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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                          )                           
                                              File No. EB-07-SE-208   
     In the Matter of                     )                           
                                              Acct. No. 200832100079  
     Comtech Mobile Datacom Corporation   )                           
                                              FRN: 0007773005         
                                          )                           


                                     ORDER

   Adopted: September 5, 2008 Released: September 8, 2008

   By the Deputy Chief, Enforcement Bureau:

    1. In this Order, we adopt the attached Consent Decree entered into
       between the Enforcement Bureau ("Bureau") and Comtech Mobile Datacom
       Corporation ("CMDC"). The Consent Decree terminates an investigation
       by the Bureau against CMDC for possible violations of section 301 of
       the Communications Act of 1934, as amended ("Act"), and sections
       25.102, 25.117, 25.136(d) and 25.276(a) of the Commission's Rules
       ("Rules") regarding CDMC's modification and operation of its mobile
       earth terminal ("MET") system.

    2. The Bureau and CMDC have negotiated the terms of a Consent Decree that
       resolve these matters. A copy of the Consent Decree is attached hereto
       and incorporated by reference.

    3. After reviewing the terms of the Consent Decree and evaluating the
       facts before us, we find that the public interest would be served by
       adopting the Consent Decree and terminating the investigation.

    4. In the absence of material new evidence relating to these matters, we
       conclude that our investigations raise no substantial or material
       questions of fact as to whether CMDC possesses the basic
       qualifications, including those related to character, to hold or
       obtain any Commission license or authorization.

    5. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act,
       and sections 0.111 and 0.311 of Rules, the Consent Decree attached to
       this Order IS ADOPTED.

    6. IT IS FURTHER ORDERED that the above-captioned investigation IS
       TERMINATED.

    7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
       shall be sent by first class mail and certified mail, return receipt
       requested, to Joan M. Griffin, Esq., Counsel for Comtech Mobile
       Datacom Corporation, Kelley Drye & Warren LLP, Washington Harbour,
       Suite 400, 3050 K Street, N.W., Washington, D.C., 20007-5108 and
       Daniel S. Wood, President, Comtech Mobile Datacom Corporation, 20430
       Century Blvd., Germantown, Maryland 20874.

   FEDERAL COMMUNICATIONS COMMISSION

   Susan McNeil

   Deputy Chief, Enforcement Bureau

                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                          )                           
                                              File No. EB-07-SE-208   
     In the Matter of                     )                           
                                              Acct. No. 200832100079  
     Comtech Mobile Datacom Corporation   )                           
                                              FRN No. 0007773005      
                                          )                           


                                 CONSENT DECREE

   The Enforcement Bureau ("Bureau") and Comtech Mobile Datacom Corporation
   ("CMDC"), by their authorized representatives, hereby enter into this
   Consent Decree for the purpose of terminating the Bureau's investigation
   into whether CMDC violated section 301 of the Communications Act of 1934,
   as amended ("Act") and sections 25.102, 25.117, 25.136(d) and 25.276(a) of
   the Commission's Rules by modifying and operating its mobile earth
   terminal ("MET") system without appropriate authorization.

   I. DEFINITIONS

    1. For the purposes of this Consent Decree, the following definitions
       shall apply:

    a. "Act" means the Communications Act of 1934, as amended, 47 U.S.C. S:
       151 et seq.

    b. "Bureau" means the Enforcement Bureau of the Federal Communications
       Commission.

    c. "CMDC" means Comtech Mobile Datacom Corporation and its
       predecessors-in-interest and successors-in-interest.

    d. "Commission" and "FCC" mean the Federal Communications Commission and
       all of its bureaus and offices.

    e. "Effective Date" means the date on which the Bureau releases the
       Adopting Order.

    f. "Investigation" means the investigation commenced by the Bureau's
       August 27, 2007 Letter of Inquiry ("LOI") regarding whether CMDC
       violated section 301 of the Act and sections 25.102, 25.117, 25.136(d)
       and 25.276(a) of the Commission's Rules by modifying and operating its
       MET system without appropriate authorization.

    g. "MET" means mobile earth terminal.

    h. "Order" or "Adopting Order" means an Order of the Bureau adopting the
       terms and conditions of this Consent Decree without change, addition,
       deletion, or modification, and formally terminating the Investigation.

    i. "Parties" means CMDC and the Bureau.

    j. "Rules" means the Commission's regulations found in Title 47 of the
       Code of Federal Regulations.

