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Response to SEC Comment Letter

 Milbank, Tweed, Hadley & McCloy LLP

 1 Chase Manhattan Plaza

 New York, NY 10005-1413

 November 4, 2005

 Intelsat, Ltd.

 Form 20-F for Fiscal Year Ended December 31, 2004

 Form 10-Q for the Fiscal Quarters Ended June 30, 2005

File No. 0-50262

 Mr. Larry M. Spirgel

 Division of Corporation Finance

 Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D.C. 20549

 Dear Mr. Spirgel:

 We note the receipt by
Intelsat, Ltd. (the “Company”), a Bermuda corporation, of the comment letter (the “Comment Letter”) dated October 12, 2005 from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) regarding the above-referenced Form 20-F (the “Form 20-F”) and the above-referenced Form 10-Q (the “Form 10-Q”). On behalf of the Company, we hereby provide the responses set forth below to the comments in
the Comment Letter.

 We also hereby submit for filing by direct
electronic transmission a Registration Statement on Form S-4 (the “Form S-4”), relating to the exchange offer of Intelsat Subsidiary Holding Company, Ltd., a Bermuda corporation and wholly owned subsidiary of the Company, for its
$1,000,000,000 Floating Rate Senior Notes due 2012, $875,000,000 8 1/4% Senior Notes due 2013 and $675,000,000
8 5/8% Senior Notes due 2015 and the related guarantees of the Company and certain subsidiary guarantors,
previously issued and sold pursuant to Rule 144A and Regulation S under the Securities Act of 1933, as amended. Where appropriate, disclosure also has been added by the Company to this Form S-4 that responds to the Staff’s comments provided in
the Comment Letter. This filing is accompanied by a separate letter from the Company providing the representations set forth in the relevant Commission no-action letters regarding Exxon Capital exchanges.

 To assist the Staff review, we have included the text of the Staff’s
comments below in bold type. Except as otherwise noted in this letter, the information provided in response to the Staff’s comments has been supplied by the Company, which is solely responsible for such information.

 Adjusted EBITDA, page 66

1.
We note that Adjusted EBITDA is a covenant measure defined by your credit agreement dated January 28, 2005. In future filings please revise to present this measure and the
discussion of this measure in your liquidity discussion. Also, present the required Adjusted EBITDA amounts included in covenants.

 The Company believes that Adjusted EBITDA, like EBITDA, is a useful measure of its operating performance. However, as requested in the Comment
Letter, the Company has included the discussion of Adjusted EBITDA in the Form S-4 (this calculation is called Covenant EBITDA in the Form S-4 for the sake of consistency with the Company’s recent earnings releases) in the
“Liquidity and Capital Resources” section of “Management’s Discussion and Analysis of Financial Condition and Results of Operations” (“MD&A”), and will continue to do so in future filings. Also, as
requested, disclosure has been included in the aforementioned discussion of Adjusted EBITDA in the Form S-4 to describe how this term is used in the covenants included in the Company’s credit agreement and indentures.

 Report of Independent Registered Public Accounting Firm, page F-2

2.
Please revise to identify the independent registered public accounting firm.

 The Staff observed that the name of the Company’s auditors, KPMG LLP (“KPMG”), was omitted
from KPMG’s audit report on page F-2 of the Form 20-F. The Company wishes to inform the Staff that this was an inadvertent, typographical error that occurred when the Form 20-F was being edgarized for filing with the SEC. The Company did
receive a signed audit report from KPMG in connection with their audit of the Company’s 2004 and 2003 financial statements and has the signed report in its files. The audit report contained in the Form S-4 for these same periods does
indicate that KPMG signed the audit report included therein, and the Company will ensure that audit reports in future filings clearly identify KPMG.

Consolidated Statement of Cash Flows, page F-6

3.
Please tell us, citing accounting literature used, why you include deferred satellite performance incentives in cash flows from financing activities.

 The Company advises the Staff that Note
2(u) of the Form 20-F (as well as Note 2(u) to the Company’s consolidated financial statements for the year ended December 31, 2004 included in the Form S-4) describes the Company’s accounting for deferred satellite performance
incentives and states the following:

 “The cost of satellite construction includes an element of deferred consideration to satellite manufacturers referred to as satellite performance incentives. Intelsat is contractually obligated to make these payments over the lives of
the satellites, provided the satellite continues to operate in accordance with contractual specifications. Historically, the satellite manufacturers have earned substantially all of these payments. Therefore, the Company accounts for these payments
as deferred financing. The Company capitalizes the present value of these payments as part of the cost of the satellites and records a corresponding liability to the satellite manufacturers. These costs are amortized over the useful lives of the
satellites and the liability is reduced as the payments are made.”

