service. As discussed below, ORBCOMM urges the Commission not to grant the Final Analysis application. ORBCOMM was the first proponent and applicant for NVNG satellite services, having filed its petition for rulemaking and application in February 1990.4 ORBCOMM was one of three ¥ Public Notice, Report No. DS—1484, November 25, 1995. 2 Orbital Communications Corporation, RM No. 7334, Public Notice Report No. 1814, April 4, 1990; Orbital Communications Corporation, File No. 22—DSS—MP—90(20), Public Notice Report No. DS8—953, April 11, 1990 .

applicants being considered in the first NVNG satellite service processing round, and also became the first NVNG satellite service licensee.? ORBCOMM has also filed a request to modify its system by adding twelve satellites to its constellation (necessitating a slight increase in required spectrum) and moving its gateway uplink to the Transit Band (149.9—150.05 MHz2) .9 Final Analysis is an applicant in the second NVNG satellite service processing round, and its proposed system may impact the ORBCOMM licensed system (as well as the proposed ORBCOMM modification) . Thus, ORBCOMM has a significant interest in the Final Analysis Application. As an initial matter, ORBCOMM observes that Final Analysis is not financially qualified to become an NVNG satellite system licensee. Final Analysis estimates that it will be able U to construct, launch and operate for one year the initial two satellites in its constellation for only $6.2 million. ORBCOMM believes that Final Analysis has significantly underestimated its costs. Final Analysis shows a total system cost of some $140 million for construction and launch of its satellite constellation —— FAISAT 1la—26 (Figure VII—2A). Thus, on an average basis, it claims it will cost over $5 million per satellite to construct and launch its satellites. For the initial two satellites, Final Analysis is claiming that it will 3 Orbital Communications Corporation (Order and Authorization), 9 FCC Red 6476 (1994) . 4/ Orbital Communications Corporation, File No. 28—SAT—MP/ML—95, Report No. DS—1484, released November 25, 1994 .

cost dnly $3 .1 million per satellite for construction, launch and the first year of operations. If anything, ORBCOMM would expect that the costs of the initial two satellites would be disproportionately high, not disproportionately low. Indeed, ORBCOMM‘s actual experience has been that the per satellite cost for the initial two satellites is significantly higher than the per satellite cost of subsequent satellites in the constellation, particularly when the up—front development costs are properly attributed to the initial satellites." Thus, Final Analysis appears to have significantly underestimated its costs for the initial two satellites in its constellation . Even putting aside the Final Analysis understatement of the costs that it must demonstrate it has the ability to fund, Final Analysis has not demonstrated the resources to meet even the $6.2 million it asserts will be necessary. As of October 31, 1994, Final Analysis showed that its parent had current assets of approximately $700,000 and operating income of roughly $1.3 million, far less than the $6.2 million Final Analysis claims it will need." Final Analysis clearly cannot rely on the 3 Indeed, ORBCOMM found that its actual costs for the construction, launch and first year of operations for the initial two satellites in its system was more than ten times Final Analysis‘ estimate of $6.2 million as the cost to construct, launch and operate for one year the initial two satellites in the Final Analysis system. 6/ ORBCOMM also is concerned with :— respect to the reliability of the financial information provided by Final Analysis. For example, Exhibit VII—2, which is an audited financial statement for Final Analysis, Inc., shows that for 1993, net income was $1,121,883; Exhibit VII—1, which is also an audited financial statement for Final Analysis, Inc., shows a net income for 1993 (continued...)

