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					                                   Federal Communications Commission                                DA 99-2965

                                              Before the
                                   Federal Communications Commission
                                         Washington, D.C. 20554

In the Matter of                                        )
ASIA SKYLINK, INC.                                      )    FCC Files Nos. 730216, 730217,
                                                        )    736359, and 736414
Petition for Revocation and for Other                   )
Appropriate Relief filed by Western                     )
Tele-Communications, Inc.                               )
Petition to Deny Applications to Modify                 )
Stations WPJC996, Aurora, CO                            )
and WPJC997, Denver, CO                                 )

                               MEMORANDUM OPINION AND ORDER

        Adopted: December 20, 1999                                    Released: December 23, 1999

By the Chief, Public Safety and Private Wireless Division, Wireless Telecommunications Bureau:

                                            I. INTRODUCTION

        1. Before us are the following pleadings submitted by Western Tele-Communications, Inc.
(WTCI): (1) a request that the Commission initiate a proceeding to revoke the licenses of Asia
Skylink, Inc. (ASI) for Private Operational Fixed Microwave Radio Stations WPJC996, Aurora,
Colorado, and WPJC997, Denver, Colorado;1 (2) a petition to deny the above-captioned ASI
applications to modify Stations WPJC996 and WPJC997;2 and (3) a complaint that ASI engaged in a
prohibited ex parte contact with Commission personnel regarding the petition to deny.3 For the
reasons stated herein, we deny all of WTCI's requests, and will grant the above-captioned

                                             II. BACKGROUND

        2. On November 17, 1995, Comsearch, which has provided frequency coordinator services
for both WTCI and ASI, initiated frequency coordination on behalf of ASI for new 6 GHz paths

   See WTCI Petition for Revocation and for Other Appropriate Relief (filed Nov. 14, 1996) (Petition for
   WTCI Petition to Deny (filed Aug. 28, 1997) (Petition to Deny).
    Letter from John Wells King, counsel for WCTI, to William F. Caton, Acting Secretary, FCC (dated Sept.
22, 1997) (Ex Parte Complaint).

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between Aurora and Denver, Colorado; Aurora and Englewood, Colorado; and Denver and Eldorado
Mountain, Colorado.4 WTCI was among the carriers notified in connection with this frequency
coordination, because it operates a 6 GHz point-to-point microwave radio system that includes a link
between Denver and Russelville (near Aurora), Colorado.5 Of the eight pairs of 30 MHz channels in
the 6 MHz band allocated by the Commission for both private operational-fixed and common carrier
point-to-point microwave service,6 WTCI's Denver-Russelville link is licensed for six pairs and WTCI
has coordinated the other two as growth channels.7

        3. On November 28, 1995, Comsearch informed WTCI that there was a possibility that ASI’s
proposed operations would cause interference to WTCI's growth channels.8 By letter dated November
30, 1995, ASI requested that WTCI relinquish its growth channels.9 By letter dated December 19,
1995, WTCI's coordinator at Comsearch advised ASI's frequency coordinator at Comsearch that
WTCI "has future need for [its] growth channels and do[es] not wish to relinquish them at this time.
Therefore, we consider the potential interference cases contained in our letter dated November 28,
1995 to be unresolved."10

