Planet Letter to FCC

OTHER submitted by Planet Labs Inc.

Planet Corrected Ownership Filing

2017-02-14

This document pretains to SAT-MOD-20150802-00053 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2015080200053_1186654

Hogan Lovells US LLP Columbia Square 555 Thirteenth Street, NW Washington, DC 20004 T +1 202 637 5600 F +1 202 637 5910 www.hoganlovells.com February 14, 2017 VIA ELECTRONIC FILING Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street N.W. Washington, DC 20554 Re: Planet Labs Inc., Call Sign S2912, IBFS File No. SAT-MOD-20150802-00053 Dear Ms. Dortch: Planet Labs Inc. (“Planet”) hereby submits this letter and attachment to correct errors in the ownership exhibit submitted with the above-referenced application on August 2, 2015. Specifically, William S. Marshall, Robert H. Schingler Jr., and Christopher R. Boshuizen, who are identified as officers and directors of Planet, were inadvertently omitted from the list of shareholders in the ownership exhibit, even though each had voting interests in Planet exceeding ten percent, as of the date of the August 2, 2015 filing.1 Also, in the ownership exhibit Draper Fisher Jurvetson should have been identified as having an approximately 16.3% equity interest (on a fully diluted basis) rather than an 18.13% voting interest. Attached is a corrected ownership exhibit. Please contact the undersigned if you have any questions. Sincerely, /s/ Tony Lin Tony Lin Counsel Tony.Lin@hoganlovells.com D 202-637-5795 Enclosure cc: Stephen Duall 1 The three individuals, who are co-founders of the company, were disclosed in the initial 2013 satellite application as shareholders having a greater than ten percent interest in the company. See Application of Planet Labs Inc., IBFS File No. SAT-LOA-20130626-00087 (filed June 26, 2013). Hogan Lovells US LLP is a limited liability partnership registered in the District of Columbia. “Hogan Lovells” is an international legal practice that includes Hogan Lovells US LLP and Hogan Lovells International LLP, with offices in: Alicante Amsterdam Baltimore Beijing Brussels Caracas Colorado Springs Denver Dubai Dusseldorf Frankfurt Hamburg Hanoi Ho Chi Minh City Hong Kong Houston Johannesburg London Los Angeles Luxembourg Madrid Mexico City Miami Milan Minneapolis Monterrey Moscow Munich New York Northern Virginia Paris Perth Philadelphia Rio de Janeiro Rome San Francisco São Paulo Shanghai Silicon Valley Singapore Sydney Tokyo Ulaanbaatar Warsaw Washington DC Associated offices: Budapest Jakarta Shanghai FTZ Zagreb. Business Service Centers: Johannesburg Louisville. Legal Service Center: Birmingham. For more information see www.hoganlovells.com

ATTACHMENT

EXHIBIT 40 Planet Labs Inc. License Application FCC Form 312 July 2015 (as corrected) INFORMATION CONCERNING SHAREHOLDERS, OFFICERS AND DIRECTORS Planet Labs Inc. (“Planet Labs”), formerly known as Cosmogia Inc. (“Cosmogia”), is a privately held corporation. The following individuals or corporations hold a 10 percent or more equity and/or voting interest in Planet Labs: Name Draper Fisher Jurvetson Address 2882 Sand Hill Road, Suite 150 Menlo Park, CA 94025 Citizenship or State of Incorporation California Percentage of Equity Interest (fully diluted) ~16.3% Name William S. Marshall Address 346 9th St. San Francisco, CA 94103 Citizenship or State of Incorporation United Kingdom Percentage of Voting Interest ~27.33% Name Robert H. Schingler, Jr. Address 346 9th St. San Francisco, CA 94103 Citizenship or State of Incorporation United States Percentage of Voting Interest ~27.33% Name Christopher R. Boshuizen Address 346 9th St. San Francisco, CA 94103 Citizenship or State of Incorporation United States Percentage of Voting Interest ~27.33% 1

EXHIBIT 40 Planet Labs Inc. License Application FCC Form 312 July 2015 (as corrected) The officers of Planet Labs are: Name Robert H. Schingler, Jr. Address 346 9th St. San Francisco, CA 94103 Name Christopher R. Boshuizen Address 346 9th St. San Francisco, CA 94103 Name William S. Marshall Address 346 9th St. San Francisco, CA 94103 Name Tom Barton Address 346 9th St. San Francisco, CA 94103 The directors of Planet Labs are: Robert H. Schingler, Jr. Christopher R. Boshuizen William S. Marshall Steve Jurvetson 2882 Sand Hill Road, Suite 150 Menlo Park, CA 94025 Zachary Bogue 665 3rd Street, Suite 150, San Francisco, CA 94107 2


Document Created: 2017-02-14 18:30:52
Document Modified: 2017-02-14 18:30:52
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