internal resources of its parent for financing, and Final Analysis has identified no other acceptable sources of funding. Thus, Final Analysis is not financially qualified to become an NVNG satellite system licensee. ORBCOMM also has concerns with the technical aspects of the Final Analysis proposed satellite system. In the 137—138 MHz band, Final Analysis apparently relied on an outdated frequency plan in selecting its downlinks." Final Analysis will cause interference to ORBCOMM because both systems would be using the 137.655—137.745 MHz band, and both will be operating right hand circularly polarized.?" Attachment 2 shows that both systems cannot operate co—frequency. In addition to Final Analysis‘ incompatibility with the licensed ORBCOMM system for the 137—138 MHz band, with respect to the 148—149.9 MHz band, ORBCOMM is concerned that Final Analysis‘ channel assignment proposal may not be effective in avoiding harmful interference, insofar as it has not indicated an intention to utilize a predictive algorithm for channel selection like ORBCOMM‘s Dynamic Channel Activity Assignment System ("DCAAS"). Moreover, because the user terminal will utilize Y (...continued) of $420,904. While this discrepancy may reflect the fact that the larger amount was intended to show 1994 part year income, mistakes of this sort call into question the accuracy of all of the information presented in the audited financial statements. 4 ORBCOMM‘s current frequency plan for the 137—138 MHz band (not taking into account its modification request) is attached as Exhibit 1 to these comments. & The problem is further exacerbated when considering ORBCOMM‘s request for a slight additional amount of downlink spectrum in its proposed modification, because there will be additional frequency overlaps.

linear polarization, the fact that Final Analysis proposes to operate cross—polarized with ORBCONMM will not impact intersystem sharing. Although some sharing of the upper portion of the 148— 149.9 MHz band for uplinks is possible, it will require careful use by, and coordination among, the different satellite systems to minimize risks of interference. Moreover, while ORBCOMM continues to believe that multiple ystems can coexist in the W uplink bands, ORBCOMM does not believe that all of the proposed second round applicants that requested use of the upper portion of the 148—149.9 MHz band, which includes Final Analysis, can be In addition, there are multiple applications for [ransit Band (149.9—150.05 MHz) for gateway uplinks, D and that limited amount of spectrum is inadgequate to fulfill all of the requests. In ‘sum, the Commission cannot possibly accommodate the needs of all of the second round NVNG satellite service applicants without an additional allocation of spectrum. The Commission is already studying the issue of an additional qglobal allocation of spectrum below 1 GHz for low— arth orbit satellite systems in the context of determining a U.S. position at the upcoming World Radiocommunication Conference ("wrC") .4 The apparent excess of demand for spectrum over the 2 Attachment 2 addresses the interference to the licensed ORBCOMM system from all of the different second round applications. In light of the substantial overlaps either with ORBCOMM or among the other second round applications, ORBCOMM does not believe that all of the proposed systems can co—exist. Preparation for International Telecommunication Union World Ragiocommunication Conference, IC Docket No. 94—31, FCC No. 95—36, released January 31, 19%95. Un

aVailable supply highlights the prematurity of the Commission‘s second NVNG satellite service processing round. The Commission cannot possibly seek to license additional systems without yet knowing how much spectrum is available. The Commission has not yet completed the initial processing round, and indeed to ORBCOMM‘s knowledge has not yet even established a U.S. position to take at the upcoming WRC with respect to an additional global allocation of spectrum below 1 GHz for low—Earth orbit satellite services. Thus, at the very least, ORBCOMM urges the Commission not to process the second round applications until these outstanding issues are resolved and can be factored into the second processing round. In sum, because Final Analysis is not financially qualified, and because the Final Analysis satellite system will likely cause harmful interference to the ORBCOMM system, ORBCOMM urges the Commission not to grant the Final Analysis application. Respectfully submitted, By ./&iifi/LNA?./j%%fi?&qu Albert! Halpfin Stephen L. Goodman Halprin, Temple & Goodman Suite 650 East Tower 1100 New York Avenue, N.W. Washington, D.C. 20005 (202) 371—9100 Counsel for Orbital Communications Corporation Dated: February 24, 1995