        4. On January 19, 1996, ASI filed applications for new 6 GHz point-to-point microwave
radio facilities in the Denver area.11 The applications included a statement from Comsearch that there
   See Petition for Revocation at Att. 1.
   Id. at 3.
   See 47 C.F.R. § 101.147(i)(8).
    ASI Opposition at 1-2, 4-5. Growth channels are channels that licensees coordinate but hold in reserve for
future expansion of their systems, i.e. no application(s) is filed immediately to activate the channels.
Reorganization and Revision of Parts 1, 2, 21, and 94 of the Rules to Establish a New Part 101 Governing
Terrestrial Microwave Fixed Radio Services, WT Docket No. 94-148, 11 FCC Rcd 13449, 13473 n.102 (1996)
(Part 101 Report and Order).
    See Petition for Revocation at Att. 2 (Letter from Andrea F. Whitley, Frequency Analyst, Frequency
Protection Services of Comsearch to Rich Andree, WTCI (Nov. 28, 1995)). Proposed frequency usage must be
coordinated with existing licensees. 47 C.F.R. § 101.103(d)(1). It appears that ASI did not directly provide
WTCI with a copy of the study Comsearch performed to determine what frequencies were available to ASI. It
also appears, from the evidence in the record, that both parties have heavily relied on Comsearch regarding this
matter. Thus, we do not believe that ASI's failure to supply the study directly to WTCI is of major importance in
resolving this matter because it appears that Comsearch, in effect, provided the study to WTCI.
   Id. at 3.
    Id. at Att. 3 (Letter from Andrea F. Whitley, Frequency Analyst, Comsearch to Scott Brown, Comsearch
(Dec. 19, 1995)). The next paragraph of the letter states, "On behalf of our client, Western Tele-
Communications, Inc., we will have no objections to the operation of your proposed system provided it is
operated within the technical parameters set forth in your coordination notice." Id. WTCI contends that this
paragraph was inserted erroneously, and, taken as a whole, the letter clearly expresses an objection and
communicates unresolved cases of potential interference. Id. at 3-4 n.2.
     FCC File Nos. 722817 and 722818 (filed January 19, 1996). See Public Notice, Report No. 1834 (rel. Feb.
9, 1996). ASI's system also includes five other sites, which are not at issue.

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were no unresolved interference objections.12 No objections were received,13 and the applications
were granted on March 12, 1996.14 Paths between the Aurora (Station WPJC996) and Denver
(Station WPJC997) facilities are in both directions. In addition, the Aurora facility has a path to
another ASI facility at Englewood, Colorado, and the Denver facility has a path to an ASI facility at
Eldorado Mountain, Colorado.

         5. On October 7, 1996, ASI filed applications to modify the licenses for Stations WPJC996
and WPJC997 to change the antenna gains, centerline heights, and signal strengths. 15 The
applications included a statement from Comsearch that there were no unresolved interference
objections.16 On November 14, 1996, WTCI filed a pleading captioned "Petition for Revocation and
Other Appropriate Relief," requesting that the Commission initiate proceedings to revoke the licenses
for Stations WPJC996 and WPJC997 because ASI's applications for those stations did not comply
with the Commission's rules regarding prior frequency coordination.17

         6. On July 14, 1997, ASI requested dismissal of its application to modify the license for
Station WPJC997,18 and filed another application to modify that station to change the antenna polarity
and attenuate the transmitter power in order to reduce interference to WTCI.19 The coordination study
included in this application states, “Western Telecommunications Inc. has not agreed to relinquish
this growth channel. No other channels are assignable in accordance with FCC interference
criteria.”20 On August 28, 1997, WTCI timely filed a petition to deny this application, alleging that

    See Petition for Revocation at Att. 1.
     WTCI states that it did not file an objection to a grant of the applications because it did not have actual
notice of the applications. Id. at 5. It blames Comsearch for neglecting to notify it of the filing of the ASI
applications. Id. According to Comsearch, the failure to notify WTCI of the filing of the ASI applications was
"due to a procedural error in our office." Id. at Att. 6 (Letter from David L. Meyer, Manager, Terrestrial
Microwave Services, Comsearch to Rich Andree, WTCI (Nov. 7, 1996)).
    See Public Notice, Report No. 1839 (rel. Mar. 15, 1996).
    FCC File Nos. 730216 (WPJC997) and 730217 (WPJC996) (filed Oct. 7, 1996) (1996 Applications). See
Public Notice, Report No. 1907 (rel. Oct. 15, 1996).
    See 1996 Applications at Supplemental Showing (Memorandum from Scott Brown, Comsearch).
    Petition for Revocation. ASI filed its opposition on December 5, 1996. ASI Opposition to Petition for
Revocation and for Other Appropriate Relief (filed Dec. 5, 1996) (ASI Opposition). WTCI filed its reply on
December 24, 1996. WTCI Reply to ASI Opposition (filed Dec. 24, 1996) (WTCI Reply).
     Letter from Joseph A. Godles, counsel for ASI, to Private Operational Fixed Radio Services, FCC (dated
July 11, 1997). ASI also filed an application to modify the path from WPJC996 to Englewood. FCC File No.
736414 (filed July 16, 1997). See Public Notice, Report No. 1949 (rel. Aug. 12, 1997). We read the reference in
the caption of WTCI's Petition to Deny to FCC File No. 730414 to refer to FCC File No. 736414. (FCC File No.
730414 was filed by an entity other than ASI.) Other than in the caption, however, WTCI does not appear to
object to this application, which does not involve any links or frequencies mentioned in WTCI’s petitions.
    FCC File No. 736359 at Exh. 1 (filed July 14, 1997). See Public Notice, Report No. 1949 (rel. Aug. 12,

