Federal Communications Commission DA 12-1930
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Request by Progeny LMS, LLC for Waiver of 
Certain Multilateration Location and Monitoring 
Service Rules
)
)
)
)
)
WT Docket No. 11-49
ORDER
Adopted:  November 30, 2012 Released:  November 30, 2012
Extended Comment Filing Deadline:  December 21, 2012 
Extended Reply Comment Filing Deadline:  January 11, 2013
By the Chief, Wireless Telecommunications Bureau, and the Chief, Office of Engineering and Technology:
1. On November 20, 2012, the Wireless Telecommunications Bureau and the Office of 
Engineering and Technology released a Public Notice seeking comment on the Joint Testing Reports and 
on Progeny’s letter of October 31, 2012, that were submitted in WT Docket No. 11-49.1 In this Order, we 
extend the comment and reply comment filing deadlines in this proceeding to provide that comments are 
due on or before December 21, 2012, and reply comments are due on or before January 11, 2013.2  
2. On November 26, 2012, The Part 15 Coalition filed its Extension Request, in which it 
asks that the comment deadlines be extended to provide that comments be due no later than December 21, 
2012 and reply comments be due no later than January 21, 2013.3 The Part 15 Coalition asserts that the 
proceeding “presents complex technical questions regarding the interference effects of an M-LMS 
licensee on 902-928 MHz unlicensed devices,” and that “the Commission must be certain that it makes 
accurate findings.”4 The Part 15 Coalition further claims that the release of the Public Notice and the 
  
1 The Wireless Telecommunications Bureau and the Office of Engineering and Technology Seek Comment on 
Progeny’s Joint M-LMS Field Testing Reports, WT Docket No. 11-49 , Public Notice, DA 12-1877 (WTB, OET rel. 
Nov. 20, 2012) (Public Notice).  The Joint Testing Reports and Progeny’s October 31 Letter are identified in the 
Public Notice.  See id. at nn.1-4.  In addition, on November 20, 2012, the Wireless Telecommunications Bureau 
released a Protective Order in this proceeding.  Request by Progeny LMS, LLC for Waiver of Certain 
Multilateration Location and Monitoring Service Rules, Protective Order, DA 12-1877 (WTB rel. Nov. 20, 2012) 
(Protective Order).
2 Initially, under the Public Notice comments were due on or before December 11, 2012, and reply comments were 
due on or before December 21, 2012.   
3 The Part 15 Coalition Request for Extension of Comment and Reply Comment Deadlines, WT Docket No. 11-49, 
filed November 26, 2012 (Extension Request).  The Part 15 Coalition states that it is composed of entities that 
manufacture, use, and/or represent users of unlicensed Part 15 devices that operate in the 902-928 MHz band.  Id. at 
2.  Its members are the American Petroleum Institute, Elster Solutions, Itron, Inc., Landis+Gyr Company, Notor 
Research, Silver Spring Networks, Utilities Telecom Counsel, and Wireless Internet Service Providers.  Id. at 
Attachment A.  On November 29, 2012, Public Knowledge and the New America Foundation filed an ex parte
submission in support of the Extension Request.  See Letter from Harold Feld, Public Knowledge, and Michael 
Calabrese, New America Foundation, to Michael H. Dortch, FCC, WT Docket No. 11-49, filed Nov. 29, 2012.     
4 See Extension Request at 3.
Federal Communications Commission DA 12-1930
2
Protective Order creates a situation where parties “will effectively be left with only seven business days 
to review materials and prepare comments.”5 The Part 15 Coalition states that an extension of time is 
necessary and would be in the public interest “[g]iven the complexity and volume of the data and 
importance of the FCC’s decision in this proceeding.”6
3. On November 27, 2012, Progeny LMS, LLC (Progeny) filed an opposition to the Joint 
Motion.7 Progeny claims that adherence to the comment schedule is “particularly justified in this case 
given the growing and critical need for the E911 position location services that Progeny seeks to provide 
to support emergency first responders.”8 Progeny also asserts that many of the Part 15 Coalition members 
have had lengthy access to the Joint Testing Reports, and that those members have “worked jointly with 
Progeny to develop and conduct the tests” or have been “clearly aware” that the Joint Test Reports were 
filed and made public before release of the Public Notice.9 Progeny further claims that the release of the 
Protective Order does not warrant an extension, and disagrees with the suggestion that the analysis of the 
test reports may be “rushed” or inaccurate.10  
4. The Commission’s policy, as set forth in Section 1.46(a) of its rules,11 is that extensions 
of time are not routinely granted.  In the instant case, however, we find that under these particular 
circumstances granting an extension of the comment and reply comment periods will serve the public 
interest by allowing all parties additional time to consider issues in the proceeding.  Under the 
circumstances of this proceeding, we find that the request for ten additional days for filing comments to 
be reasonable, and we extend the comment period until December 21, 2012.  We also provide ten 
additional days for filing reply comments and extend the reply comment deadline until January 11, 2013, 
which we find to be sufficient for this proceeding. 
5. Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the Communications Act 
of 1934, as amended, 47 U.S.C. § 154(i), and sections 0.131, 0.331, and 1.46 of the Commission’s Rules, 
47 C.F.R. §§ 0.131, 0.331, and 1.46, The Part 15 Coalition’s Request for Extension of Comment and 
Reply Comment Deadlines IS GRANTED IN PART AND DENIED IN PART.
6. IT IS FURTHER ORDERED that, pursuant to section 4(i) of the Communications Act of 
1934, as amended, 47 U.S.C. § 154(i), and sections 0.131, 0.331, and 1.46 of the Commission’s rules, 47 
C.F.R. §§ 0.131, 0.331, and 1.46, the deadline to file comments in this proceeding is extended to 
December 21, 2012 and the deadline to file reply comments in this proceeding is extended to January 11, 
2013.
  
5Id. at 3-4.
6Id. at 4.
7 Opposition of Progeny LMS, LLC, WT Docket No. 11-49, filed November 27, 2012 (Opposition).
8 Id. at 1.
9 Id. at 3-4.
10 Id. at 4-5.
11 47 C.F.R. § 1.46(a).
Federal Communications Commission DA 12-1930
3
FEDERAL COMMUNICATIONS COMMISSION
Ruth Milkman
Chief, Wireless Telecommunications Bureau
Julius P. Knapp
Chief, Office of Engineering and Technology