   II. BACKGROUND

    2. Under section 301 of the Act, "[n]o person shall use or operate any
       apparatus for the transmission of energy or communications or signals
       by radio ... except under and in accordance with this Act and with a
       license in that behalf granted under the provisions of this Act."
       Under section 25.102 of the Rules, "[n]o person shall use or operate
       apparatus for the transmission of energy or communications or signals
       by space or earth stations except under, and in accordance with, an
       appropriate authorization granted by the Federal Communications
       Commission." Section 25.276(a) of the Rules requires that earth
       stations transmit to appropriate points of communications, while
       section 25.136(d) of the Rules requires that earth stations operating
       in the lower part of the L-band have certain minimum capabilities "to
       ensure compliance with footnote 5.353A and the priority and real-time
       preemption requirements imposed by Footnote US 315" as set forth in
       section 2.106 of the Rules. Pursuant to section 25.117 of the Rules,
       no modification which affects the parameters or terms and conditions
       of a station authorization may be made except upon application to and
       grant of such application by the Commission.

    3. On August 27, 2007, the Bureau issued the LOI to CMDC. The LOI
       directed CMDC, among other things, to submit a sworn written response
       to a series of questions relating to the modification and operation of
       CMDC's MET system. CMDC responded to the LOI on September 26, 2007.

   III. TERMS OF AGREEMENT

    4. Adopting Order. The Parties agree that the provisions of this Consent
       Decree shall be subject to final approval by the Bureau by
       incorporation of such provisions by reference in the Adopting Order
       without change, addition, modification, or deletion.

    5. Jurisdiction. CMDC agrees that the Bureau has jurisdiction over it and
       the matters contained in this Consent Decree and has the authority to
       enter into and adopt this Consent Decree.

    6. Effective Date; Violations. The Parties agree that this Consent Decree
       shall become effective on the date on which the Bureau releases the
       Adopting Order. Upon release, the Adopting Order and this Consent
       Decree shall have the same force and effect as any other order of the
       Bureau. Any violation of the Adopting Order or of the terms of this
       Consent Decree shall constitute a separate violation of a Bureau
       order, entitling the Bureau to exercise any rights and remedies
       attendant to the enforcement of a Commission order.

    7. Termination of Investigation. In express reliance on the covenants and
       representations in this Consent Decree and to avoid further
       expenditure of public resources, the Bureau agrees to terminate the
       Investigation. In consideration for the termination of the
       Investigation, CMDC agrees to the terms, conditions, and procedures
       contained herein. The Bureau further agrees that in the absence of new
       material evidence, the Bureau will not use the facts developed in this
       investigation through the Effective Date of the Consent Decree, or the
       existence of this Consent Decree, to institute, on its own motion, any
       new proceeding, formal or informal, or take any action on its own
       motion against CMDC concerning the matters that were the subject of
       the investigation. The Bureau also agrees that it will not use the
       facts developed in this investigation through the Effective Date of
       this Consent Decree, or the existence of this Consent Decree, to
       institute on its own motion any proceeding, formal or informal, or
       take any action on its own motion against CMDC with respect to CMDC's
       basic qualifications, including its character qualifications, to be a
       Commission licensee or authorized common carrier.