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frequency coordination was incomplete and the conflicts still were not resolved.21

         7. On September 9, 1997, counsel for ASI spoke via telephone to the Chief of the Private
Wireless Division, Wireless Telecommunication Bureau,22 regarding ASI's modification applications
and WTCI's petition to deny.23 He requested expedited action on the applications on the grounds that
the petition to deny merely repeated arguments WTCI made in previous filings, which in counsel's
view the Commission resolved when it granted ASI's original applications.24 He also stated that delay
by the Commission in processing the applications furthered WTCI's apparent goal of keeping
competitors out of the Denver market.25 On September 22, 1997, WTCI submitted a letter26 objecting
to these statements and requesting sanctions pursuant to Section 1.1216 of the Commission's Rules.27

                                                  III. DISCUSSION

         8. As an initial matter, ASI contends28 that WTCI's Petition for Revocation,29 based as it is on
information in ASI's original applications, is in effect an untimely petition to deny those applications
or a petition for reconsideration of the grant of those applications,30 because it was filed more than
thirty days after public notice of the filing and grant of those applications.31 WTCI replies32 that the

    Id. at Exh. 2.
     Petition to Deny. On September 10, 1997, ASI filed its opposition to the Petition to Deny. ASI Opposition
to Petition to Deny (filed Sept. 10, 1997). On September 22, 1997, WTCI filed its reply to the ASI Second
Opposition. WTCI Reply to ASI Second Opposition (filed Sept. 22, 1997).
     Pursuant to an internal reorganization of the Wireless Telecommunications Bureau, the functions of the
Private Wireless Division are now administered by the Public Safety and Private Wireless Division.
    Letter from Henry Goldberg, counsel for Asia Skylink, Inc., to William F. Caton, Acting Secretary, FCC,
(Sept. 10, 1997).
       Id. at 1.
       Ex Parte Complaint.
       47 C.F.R. § 1.1216.
       See ASI Opposition at 3.
     The Commission does not recognize a formal right to seek revocation of a license. See, e.g., Danbury
Cellular Telephone Company, Inc., Memorandum Opinion and Order, 6 FCC Rcd 4186, 4188 n.2 (CCB Mobile
Services Division 1991) (citing Puerto Rican Media Action and Educational Council, Inc. v. Educational
Broadcasting Corp., 51 FCC 2d 1178, 1179 (1973)). Pleadings so captioned are treated as informal requests for
Commission action. See 47 C.F.R. § 1.41.
    See CNA Financial Corp., Memorandum Opinion and Order, 58 FCC 2d 607, 609 ¶ 6 (1976); Asbury &
James TV Cable Service, Decision, 13 FCC 2d 333, 334 ¶ 3 (1968).
       See 47 C.F.R. §§ 1.106(f) (petition for reconsideration must be filed within 30 days of public notice of final

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Petition for Revocation is proper because Section 312(a) of the Communications Act empowers the
Commission to revoke a license in two circumstances relevant to ASI's conduct: for false statements
knowingly made by an applicant, and because of conditions coming to the Commission's attention that
would warrant refusal to grant an initial license or permit.33 We need not resolve this dispute for we
have reviewed the contentions in the Petition for Revocation and the Petition to Deny (which raises
the same issues), and we find them to be without merit.

         9. Section 101.103(d)(1) of the Commission's Rules provides in pertinent part, that

         Proposed frequency usage must be prior coordinated with existing licensees,
         permittees and applicants in the area, and other applicants with previously filed
         applications, whose facilities could affect or be affected by the new proposal in terms
         of frequency interference on active channels, applied-for channels, or channels
         coordinated for future growth. Coordination must be completed prior to filing an
         application for regular authorization, or an amendment to a pending application, or
         any major modification to a license. . . . All applicants and licensees must cooperate
         fully and make reasonable efforts to resolve technical problems and conflicts that may
         inhibit the most effective and efficient use of the radio spectrum; however, the party
         being coordinated with is not obligated to suggest changes or re-engineer a proposal
         in cases involving conflicts. Applicants should make every reasonable effort to avoid
         blocking the growth of systems as prior coordinated. . . . In the event that technical
         problems are not resolved, an explanation must be submitted with the application.34

