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Public Knowledge and Open Technology Institute at �鶹������ý (“PK and OTI”) submitted these  in Opposition to the Petitions for Reconsideration regarding the Commission’s 2016 Spectrum Frontiers Order. Specifically, PK and OTI oppose efforts to reverse the allocation of 37-37.6 GHz band for non-exclusive shared access, the operability requirement across the entire 37-40 GHz band, the allocation for unlicensed spectrum in the 64-71 GHz band, and the cybersecurity disclosure rules adopted in the Report & Order. The Commission developed a balanced set of rules to govern the first batch of spectrum being dedicated to 5G technologies, with appropriate allocations for licensed, shared, and unlicensed use, with appropriate protections for federal users and incumbents. The Commission also adequately addressed its public interest obligations to protect consumers and the nation’s communications infrastructure, by continuing to seek information regarding cybersecurity practices. The Commission’s actions on these issues best serve the public interest, and the agency should not turn away from these strong policies. To the extent any of the Petitions fail to satisfy the requirements of the Commission’s rules for Petitions for Reconsideration by attempting to relitigate or revisit issues already resolved by the Commission.

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