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Comments of Space Data Corporation

Space Data is the leader in high altitude balloon borne communications platforms where between 65-100,000 feet we have flown over 20,000 commercial SkySite® flights totaling over 250,000 flight hours as well as supply the military with our StarFighter® platform which extends 2 way radio communications from under 10 miles to over 400 miles. We were founded in 1999 and to develop our technology we decided that the ReFlex paging protocol was appropriate and that FCC licensed spectrum was available. Hence we participated in FCC Auctions 40, 41 and 50 and through secondary market transactions accumulated almost 2 of the 3 MHz allocated to Narrowband PCS (NPCS) in the 901/930/940 MHz bands.