WTCI claims that ASI did not complete coordination prior to filing its applications because WTCI's
interference cases were left unresolved, and that ASI failed to include in its applications an
explanation of the unresolved technical problems.35 WTCI also claims that ASI made no reasonable
efforts to resolve the conflicts and that ASI failed to make every reasonable effort to avoid blocking
the growth of WTCI's systems as prior coordinated.36 Further, WTCI asserts37 that ASI did not make
the showing required by Section 101.103(d)(2)(xii), which states, "Any frequency reserved by a

action), 101.43(a)(4) (petition to deny must be filed within 30 days of application appearing on public notice).
    WTCI Reply at 6.
    47 U.S.C. § 312(a)(1), (2).
     47 C.F.R. § 101.103(d)(1); see also 47 C.F.R. § 101.103(d)(2)(iv) ("Every reasonable effort should be made
by all applicants, permittees and licensees to eliminate all problems and conflicts."), (vii) ("All technical
problems that come to light during coordination must be resolved unless a statement is included with the
application to the effect that the applicant is unable or unwilling to resolve the conflict and briefly the reason
therefor."). The cited language from Section 101.103(d) is identical to former Section 21.100(d), which was in
effect at the time the ASI facilities were coordinated. See 47 C.F.R. § 21.100(d) (1995).
    WTCI Petition at 7-8.
    Id. at 7.
    Id. at 7-8.

                                      Federal Communications Commission                         DA 99-2965

licensee for future use . . . must be released for use by another licensee, permittee or applicant upon a
showing by the latter that it requires an additional frequency and cannot coordinate one that is not
reserved for future use."38 Finally, WTCI argues39 that ASI did not satisfy former Section 94.15(c) of
the Commission's Rules, to which ASI's initial applications were subject40, which required an
applicant to select a frequency band with the assignable bandwidth most consistent with the proposed
communications requirements, and to provide a supplemental showing of the basis for the frequency
band selection and bandwidth requested, and the proposed schedule for implementation of bandwidth

        10. Having reviewed the entire record in this matter, we conclude that ASI's applications
were not deficient. As described above, ASI and WTCI came to an impasse over the latter’s refusal to
relinquish its growth channels. Several of WTCI's arguments are based on the premise that the
impasse constituted an unresolved technical problem under the Commission's Rules that left ASI's
coordination incomplete and should have been explained in ASI's applications. We concur with ASI’s
contention, however, that WTCI's unwillingness to release its growth channels was not an unresolved
"technical problem."42 Thus, we disagree with WTCI’s assertions that ASI's coordination or
applications were incomplete.

         11. Moreover, it is not clear what further efforts ASI could have made to resolve the conflict.
 ASI states that it purposely designed its system to use only one of WTCI's growth channels,
notwithstanding the fact that this design was to ASI's detriment.43 ASI claims that it used the same
frequency at its Eldorado Mountain and Aurora sites, at the risk of increased interference into its own
system due to reflection, solely to avoid using WTCI's other growth channels.44 ASI further states that
it also chose high-performance antennas to improve the interference characteristics of its system. 45

        12. Notably, WTCI does not refute ASI’s contentions and instead contends that ASI could
have made greater efforts to avoid blocking the growth of WTCI's systems by changing the polarity of
the signal from Denver to Aurora or by choosing a frequency in the 11 GHz band.46 ASI argues that
WTCI's suggestions are not realistic solutions.47 It cites an engineering analysis performed by
       47 C.F.R. § 101.103(d)(2)(xii).
       WTCI Petition at 12.
   See 47 C.F.R. § 101.4(a).
       47 C.F.R. § 94.15(c) (1995).
       ASI Opposition at 1.
       ASI Opposition at 5.
       WTCI Petition at 10.
       ASI Opposition at 6.

