Inmarsat PDR Letter.

SUPPLEMENT submitted by ISAT US Inc.

Supplement

2010-07-27

This document pretains to SES-ASG-20100107-00015 for Assignment on a Satellite Earth Station filing.

IBFS_SESASG2010010700015_831515

555 Eleventh Street, N.W., Suite 1000 Washington, D.C. 20004-1304 Tel: +1.202.637.2200 Fax: +1.202.637.2201 www.lw.com FIRM / AFFILIATE OFFICES Abu Dhabi Moscow Barcelona Munich Beijing New Jersey Brussels New York Chicago Orange County Doha Paris July 27, 2010 Dubai Riyadh Frankfurt Rome Hamburg San Diego Hong Kong San Francisco Marlene H. Dortch Houston Shanghai Secretary London Silicon Valley Federal Communications Commission Los Angeles Singapore 445 12th Street, SW Madrid Tokyo Milan Washington, D.C. Washington, DC 20554 Re: Inmarsat Hawaii Inc. and ISAT US Inc., Call Sign E090032 IBFS File Nos. SES-ASG-20100107-00015; ISP-PDR-20100107-00006; ISP-PDR-20100323-00005 Dear Ms. Dortch: On behalf of Inmarsat Hawaii Inc. (“Inmarsat Hawaii”) and ISAT US Inc. (“ISAT US”), we are submitting this letter to supplement certain ownership information previously submitted to the Commission. Inmarsat Hawaii and ISAT US are both indirect, wholly-owned subsidiaries of Inmarsat plc. On January 7, 2010, Inmarsat Hawaii and ISAT US filed an application seeking authority to assign the license for Call Sign E090032 from Inmarsat Hawaii to ISAT US on a pro forma basis. See IBFS File No. SES-ASG-20100107-00015. The application also requested declaratory rulings that foreign ownership of these entities would serve the public interest. See 47 U.S.C. § 310(b)(4); IBFS File Nos. ISP-PDR-20100107-00006 and ISP-PDR-20100323- 00005. The application and associated declaratory rulings were granted on May 25, 2010. Among other things, the application included an exhibit describing the various holding companies in the Inmarsat ownership chain. Recently, Inmarsat learned that this exhibit had omitted reference to Inmarsat Holdings Ltd., the direct subsidiary of Inmarsat plc and also a company formed under the laws of England and Wales, with its principal place of business in the United Kingdom. This omission was entirely inadvertent; indeed, the existence of Inmarsat Holdings Ltd. in the Inmarsat ownership chain has been disclosed to the Commission in prior filings, and approved. See, e.g., IBFS File No. ITC-214-20090501-00194. Notably, the inclusion of a reference to Inmarsat Holdings Ltd. in the exhibit would not have altered materially the Commission’s analysis under Section 310(b)(4); the ultimate ownership of Inmarsat Hawaii and ISAT US by Inmarsat plc and its shareholders was disclosed fully, as was the fact that all non-U.S. Inmarsat entities are formed under the laws of England and Wales and have their principal places of business in the United Kingdom, a WTO member country. DC\1319385.1

Marlene H. Dortch July 27, 2010 Page 2 Regardless, we regret this oversight and any inconvenience it may cause, and appreciate the Commission’s willingness to assist Inmarsat Hawaii and ISAT US in ensuring a complete record with respect to their ownership. Toward that end, Exhibit A hereto contains a revised description of the Inmarsat ownership chain, which should be substituted for that included in the application. Please contact the undersigned should you have any questions in this matter. Respectfully submitted, /s/ John P. Janka John P. Janka Jarrett S. Taubman Counsel to Inmarsat Hawaii Inc. and ISAT US Inc. cc: Susan O’Connell DC\1319385.1

Exhibit A: Corrected Description of the Inmarsat Ownership Chain Inmarsat Hawaii Inc. and ISAT US Inc. are both wholly owned by Inmarsat U.S. Holdings, Inc., a Delaware corporation with its principal place of business in the United States. Inmarsat U.S. Holdings, Inc. is wholly owned by Inmarsat Services Ltd. Inmarsat Services Ltd. is wholly owned by Inmarsat Ventures Ltd. Inmarsat Ventures Ltd. is wholly owned by Inmarsat Investments Ltd. Inmarsat Investments Ltd. is wholly owned by Inmarsat Group Ltd. Inmarsat Group Ltd. is wholly owned by Inmarsat Holdings Ltd. Inmarsat Holdings Ltd. is wholly owned by Inmarsat plc. Information about the ownership and management of Inmarsat plc is on file with the Commission, and Inmarsat Hawaii Inc. and ISAT US Inc. incorporate that information by reference.1 With the exception of Inmarsat Hawaii Inc., ISAT US Inc., and Inmarsat U.S. Holdings, Inc., each of the Inmarsat entities described above is formed under the laws of England and Wales and has its principal place of business in the United Kingdom. Each of the Inmarsat entities described above can be reached care of the applicants at their U.S. address, and has as its primary business the provision of satellite communications services or acting as a holding company for such businesses. 1 See ISP-PDR-20090818-00006; ULS File No. 0004040346. DC\1319385.1


Document Created: 2010-07-27 11:31:27
Document Modified: 2010-07-27 11:31:27
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