Attachment 1 ORBCOMM Revised Frequency Plan Table 1 lists the revised frequency and polerization plan for the ORBCOMM constellation. The plan is based on keeping the ORBCOMM downlinks on the outer edges of the primary alloceted downlink bend to minimize the potential interference to Starsys. The LHCP downlink channels are grouped together to aid in obtaining a possible filtering solution to Starsys‘ interference problem. In addition to providing a benefit to Starsys, this frequency plen also maintains sufficient frequency separation from the Neational and International meteorological satellite bands to ensure that no interference occurs to these operations. Table 1 ORBCOMM Revised Frequency Plan Channel Center Required Polarization Number Frequency Bendwidth MHz kHz S—1 137.1909 e LHCP S—2 137.2050 15 LHCP S—3 137.2200 15 LHECP S4 137.2350 15 LECP 5.5 137.2500 15 LHCP S—5 137.2650 15 LECP S—7 137.2809 15 LHECP S—8 137.2950 15 LHCP S—9 137.3100 15 LHCP $—10 137.3825 15 RECP S11 137.3975 15 RHCP S—12 137.6625 15 RHCP S—13 137.67735 15 RHCP <§A14 137.6925 15 RHCP §—415 137.7075 15 RHCP S—16 137.7225 15 RHCP s SA7 137.7375 15 RHCP S—18 137.8050 15 RECP Gatewey 137.5600 50 RHCP mr

Attachment 2 Sharing Analysis 1. Introduction In this section, the interference levels into ORBCOMM receivers from the six second round applicants are calculated (Tables A2—1 and A2—2) based on link budgets presented in the ORBRCOMM Amended Application. 2. Approach and Assumptions A performance analysis, shownin the following tables, was conducted to determine received carrier power levels and power margins in the ORBCOMM system in the presents of co—channel interference from carriers of the second round applicants. A static analysis was completed for each proposed system wherein the carrier—to—interference ratio was calculated. Interference to ORBCOMM was analyzed for both interference to the gateway links and interference to the subscriberlink. Specifically, this includes: — interference from the proposed gateway of a second round applicant to the ORBCOMM gateway uplink — interference from the proposed subscriber to the ORBCOMM subscriber uplink, — interference from the proposed gateway downlink to the ORBCOMM gateway downlink, and — interference from the proposed subscriber downlink to the ORBCOMM subscriber downlink. In all but one of the scenarios, the C/I ratio was either negative or low enough to make the link useless. The exception that produced a positive ratio was where the interfere used CDMA modulation. The results are presented in Tables A2—1 and A2—2. Three inputs bear special mention: the antenna gain, elevation angle of interferor relative to the ORBCOMM receiver, and how the difference in bandwidths was handled. The antenna gains were taken from the applicant‘s link budgets and any antenna patterns that were available. The assumed values are given in Table A2—3. In general, near maximum gains were used. The antenna gain is, of course, related to the angle of elevation. In most cases the antenna gain probably does not vary, with changes in elevation angle, as fast as the free space loss, consequently, the angle of elevation can cause a large difference in the amount of interference. In general, the elevation angle on the interfering signal path was assumed to be 60°. This was an attempt to obtain a compromise between a worst case scenario of the rare case of a near—direct fly over and a limb pass. No excess path loss was added into the interfering signal‘s path.

Account was taken of the different interfering and desired signal bandwidths of the systems with the use of a bandwidth factor. This factor assumes that if the bandwidth of the interferoris less than the ORBCOMM bandwidth, then the power total power of a single interferon is received. Consequently, if the interfering bandwidth is larger then that of the ORBCOMM link than only a portions of the interfering poweris received. AZ— b?

