2008 ANNUAL REPORT June 30,2008 RECEIVED - FCC JW 36 2008 CONFIDENTIAL, NOT FOR PUBLIC INSPECTION VIA OVERNIGHT COURIER Federal Communications Commission Columbia Operations Center 9200 Farmhouse Lane Columbia, Maryland 2 1046 Re: ORBCOMM License Corp. FCC Call Sign S2103 Annual NVNG MSS Licensee Report 47 C.F.R. §25.142(c) REQUEST TO WITHOLD ATTACHED CONFIDENTIAL COMMERCIALLY SENSITIVE MATERIALS FROM PUBLIC INSPECTION - 47 C.F.R. 55 0.457(d) & 0.459 Dear Sir or Madam: Pursuant to Section 25.142(c) of the Commission’s Rules, ORBCOMM License Corp. (“ORBCOMM”), hereby submits the attached Annual Report on the state of the ORBCOMM Non-Voice Non-Geostationary mobile satellite service (“NVNG MSS?’) satellite system (the “Annual Report”). The entire content of ORBCOMM’s Annual Report is CONFIDENTIAL, ORBCOMM PROPRIETARY, COMMERCIALLYSENSITIVE TRADE SECRET information . Pursuant to Sections 0.457(d) and 0.459 of the Commission’s Rules, ORBCOMM respectfully requests that the entirety of its Annual Report be accorded confidential treatment by the Commission and withheld from public inspection. The Annual Report contains proprietary trade secret commercially sensitive internal operational information that is not publicly disclosed by ORBCOMM, and thus should be treated as confidential by the Commission. Moreover, disclosure of this information would cause competitive harm to ORBCOMM by providing its competitors with detailed information on the capacity and operations of ORBCOMM’s satellite s ys tem. 2 1 IS Linwood Avenue, Suite 100, Fort Lee, NI 07024 Telephone: 201 -363-4900 lacsimile: 703-433-6400 2 I700 Atlantic Boulevard, Ilulles, VA 20 I66 Telephone: 703-433-6300 Facsimile: 703-433-6400 CURrFIDENTIAL, NOT FOR PUBLIC INSPECTION Annual NVBG NISS Licensee Report 47 C,F,R. 25.142(c) FCC Columbia Operations Center VCC Call Sign S2103 June 30,2008 Page 2 of 2 Irideed, in adopting the NVNG MSS service niles, the Comnlissiun cxplici tly intlicatcd that it would grant confidential treatment to infomntion filed in accordance with Section 25. I42(c) of its Rules.' Thus, ORBCOMhTs Annual Report should be exempt fioni yublic disclosure pursuant to Section 0.457(d j of the Commission's Rules, Howe-t'er, clue to the vcry sensitive nature of the infonnation contained in the Annual Report. and out of an aburidar~ce of' caution, OREXCOMM is also hereby requesting confidential treatment cd its Annual Kcpor-t pirrsuant to Section 0.459 of the C2'onimission's Rules. Accordingly, gant oC the iiistaiit request to withhold the attached inaterials froin public illspection will serve the public intorest, convcnience and necessity. Kindly direct any inquiries concerning this submission to thc undersigned. Very tnily yours, Walter H. Sonnenfeldt Vice President, Regulatory Affairs Tel: 585-461-3018 E-Mail: sonnenfeldt .wal ter(i:orbcomm.cum Attac hm cnt : CONFIDENTIAL S u bm i ssi on