                                      Federal Communications Commission                                     DA 99-2965

Comsearch to determine ASI's alternative frequency options.48 ASI asserts that this letter recognizes
that whether or not ASI changed the polarity of the Aurora receive channel, ASI's Denver and Aurora
receivers would incur "major" interference from WTCI's stations, and that ASI could not change the
polarity of the Aurora transmit signal because "it [is] already crosspole (best scenario) to [another of]
WTCI's growth frequenc[ies]."49 ASI asserts that if it implemented WTCI's suggestion, its system
would be inoperable should WTCI ever decide to activate one of the growth channels it has claimed
for the Russelville station.50 ASI further claims that Comsearch was able to find only one clear 11
GHz frequency pair that conceivably could meet ASI's needs, and even that channel pair was subject
to potential interference from yet another WTCI transmitter located only 0.1 mile away. 51 Upon
reviewing the record in this matter, we are not persuaded that WTCI’s suggestions would constitute
reasonable efforts to avoid blocking the growth of its systems.52

          13. In addition, we agree with ASI that Section 101.103(d)(2)(xii) of the Rules required
WTCI to relinquish the channel pair requested by ASI.53 WTCI contends that ASI has shown neither
that it requires WTCI's growth channel nor that no other channel is available that is not reserved for
future use.54 ASI's applications indicate, based on expected customer demand, an initial baseband
loading of 2400 channels and a 10-year projected baseband channel load of 2400 channels. ASI, like
all licensees, is required to meet the efficiency standards of Section 101.141 of the Commission's

   See WTCI Petition at Att. 12 (Letter from Anh C. Tran, Senior Engineer, Microwave and Satellite Services,
Comsearch, to Mr. Rich Andrea, WTCI (Nov. 14, 1996)).
    ASI Opposition at 6. See also WTCI Petition at Att. 12 (Letter from Anh C. Tran, Senior Engineer,
Microwave and Satellite Services, Comsearch, to Mr. Rich Andrea, WTCI (Nov. 14, 1996)).
    ASI Opposition at 6.
    We also note that an existing licensee who is trying to protect its growth channels may not dictate what the
incoming applicant should do, and effectively engineer the new applicant's system. We believe that the
Commission has given clear guidance regarding this matter when it discussed frequency and route coordination:

          One other point we wish to make clear is that we do not intend, by the device of coordination, to give
          one carrier a veto power over another's technical proposal. If the problem cannot be resolved, . . . [and]
          the objecting carrier deems the matter to be of sufficient importance, it may, of course, file a petition to
          deny or an informal objection. In accordance with long-established practice, the Commission does not
          grant any application where it is aware of likely interference to any authorized station.

Establishment of Policies and Procedures for Consideration of Applications to Provide Specialized Common
Carrier Services in the Domestic Public Point-to-Point Microwave Radio Service and Proposed Amendments to
Parts 21, 43, and 61 of the Commission's Rules, First Report and Order, 29 FCC 2d 870, 930-931 ¶132 (1971),
aff'd, 33 FCC 2d 408 (1972) (First Report and Order) (emphasis added). We note that growth channels are not
"authorized stations." Thus, we do not believe that WTCI is entitled to compel ASI to go to another frequency
band or engineer its facilities so as to accommodate WTCI's growth channels.
    ASI Opposition at 6.
    WTCI Reply at 4.

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Rules.55 Under the circumstances presented, we do not have sufficient reason to doubt that ASI will
meet the standards. In addition, we already have rejected WTCI's suggestion that ASI should have
used an available 11 GHz channel, instead. The Commission's "policy is to protect the future
expansion of existing growth routes to the extent practicable."56 We find that it is not practicable for
WTCI to hold all of its growth channels in light of ASI's more current requirements.

         14. Moreover, when it enacted Section 101.103(d), the Commission contemplated that
growth channels would be for “months,” not years.57 The Commission specifically stated that, under
this rule, "any party needing to hold growth channels for longer than six months must demonstrate a
need for them in the event that another entity is unable to clear another channel."58 When ASI filed its
applications, WTCI had been holding its growth channels at its Denver and Russelville stations for
more than six years without offering a justification for its need for them, other than the statement that
it "does not wish to relinquish [them]."

