The Open Technology Institute at the New America Foundation (“OTI”) and Public Knowledge (“PK”) support the Commission’s balanced and sequenced approach toward the Congressional goal of ensuring unlicensed access to 600 MHz spectrum nationwide, while ensuring unlicensed operations do not cause harmful interference to licensed LTE services. OTI and PK file these comments in reply to oppositions to petitions for reconsideration filed in this proceeding by Qualcomm, GE Healthcare (“GEHC”), the WMTS Coalition (“WMTS”), Sennheiser Electronic Corp. (“Sennheiser”) and the Radio Television Digital News Association (“RTDNA”).
OTI and PK concur entirely with the arguments raised by WISPA and Google/Microsoft in their respective Opposition to Petitions for Reconsideration. OTI and PK agree that each of the petitions filed by the parties noted above are both procedurally and substantively defective, determination on the technical rules that can permit unlicensed operations in the 600 MHz duplex gap, guard bands and Channel 37.
Read the full Reply Comments here (PDF).
