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Mr Mark Arkell Manager Spectrum Planning Spectrum Planning and Engineering Branch Australian Communications and Media Authority PO Box 78 Belconnen ACT 2616 Dear Mr Arkell, I refer to the recently released discussion paper, Proposed update to the Australian Radiofrequency Spectrum Plan, and the request by the Australian Telecommunications and Media Authority (ACMA) for public comment on the proposed changes. Gogo thanks the ACMA for the opportunity to provide feedback on this proposal. Gogo (www.gogoair.com, NASDAQ:GOGO) is a US-based provider of in-flight communications (IFC) and in-flight entertainment (IFE) services. These services are offered in North America via Gogo’s air-to-ground network and, globally, via satellite based aircraft access. The Gogo system comprises of an onboard Wi-Fi network and Ku-band satellite air earth stations (AES) to provide a connection between the aircraft and the Internet via satellites in geostationary orbits and terrestrial infrastructure. There is increasing airline and passenger demand for IFC and IFE services, including the provision of services in Australia by both domestic and international airlines. Gogo is responding to this increasing market demand by evaluating opportunities to expand its business globally. In view of this, Gogo notes the proposal to add a new subsection 10.9 to the Australian Radiofrequency Spectrum Plan, as follows:

10 Use of frequency bands — other circumstances

(9) A frequency band may be used by a mobile earth station receiver in a frequency band allocated for a fixed-satellite service (space-to-Earth).

Gogo also notes the ACMA’s explanatory comments that: “This provision is intended to add flexibility to the type of devices that can be used to receive satellite transmissions. As the proposed subsection applies only to receivers, and as the transmitting satellites would have already completed (or be in the process of completing) the ITU satellite coordination process, it is considered that there is no risk of assignments made under this proposed provision interfering with other services”.

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Gogo strongly supports the addition of the new subsection 10.9 as proposed and agrees with the ACMA’s comments. This change will remove an anomaly with the Australian Spectrum Plan which is not reflected in other jurisdictions. It will reduce unnecessary regulatory and licensing burden for the ACMA, IFC providers and other companies seeking to offer MSS-based services to the Australian market. In this respect, it is relevant that, as stated by the ACMA, the objects of the Act and its Principles for Spectrum Management are “....to maximise the overall public benefit derived from the use of the radiofrequency spectrum”. Facilitating a reduction in regulation and compliance, responding to increasing market and consumer demand and providing industry certainty and flexibility will all be positive outcomes of this proposed change. Please let me know if you wish additional information or to discuss this matter further. Yours sincerely,

Greg Oliveau International Market Development