C-Band Rebuttal T-Mobile

Last year, T-Mobile USA, Inc. (“T-Mobile”) proposed an alternative to the C-Band Alliance (“CBA”) Market-Based Approach that would force C-band satellite operators to participate in an incentive auction and cede their existing, investment-backed expectations in their spectrum (the “Original Proposal”). The CBA made clear that the Original Proposal would induce a massive holdout problem, slow 5G deployment to a crawl, and violate the Communications Act’s requirements for incentive auctions to be both voluntary and among competing bidders.