TABLE A2—1 DOWNLINK ANALYSIS 137—138 MHz Performance Factor Satellite System CTA VITA E—SAT Mobile Fixed Field Field— DCC Remote Remote— Gateway Gateway Modulation type OQPSK FSK FSK FSK CDMA CDMA CDMA Data rate (kbps) 19.2 38.4/19.2 9.6 9.6 1041 ‘1 1 _signal bandwidihb (kHz) 165.4 65/38.4 19.2 19.2 Polarization RHC & RHC RHC RHC LHC LHC Transmilter output power 13.98 7.00 7.00 7.00 3.00 3.00 3.00 (GBW) Transmitter Line Losses 0 0 0 0 0.5 0.5 0.5 (dB) Transmitter antenna gain 4.9 0 0 0 1.2 1.2 1.2 (dBi) Transmitter ERP (dBW) 18.88 7.00 7.00 7.00 3.70 3.70 3.70 Earth Station Antenna 55 60 60 60 60 60 60 Elevation Anale Satellite Altitude (km) 1000 500 $00 800 1262 2 1262 Free space loss (dB) 136.7 134.4 134.4 134.4 138.3 138.3 Excess path loss incl fading, 0 0 0 0 0 0 rain, etc. (dB) Receiver antenna sain (dBi) —4 ~4 —4 15 —4 ~4 15 Receiver Line Loss (dB) 0 0 0 0 0 0 0 Polarization mismatch loss 0 0 0— 0 0 0 0 (dB) : Received signal power —121.8 —~131.4 ~131.4 —112.4 —138.6 —138.6 —119.6 (GBW) Transmitted Bandwidth 16.4 38.4 19.2 19.2 1041 1000 1000 (kHz) Receiver Bandwidth (kHz) 4.8 57.6 4.8 57.6 57.6 4, 57.6 Energy in receiver ~127.2 —129.6 ~137.4 —107.6 —151.2 ~161.8 —132.0 bandwidth {(dB W) Receiver system noise 724 955 724 724 955 724 724 temperature (K) Receiver noise spectral 200 —198.8 ~200 —200 —198.8 —200 200 density (dBW/Hz) ORBCOMM Camer ~143.8 ~127.8 ~143.8 —127.8 ~127.8 —143.8 —127.8 Power! Received Interference ~127.1 —129.6 —~137.4 —107.6 —148.1 ~159.4 —131.9 Power C/A —~16.7 1.8 —6.4 —20.2 20.3 15.6 4.1 1 Based on ORBCOMM Amended Application Link Budgets AZ—3

TABLE A2—1 (con‘t) DOWNLINK ANALYSIS 137—138 MHz Downlink Analysis — 137—138 MHz Satellite System Final Analysis LEO—ONE RT / MT Transceiver Performance Factor Modulation type OQPSK/GMSK Data rate (kbps) 9.6 24 signal bandwidth (kHz) 14.4 19.1 Polarization RHC Transmitter output power (dBW) 10.00 14.00 Transmission Line Losses (dB) 0.2 0 Transmitter antenna eain (dBi) —1 0 Transmitter EIRP (dBW) 8.80 14.00 Earth Station Antenna Elevation Angle 60 60 Satellite Altitude (km) 1000 950 Free space loss (dB) 136.3 135.9 Excess path loss incl fading, rain, etc. (dB) 0 0 Receiver antenna gain (dBi) —4 ~4 Receiver Line Loss (dB) 0 0 Polarization mismatch loss (dB) 0 0 Received simmal power (dBW) ~131.5 —125.9 Transmitted Bandwidth (kHz) 14.4 19.1 Receiver Bandwidth (kHz) 4.8 4.8 Power in receiver bandwidth_(dBW) 136.3 ~131.9 Receiver system noise temperature (K) 724 724 Receiver noise spectral density (dBW/Hz) —200 —200 ORBCOMM Carrier Power ~143.8 ~142.8 Received Interference Power —136.3 —~131.9 CA ~7.5 —10.9

TABLE A2—2 UPLINK ANALYSIS 148 —150.05 MHz Performance Factor Satellite System CTA VITA E—SAT Gatewy Mobile Fixed Field DCC Remote Modulation type OQPSK OQPSK FSK FSK CDMA CDMA Data rate (kbps) 50 2.4 — 4.8 19.2 9.6 1 0.1 signal bandwidth (kHz) 42.8 4.1/2.1 38.4 19.2 Polarization RHC Vertical RHC RHC RHC RHC Transmitter output power 10.0 7.0 26.6 16.6 7.0 7.0 (dBW) Transmitter Line Losses (dB) 0 0 0 0 0 0 Transmitter antenna gain (dBi) 16.3 —0.7 0 0 11 2 Transmitter EIRP (dBW) 26.3 6.3 26.6 16.6 18.0 9.0 Earth Station Antenna Elevation 89 60 60 60 60 60 Angle Receiver Altitude (km) 775 775 775 775 775 715 Free space loss (dB) 133.8 134.8 134.1 134.1 134.8 134.8 Excess path loss incl fading, 0 0 0 0 0 0 rain, etc. (dB) Receiver antenna gain (dBi) 1.0 3.6 1.0 3.6 1.0 3.6 Receiver Line Loss (dB) —1.4 ~2.3 ~1.4 —2.3 —1.4 2.3 Polarization mismatch loss (dB) 0 0 0 0 0 0 Received signal power (dBW) —103.9 —125.0 ~104.0 —114.0 —113.3 —122.3 Transmitted Bandwidth (kHz) 42.8 2.1 38.4 19.2 1000 1000 Receiver Bandwidth (kHz) 57.6 2.4 57.6 2. 4 57.6 2.4 Power in receiver bandwidth —103.9 —127.2 ~107.9 —123.0 ~125.7 ~148.5 (dBW) Receiver system noise 1950 537 1950 537 1950 537 temperature (K) Receiver noise spectral density —195.7 —201.3 —195.7 201.3 —195.7 —201.3 (dGBW/Hz) ORBCOMM Carrier Power —112.0 ~148.6 —112.0 —148.6 ~112.0 —148.6 Received Interference Power —103.9 —127.2 —~107.9 ~123.0 —125.7 ~148.5 C/AI —8.1 —21.4 A4.1 —24.9 12.7 0.6

