The Federal Communications Commission (FCC) has initiated a Notice of Proposed Rulemaking (“C-Band NPRM”) to consider whether and how to repurpose a portion of the 3700-4200 MHz band (“C-Band”) to terrestrial operations. The C-Band Alliance (CBA) proposed that the FCC permit the CBA to enter into secondary market agreements with 5G service providers to use up to 180 MHz of the 200 MHz of spectrum to be cleared by the CBA members. If the FCC agrees, the CBA would conduct a private auction process for interested entities to seek access to the cleared spectrum. The process is being designed by expert auction consulting firm Auctionomics and the specifics of the auction process will need to be approved by the FCC. Successful auction participants would apply to the FCC for a Flexible Use license which, if approved, would authorize the provision of terrestrial service in the agreed-upon geographic area and spectrum.