 The Company believes that deferred satellite incentives are in substance long-term financing for the purchase of property, plant and equipment since such payments relate to the construction of satellites

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 and it is contractually obligated to make these payments over the lives of the satellites. The Company does not believe
these payments relate to transactions that enter into the “determination of income”, as described in paragraph 21 of Statement of Financial Accounting Standards (“SFAS”) No. 95, “Statement of Cash Flows”
which defines operating activities. The classification of payments for deferred satellite incentives as financing activities is accounted for in accordance with paragraph 20.c of SFAS No. 95. As noted, footnote 8 to paragraph 20.c
indicates, “…most principal payments on seller’s financed debt directly related to a purchase of property, plant, and equipment or other productive assets are financing cash flows.” Accordingly, since such payments relate to the
cost of satellite construction, the Company believes that its accounting for deferred satellite incentives is in accordance with the interpretation of paragraph 20.c of SFAS No. 95.

 Note 19 Contingencies, page F-33

 (b) Litigation and claims, page F-33

4.
We note on your Form 8-K filed on March 16, 2005 that “Subsequent to the issuance of its earnings release dated March 3, 2005, the Company updated its results
to include the effect of a $1.7 million judgment in favor of certain of its former employees in respect of certain wrongful termination and related claims.” We also note that you do not disclose the $1.7 million judgment in your notes
to your financial statements. Tell us and disclose in future filings all instances for which material reserves are required in accordance with SFAS 5 and FIN 45.

 The Company notes the Staff’s comment and in future filings, if applicable, the Company will disclose all instances of
material reserves in accordance with SFAS No. 5, “Accounting for Contingencies,” and Financial Accounting Standards Board Interpretation (“FIN”) No. 45, “Guarantor’s Accounting and Disclosure
Requirements for Guarantees, Including Indirect Guarantees of Indebtedness of Others—an interpretation of FASB Statements No. 5, 57, and 107 and rescission of FASB Interpretation No. 34.”

 The Company supplementally advises the Staff that it does not currently have
any material reserves required under SFAS No. 5 or Fin No. 45. Disclosure of the Company’s known contingencies and claims has been provided in Note 19 of the Form 20-F and Note 12 of the Form 10-Q, as well as in the comparable notes
to the consolidated financial statements included in the Form S-4.

 The Company also supplementally advises that it did not believe this employee litigation was material to the operating results of the Company and previous disclosure was adequately covered in the “normal course litigation” note of
the Company’s periodic filings. Note 15(b) of the Company’s Form 6-K for the quarter ended September 30, 2004 stated the following:

 “The Company is subject to litigation in the normal course of business, but management does not believe that the resolution of any pending
proceedings would have a material adverse effect on the Company’s financial position or results of operations.”

 Following the Company’s receipt of the court ruling, rendered by the labor court of Toulouse, France on January 31, 2005 and before the Company
filed its financial statements with the SEC, the Company accounted for this judgment in accordance with paragraph 8.a of SFAS No. 5.

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 Note 20 Business segment and geographic location, page F-35

5.
We note on page 60 of your Results of Operations that you disclose a table that sets forth revenue by service commitment type. In future filings please disclose revenues from
external customers for each service or group of similar services as required by paragraph 37 of SFAS 131.

 The Company believes it has complied with paragraph 37 of SFAS No. 131, “Disclosures about Segments of an Enterprise and Related
Information,” since currently substantially all of its revenue is from one service, providing capacity on its fleet of satellites to customers. In the “Results of Operations” section of MD&A in the Form 20-F and in the Form
S-4, the Company has further disaggregated revenue by type of capacity. The Company’s disaggregation is based, in part, on the term, volume and specifications of its customer service contracts. The Company believes that this disaggregation of
capacity follows industry practice.

 Note 25 Quarterly Financial
Information - Unaudited

6.
Tell us why operating income (loss) was particularly low in the quarter ended December 31, 2003 and 2004. In future filings, disclose any seasonality or trend regarding
quarterly financial information presented.

 The Company notes the Staff’s comment and in future filings, the Company will disclose any seasonality or trends, if applicable.