TABLE A2—2 (con‘t) UPLINK ANALYSIS 148 —150.05 MHz Performance Factor Satellite System Final Analysis GE Americom LEO—ONE GS RT / MT DCC Ground Gateway Mobile Modulation type OQPSK OQPSEK/G GMSK GMSK OQPSK OQPSK MSK Data rate (kbps) 54 19.2 /9.6 9.6 2.4 50 9.6 signal bandwidth (kHz) 36 14.4 42.8 8.2 Polarization RHC Linear RHC Vertical Transmitter output power (dBW) 13.00 10.00 14.77 10.00 0.79 8.45 Transmitter Line Losses (dB) 1 0.2 0 0 0 0 Transmitter antenna gain (dBi) 10 0 10 0 16 0 Transmitter EIRP (dBW) 22.00 9.80 24.77 10.00 16.79 8.45 Earth Station Antenna Elevation 60 60 60 60 60 60 Angle Receiver Altitude (km) 775 775 775 775 775 775 Free space loss (dB) 134.8 134.8 134.8 134.8 134.8 134.8 Excess path loss incl fading, 0 0 0 0 0 0 rain, etc. (dB) Receiver antenna gain (dBi) 1.0 3.6 1.0 3.6 1.0 3.6 Receiver Line Loss (dB) ~1.4 ~2.3 ~1.4 ~2.3 ~1.4 2.3 Polarization mismatch loss (dB) 0 0 0 0 0 0 Received signal power (dBW) —113.2 —123.7 —110.4 —123.5 —118.4 —125.1 Transmitted Bandwidth (kHz) 36 14.4 13.2 7.8 42.8 8.2 Receiver Bandwidth (kHz) 57.6 2.4 57.6 2.4 57.6 2.4 Energy in receiver bandwidth —~113.2 —131.5 —110.4 —128.6 ~118.4 —130.1 (dBW) Receiver system noise 1950 537 1950 537 1950 537 temperature (K) Receiver Noise density —195.7 —201.3 —195.7 —201.3 —~195.7 —201.3 (dBW/Hz) ORBCOMM Carrier Power ~112.0 —148.6 112.0 —148.6 —112.0 —148.6 Received Interference Power ~113.2 ~131.5 ~110.4 —128.6 ~118.4 ~130.4 CA —~1.2 —17.1 —1.6 —20.0 6.4 —18.2 A2—6

TABLE A2—3 — ASSUMED ANTENNA PARAMETERS USED IN THE ANALYSIS Uplink Antenna Type Antenna Gain Antenna dBi Pattern CTA Gatewa dish 17/16.3 Subscriber — 0.7 Vitasat Gateway Yaci/helix 14 trackin Subscriber fixed 0 2.5 Gatewa dish Subscriber omni omni Final Analysis Gatewa Subscriber GE American Gatewa steerable Subscriber hemisph. Gatewa dish trackin Subscriber omni max @ 0_ null @ 90 Downlink Antenna Type Antenna Gain (dBi) Antenna Pattern CTA Subscriber quadrifilar 4.9 hemisp. 1 @ nadir 4.9 @ 58_ VITA Fixed 3 omni within 1 to 2 dB Field 3 omani E—SAT DCC dish 1.2 Remote 1.2 Final Analysis Subscriber 3 3 dBi @ 5_ —9.5 dBi @ nadir LEO—ONE Subscriber 5.7 dBi 5.17 @ 60_

