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                           Before the
                     Washington, D.C.  20554

In the Matter of                        )
COMSAT CORPORATION,                )
     Complainant,                       )
v.                                 )    File No. E-99-27
     Defendant.                         )

                         ORDER ON REVIEW

Adopted: February 22, 2001                                   
Released: February 26, 2001

By the Commission: 

     1.   The Commission has before it an Application for Review 
filed by COMSAT Corporation1 (``COMSAT'') pursuant to section 
1.115 of the Commission's rules.2  COMSAT requests review of a 
November 15, 2000 order by the Enforcement Bureau,3 which 
dismissed with prejudice a complaint COMSAT filed against Stratos 
Mobile Networks (USA), LLC (``Stratos'') pursuant to section 208 
of the Communications Act of 1934, as amended (``Act'').4 The 
Bureau determined that both the doctrine of res judicata and 
section 207 of the Act5 precluded COMSAT from bringing the 

     2.   Upon careful review of the Application for Review and 
the entire record herein, we conclude that COMSAT has failed to 
demonstrate that the Enforcement Bureau erred.  The Enforcement 
Bureau properly decided the matters raised below, and we uphold 
its decision for the reasons stated in the Bureau Order.6  

     3.   Accordingly, IT IS ORDERED, pursuant to sections 4(i), 
4(j), 207, and 208 of the Act, 47 U.S.C.  154(i), 154(j), 207, 
208, and section 1.115(g) of the Commission's rules, 47 C.F.R.  
1.115(g), that the Application for Review filed by COMSAT 
Corporation IS DENIED and this proceeding IS TERMINATED WITH 

                              FEDERAL COMMUNICATIONS COMMISSION

                              Magalie Roman Salas 

1    Application for Review of COMSAT Corporation, File No. E-99-
27 (filed December 18, 2000) (``Application for Review'').

2    47 C.F.R.  1.115.

3    COMSAT Corporation v. Stratos Mobile Networks (USA), LLC, 
Memorandum Opinion and Order, DA No. 00-2589 (Enf. Bur. Nov. 15, 
2000) (``Bureau Order''). 

4    47 U.S.C.  208.

5    47 U.S.C.  207.

6    We note that COMSAT does not contest the Enforcement 
Bureau's conclusion that COMSAT has made contradictory 
representations to the Commission concerning the nature of its 
contractual relationship with Stratos.  Bureau Order at  19, 
22-23, and 28 (explaining that COMSAT argues in this case that 
Stratos was not bound by a certain contract between COMSAT and 
IDB Mobile Communications, Inc. (``IDB''), even though COMSAT 
represented in prior Commission proceedings that Stratos was 
``directly, explicitly, and unambiguously'' bound by the same 
contract).  To the extent that COMSAT relies on principles of 
fairness and equity to argue against our application of the res 
judicata doctrine (Application for Review at 10-11, 16-17), this 
conspicuous omission by COMSAT substantially undermines its