 The Company supplementally advises the Staff that for the quarter ended December 31, 2003, operating income (loss) was lower than previous quarters
because of a decline in quarterly revenue and increasing fixed costs. Revenue was down for the quarter primarily attributable to lower renewals of service agreements and renewals at lower prices in certain markets. This is consistent with the
revenue trend described on page 54 of the Form 20-F under the heading “Trends Impacting Our Revenue” and in the corresponding section in MD&A in the Form S-4 which states “. . . since 2001, we have been experiencing an overall
decline in revenue that we expect will continue in the near term.” Expenses for the quarter followed an increasing trend throughout 2003 as the Company expanded its terrestrial infrastructure for the provisioning of hybrid and managed service
offerings. In addition, operating expenses during the quarter were somewhat higher as the Company incurred expenses preparing for the closing and integration of the Intelsat Americas assets that were purchased in March 2004.

 For the quarter ended December 31, 2004, the Company’s operating
income (loss) was lower than previous quarters because of a non-cash impairment charge of approximately $84.4 million during the quarter related to an anomaly on the Company’s IA-7 satellite. The anomaly and impairment charge are described in
detail on page 57 of MD&A and Note 9 on page F-19 of the Form 20-F and in corresponding places in MD&A and in the notes to the consolidated financial statements included in the Form S-4.

 The Company does not currently believe seasonality or trends affect its
quarterly results.

 Disclosure has been added to the Form S-4
in Note 25 of the consolidated financial statements for the year ended December 31, 2004 as follows:

 “The Company’s quarterly revenues and operating income are not impacted by seasonality since customer contracts for satellite
utilization are generally long-term. The decline in operating income during the quarter ended December 31, 2003 was due to a decline in revenue associated with lower renewals of service agreements and renewals at lower prices in certain
markets.

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 Expenses increased as the Company expanded its terrestrial infrastructure for the provisioning of hybrid
and managed service offerings. The decline in operating income during the quarter ended December 31, 2004 was due to the one-time charge of approximately $84.4 million related to the partial failure the IA-7 satellite.”

 Form 10-Q for the Fiscal Quarters ended June 30, 2005

 Results of Operations, page 22

 Selling, General and Administrative, page 26

7.
We note that the increase in selling, general and administrative expenses was primarily due to increases in professional fees of $46.2 million, incurred mainly in connection
with the Acquisition Transaction. We also note on page 62 of your Form 20-F for the Fiscal Year Ended December 31, 2004 that the increase in selling, general and administrative expenses was due primarily to increases in professional fees
of $11.9 million mainly due to the acquisition of yourself by Intelsat Holdings. Tell us why you recorded cost related to Intelsat Holdings acquisition of yourself (pre and post acquisition) in SG&A expense. Tell us why these costs were not
used to establish a new accounting basis of your company. Refer to your basis in accounting literature.

 The Company supplementally advises the Staff that under terms of the Intelsat Holdings acquisition agreement, the Company and the investors which formed
Intelsat Holdings (the “Investors”) separately paid transaction fees related to this acquisition individually incurred. The Investors did not reimburse the Company for transaction fees nor does the Company expect to receive reimbursement.
Since the Company was not the acquiring entity, the consideration received from the buyers contemplated that each party would pay their own transaction costs. These costs were indirect and general expenses related to the business combination,
professional fees incurred by the predecessor company to market itself and consummate the sales transaction were expensed in accordance with SFAS No. 141, “Business Combinations.”

 The Company believes that its treatment of professional fees related to the
Acquisition Transactions is in accordance with paragraph 24 of SFAS No. 141, which states,

 “The cost of an entity acquired in a business combination includes the direct costs of the business combination. Costs of registering and issuing
equity securities shall be recognized as a reduction of the otherwise determinable fair value of the securities. However, indirect and general expenses related to business combinations shall be expensed as incurred.”

 The Company recorded amounts during the year ended December 31, 2004 and
the period January 1 to January 31, 2005 (the predecessor entity periods). No professional fees related to the Intelsat Holdings acquisition have been recorded in the successor entity reporting period (February 1, 2005 to June 30,
2005). As described on pages 22-23 of the Form 10-Q and in the interim periods “Results of Operations” section in MD&A in the Form S-4, the Company combined the predecessor entity and successor entity reporting periods for comparative
discussion purposes in MD&A.

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 Note 7 Satellite developments, page 13

8.
We note that you have entered into a revenue share agreement with New Skies Satellites N.V. for alternate capacity provided to certain customers. Please tell us and disclose in