Engineering Certificate I hereby certify that I am the technically qualified person responsible for preparation of the engineering information contained in this submission, and that I am familiar with Part 25 of the Commussion‘s Rules, that I have reviewed the engineering information contained in this submission and that it is complete and accurate to the best of my knowledge. Dated this 24th day of February, 1995 _z> Paul A. Locke Manager, Space Segment Engineering Orbital Communications Corporation

CERTIFICATE OF SERVICE I, Katherine H. Rasdorf, hereby certify that the foregoing ORBCOMM Comments on the second processing round applications was served by first—class mail, postage prepaid, this 24th day of February, 1995 on the following persons: Chairman Reed Hundt* Commissioner James H. Quello* Federal Communications Commission Federal Communications Commission 1919 M Street, N.W., Room 814 1919 M Street, N.W., Room 802 Washington, D.C. 20554 Washington, D.C. 20554 Commissioner Andrew C. Barrett* Commissioner Rachelle B. Chong* Federal Communications Commission Federal Communications Commission 1919 M Street, N.W., Room 826 1919 M Street, N.W., Room 844 Washington, D.C. 20554 Washington, D.C. 20554 Commissioner Susan Ness* Karen Brinkman, Special Assistant* Federal Communications Commission Office of the Chairman 1919 M Street, N.W. Federal Communications Commission Room 832 ‘ 1919 M Street, N.W. Washington, D.C. 20554 Room 814 Washington, D.C. 20554 Tom Tycz* Cecily C. Holiday* Federal Communications Commission Federal Communications Commission 2000 M Street, N.W. 2000 M Street, N.W. Room 811 Room 520 Washington, D.C. 20554 Washington, D.C. 20554 Kristi Kendall, Esq.* Fern J. Jarmulnek* Satellite Radio Branch Satellite Radio Branch Federal Communications Commission Federal Communications Commission 2000 M Street, N.W., Room 517 2000 M Street, N.W. Washington, D.C. 20554 Room 518 Washington, D.C. 20554

Mr. Scott Blake Harris* Jill Abeshouse Stern Chief, International Bureau CTA INCORPORATED Federal Communications Commission Shaw, Pittman, Potts, & Trowbridge 2000 M Street, N.W., Room 800 2300 N. Street, N.W., Second Floor Washington, D.C. 20554 Washington, D.C. 20037 Robert Mazer Raul R. Rodriguez, Esquire LEO ONE USA Corporation Starsys, Inc. Rosenman & Colin Leventhal, Senter & Lerman 1300 19th Street, N.W. 2000 K Street, N.W., Suite 600 Washington, D.C. 20036 Washington, D.C. 20006—1809 Henry Goldberg, Esq. Mr. Philip V. Otero Goldberg, Godles, Wiener & Wright Vice President & General Counsel 1229 Nineteenth Street, N.W. GE American Communications, Inc. Washington, D.C. 20036 Four Research Way Princeton, New Jersey 08540 E—Sat, Inc. Albert J. Catalano c/lo Leslie A. Taylor Ronald J. Jarvis Leslie Taylor Associates, Inc. Final Analysis Communications 6800 Carlynn Court Services, Inc. Bethesda, Maryland 20817—4301 Catalano & Jarvis, P.C. 1101 30th Street, N.W. Suite 300 Washington, D.C. 20007 Michael Ladino Joseph F. Sedlak General Counsel Volunteers in Technical Assistance CTA INCORPORATED 1600 Wilson Boulevard 6116 Executive Boulevard Suite 500 Suite 800 Arlington, VA 22209 Rockville, MD 20852 ow C Kat\herine H. Rasdorf * Hand Delivered


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