    8. Compliance Plan. For purposes of settling the matters set forth
       herein, CMDC agrees to maintain a Compliance Plan to ensure future
       compliance with the Act, the Commission's Rules, and the Commission's
       orders. Specifically, CMDC has taken and will continue to take the
       following steps:

    a. Compliance Officer. CMDC has designated one member of its senior
       management team (no less than vice president or equivalent) to be the
       FCC compliance officer. The FCC compliance officer will be
       knowledgeable about the configuration and operation of CMDC's MET
       system. The FCC compliance officer will also be familiar with CMDC's
       blanket MET system license and the FCC Rules applicable to operation
       under and modification of the terms and conditions of the license. The
       FCC compliance officer may rely on outside consultants in complying
       with these requirements.

    b. Staff training. The FCC compliance officer will be responsible for
       ensuring that all appropriate CMDC staff receive training regarding
       CMDC's blanket MET system license and the FCC Rules applicable to
       operation under and modification of the terms and conditions of the
       license. Such training will be completed within ninety days of the
       Effective Date. Any new employees for whom such training would be
       appropriate will receive training within sixty days of the
       commencement of their employment.

    c. Compliance Reports. CMDC will file compliance reports with the
       Commission ninety (90) days after the Effective Date, twelve (12)
       months after the Effective Date, and twenty-four (24) months after the
       Effective Date. Each report shall include a compliance certificate
       from an officer, as an agent of CMDC, stating that the officer has
       personal knowledge that CMDC has established operating procedures
       intended to ensure compliance with this Consent Decree, together with
       an accompanying statement explaining the basis for the officer's
       compliance certification. All reports shall be submitted to Chief,
       Spectrum Enforcement Division, Enforcement Bureau, Federal
       Communications Commission, 445 12th Street, S.W., Washington, D.C.
       20554.

    d. Termination Date. Unless stated otherwise,  the requirements of this
       Consent Decree will expire twenty-four (24) months from the Effective
       Date.

    e. Entire Agreement. The Parties agree that this Consent Decree contains
       the entire agreement between the Parties with respect to its subject
       matter and supersedes any prior or contemporaneous agreements or
       understandings of any kind with respect to such subject matter. For
       the purposes of 47 U.S.C. S: 503(b)(6)(B), the Parties agree that the
       relevant date is May 30, 2007.

    9. Voluntary Contribution. CMDC agrees that it will make a voluntary
       contribution to the United States Treasury in the amount of $25,000.
       The payment will be made within 30 days after the Effective Date of
       the Adopting Order. The payment must be made by check or similar
       instrument, payable to the order of the Federal Communications
       Commission. The payment must include the Account Number and FRN Number
       referenced in the caption to the Adopting Order. Payment by check or
       money order may be mailed to Federal Communications Commission, P.O.
       Box 979088, St. Louis, MO 63197-9000. Payment by overnight mail may be
       sent to U.S. Bank - Government Lockbox #979088, SL-MO-C2-GL, 1005
       Convention Plaza, St. Louis, MO 63101. Payment by wire transfer may be
       made to ABA Number 021030004, receiving bank TREAS/NYC, and account
       number 27000001. For payment by credit card, an FCC Form 159
       (Remittance Advice) must be submitted. When completing the FCC Form
       159, enter the Account number in block number 23A (call sign/other
       ID), and enter the letters "FORF" in block number 24A (payment type
       code).

   10. Waivers. CMDC waives any and all rights it may have to seek
       administrative or judicial reconsideration, review, appeal or stay, or
       to otherwise challenge or contest the validity of this Consent Decree
       and the Order adopting this Consent Decree, provided the Bureau issues
       an Order adopting the Consent Decree without change, addition,
       modification, or deletion. CMDC shall retain the right to challenge
       Commission interpretation of the Consent Decree or any terms contained
       herein. If either Party (or the United States on behalf of the
       Commission) brings a judicial action to enforce the terms of the
       Adopting Order, neither CMDC nor the Commission shall contest the
       validity of the Consent Decree or the Adopting Order, and both CMDC
       and the Commission shall waive any statutory right to a trial de novo
       with respect to the issuance of the Adopting Order and shall consent
       to a judgment incorporating the terms of this Consent Decree. CMDC
       hereby agrees to waive any claims it may otherwise have under the
       Equal Access to Justice Act, 5 U.S.C. S: 504 and 47 C.F.R. S: 1.1501
       et seq., relating to the matters addressed in this Consent Decree. By
       this Consent Decree, CMDC neither waives nor alters its right to
       assert and seek protection from disclosure of any privileged or
       otherwise confidential and protected documents and information, or to
       seek appropriate safeguards of confidentiality for any competitively
       sensitive or proprietary information.

