Abstract
The 37/39 GHz band was fragmented in the United States under a mixture of license regimes for incumbent holdings. To unlock the considerable value of this band for 5G service, it would need to be wholly restructured in a way that respected incumbent property rights and created a level playing field. This is a white paper submitted to the FCC on behalf of AT&T outlining an auction design that would achieve all of this in a single auction process. The paper proposes to offer incumbents vouchers in an auction in exchange for their legacy licenses. The vouchers would entitle incumbents to an incentive payment corresponding to their holdings in MHz-pops at auction clearing prices. This paper formed the basis for the design ultimately adopted by the FCC for Auction 103.
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