        15. Finally, we reject WTCI's argument that ASI did not indicate how selection of 6 GHz
channels with 30 MHz assignable bandwidth is consistent with its communications requirements, as
required by former Section 94.15(c).59 WTCI presumes that ASI's services are provided over
equivalent 4 kHz, voice-grade channels based on a single 30 MHz analog radio channel ordinarily
accommodating up to 2400 voice-grade channels.60 WTCI then states that ASI's need for such
expansive bandwidth over its proposed system has not been established.61 We reject WTCI's
argument that ASI did not make the showing required by former Section 94.15(c) for the same reasons
we rejected WTCI's argument that ASI did not make the showing required by Section

         16. Therefore, we conclude that WTCI's Petitions should be denied. While we are not
persuaded by WTCI's arguments, we nonetheless note that ASI should have cooperated more fully in
its endeavors to satisfy its frequency coordination obligations and we caution it to do so in the future.
 It appears that ASI overly relied on its frequency coordinator and failed to directly provide WTCI
with the showing that no other frequencies were available in the 6 GHz band and state its reasons for
why it needed one of those channels. We also disapprove of WTCI’s apparent attempts to prior-
coordinate and reserve all the wider channels in the 6 GHz band as its growth channels. In the

    47 U.S.C. § 101.141.
    First Report and Order, 29 FCC 2d at 931 ¶134 (emphasis added).
    Part 101 Report and Order, 11 FCC Rcd at 13473 n.101.
    Id. at 13474 ¶ 66. In this order, the Commission shifted the burden to the entity reserving the growth
channel, and required the holder to make the showing that the channel is still needed if another entity needs that
    WTCI Petition at 12.
    See supra ¶ 13.

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competitive environment which exists today, frequency spectrum is becoming more scarce, especially
in the lower frequency bands where longer microwave routes are possible.

         17. Ex Parte Complaint. WTCI also argues that the statements of ASI's counsel on
September 9, 1997, to the Chief of the Private Wireless Division were an impermissible ex parte
presentation.63 We disagree. Ex parte presentations are communications directed to the merits or
outcome of a proceeding which, if written, are not served on the parties to the proceeding or, if oral,
are not preceded by notice to the parties and an opportunity for the parties to be present. 64 An oral
presentation giving reasons, other than the need to resolve administrative delay, why the proceeding
should be resolved is not treated as an ex parte presentation if a summary is promptly filed in the
record and served on the other parties.65 While the substance of ASI’s counsel’s statements -- that the
matter was deserving of expedited action because the Commission had already addressed the issues,
and a delay could have the affect of keeping competitors out of the Denver market -- were reasons
other than the need to resolve administrative delay why the proceeding should be resolved, ASI's
counsel promptly filed a summary with the Commission and served a copy on WTCI's counsel, so the
contact is not considered an ex parte presentation under the Commission's Rules. Further, contrary to
WTCI's suggestion, the fact that ASI made the same points in some of its pleadings in this proceeding
does not convert the statements into discussions of the merits of the case.66 Thus, we find that the
statements of ASI’s counsel did not constitute a violation of the Commission’s ex parte rules.

                                         IV. CONCLUSION

         18. For the reasons stated above, WTCI's Petitions are denied. Specifically, we conclude that
ASI met the fundamental requirements of Section 101.103 of the Commission's Rules pertaining to
frequency coordination, and that WTCI does not have a sufficient basis under these circumstances to
retain reservation of all of its prior-coordinated growth channels.

                                      V. ORDERING CLAUSES

       19. Accordingly, IT IS ORDERED that pursuant to Sections 4(i), 309, and 312 of the
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 309, and 312, and Section 1.939 of
the Commission's Rules, 47 C.F.R. § 1.939, WTCI's Petition for Revocation and for Other
Appropriate Relief, filed on November 14, 1996, and Petition to Deny, filed on August 28, 1997, ARE
DENIED, and FCC File Nos. 730217, 736359, and 736414 filed by Asia Skylink, Inc. will be granted.

       20. IT IF FURTHER ORDERED that, pursuant to Section 1.934 of the Commission's Rules,
47 C.F.R. § 1.934, FCC File No. 730216, filed by ASI on October 7, 1996, SHALL BE DISMISSED.

       21. This action is taken pursuant to the authority delegated by Sections 0.131 and 0.331 of
the Commission's Rules, 47 C.F.R. §§ 0.131, 0.331.

    Ex Parte Complaint at 2.
    47 C.F.R. § 1.1202(a), (b).
    47 C.F.R. § 1.1204(a)(11).
    Ex Parte Complaint at 2.

    Federal Communications Commission                        DA 99-2965



        D’wana R. Terry
        Chief, Public Safety and Private Wireless Division
        Wireless Telecommunications Bureau


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