   11. Severability. The Parties agree that if any of the provisions of the
       Adopting Order or the Consent Decree shall be invalid or
       unenforceable, such invalidity or unenforceability shall not
       invalidate or render unenforceable the entire Adopting Order or
       Consent Decree, but rather the entire Adopting Order or Consent Decree
       shall be construed as if not containing the particular invalid or
       unenforceable provision or provisions, and the rights and obligations
       of the Parties shall be construed and enforced accordingly. In the
       event that this Consent Decree in its entirety is rendered invalid by
       any court of competent jurisdiction, the Consent Decree shall become
       null and void and may not be used in any manner in any legal
       proceeding.

   12. Subsequent Rule or Order. The Parties agree that if any provision of
       the Consent Decree conflicts with any subsequent rule or order adopted
       by the Commission (except an order specifically intended to revise the
       terms of this Consent Decree to which CMDC does not expressly
       consent), that provision will be superseded by such Commission rule or
       order.

   13. Successors and Assigns. CMDC agrees that the provisions of this
       Consent Decree shall be binding on its successors, assigns, and
       transferees.

   14. Final Settlement. The Parties agree and acknowledge that this Consent
       Decree shall constitute a final settlement between the Parties. The
       Parties further agree that this Consent Decree does not constitute
       either an adjudication on the merits or a factual or legal finding or
       determination regarding any compliance or noncompliance with the
       requirements of the Act or the Commission's Rules and orders. The
       Parties agree that this Consent Decree is for settlement purposes
       only, and that by agreeing to this Consent Decree, CMDC does not admit
       or deny any noncompliance, violation, or liability associated with or
       arising from its actions or omissions involving the Act or the
       Commission's Rules.

   15. Modifications. This Consent Decree cannot be modified without the
       advance written consent of both Parties.

   16. Paragraph Headings. The headings of the Paragraphs in this Consent
       Decree are inserted for convenience only and are not intended to
       affect the meaning or interpretation of this Consent Decree.

   17. Authorized Representative. Each party represents and warrants to the
       other that it has full power and authority to enter into this Consent
       Decree.

   18. Counterparts. This Consent Decree may be signed in any number of
       counterparts (including by facsimile), each of which, when executed
       and delivered, shall be an original, and all of which counterparts
       together shall constitute one and the same fully executed instrument.


     _______________________________    ________________________________    
                                                                            
     Susan McNeil                       Daniel S. Wood                      
                                                                            
     Deputy Bureau Chief                President                           
                                                                            
     Enforcement Bureau                 Comtech Mobile Datacom Corporation  
                                                                            
     ________________________________   ________________________________    
                                                                            
     Date                               Date                                


   47 U.S.C. S: 301.

   47 C.F.R. S:S: 25.102, 25.117, 25.136(d) and 25.276(a).

   47 U.S.C. S: 154(i).

   47 C.F.R. S:S: 0.111 and 0.311.

   47 U.S.C. S: 301.

   47 C.F.R. S:S: 25.102, 25.117, 25.136(d) and 25.276(a).

   Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division
   Enforcement Bureau to Joan M. Griffin, Counsel for Comtech Mobile Datacom
   Corporation (August 27, 2007).

   See Letter from Joan M. Griffin, Esq., counsel to Comtech Mobile Datacom
   Corporation, to Marlene H. Dortch, Secretary, Federal Communications
   Commission (Sept. 26, 2007).

   Federal Communications Commission DA 08-2034

   6

   5

   Federal Communications Commission DA 08-2034