SiriusXM: The Expensively Bought Monopoly with the Asset-Light Wild Card

The Form 10-Q for the quarter ended 30 June 2026 contains two numbers that make an odd pair: income from operations of $926m for the first half, and goodwill of $12.390bn, larger than all the rest of the group's invested capital combined [1]. More than half of what sits inside SiriusXM is the premium paid for past acquisitions: XM, Pandora, the Liberty transaction. On that capital base the company earns just about its cost of capital. On the part that actually operates satellites, sells subscriptions and delivers advertising, it earns two and a half times as much.

The market's scepticism therefore has a valid core: streaming is putting the in-car subscription under pressure, leverage is high, and the goodwill comes from acquisitions that were too expensive. I hold the facts to be right and the conclusion to be wrong. Anyone reading SiriusXM only as a balance-sheet capital base misses that it contains two different companies: an expensively bought acquisition vehicle that barely covers its cost of capital, and a highly profitable, capital-free operating business that is just beginning to build an advertising platform.

Against the 5 September version, this revision cuts the fair value. The reason does not lie in the two-companies thesis, which is confirmed, but in the quality of the free cash flow my model rests on. The reasoning sits in the section on open assumptions.

The foundation: the cash machine

SiriusXM is a subscription business with satellite-based infrastructure and roughly 32.9 million subscribers, almost all of them in vehicles [1]. The second quarter of 2026 shows how resilient this machine is: adjusted EBITDA $691m (+3% year on year), free cash flow $593m (+48%), and the first positive self-pay net additions in four years at 22,000 [1]. Self-pay churn fell to 1.4% and ARPU rose to $15.32 [1].

The mechanism behind this is the most important point of this section: subscription revenue grows despite a nearly flat subscriber count, because higher prices per user more than offset volume erosion. Management expects this constellation to continue. For 2026 it guided to free cash flow of around $1.35bn, and for 2027 it targets $1.5bn [2]; with the Q2 results it raised the 2026 outlook to $1.375bn [17].

One qualification belongs with those net additions. On the Q1 call, management put the contribution of companion subscriptions, meaning second and household subscriptions for existing customers, at 124,000 additional self-pay net additions in the first quarter [11]. Against reported net additions of minus 111,000 in the same quarter, that means the quarter would have been at roughly minus 235,000 without this upsell to its own base. For the second quarter the company has not disclosed the share, neither in the filing nor on the call. CEO Jennifer Witz has herself pointed out that take rates can mature. An upsell into a known installed base is finite by construction.

At a market capitalisation of roughly $8.89bn (price $26.36 × 337.1m shares, as of 6 October 2026), that implies a free cash flow yield between 13.8% and 15.5%, depending on which cash flow base is used: the adjusted base of $1.230bn or the raised guidance of $1.375bn [9][17]. The foundation is not the story, though. It is the base the story stands on.

The return-on-capital analysis: two companies in one

I measure return on invested capital (ROIC) against the cost of capital (WACC), and on that measure SiriusXM splits in two. The basis is the first half of 2026 from the 10-Q filed 30 July 2026, annualised [1]. The 22% tax rate and the WACC are my own assumptions.

The reading follows the logic of my serial-acquirer analyses: ROIC including goodwill measures the return on the price actually paid, ROIC excluding goodwill the operating efficiency of the core business. At SiriusXM the two are far apart.

On the price paid, SiriusXM earns 6.8% against a 6.5% cost of capital; the spread is effectively zero. The acquisition history (the XM merger, Pandora, the Liberty transaction) has tied up capital at a return that covers costs today but creates no value. The cumulative goodwill impairment of $3.78bn, of which $2.82bn came from the 2024 Liberty deal alone, is the accounting evidence [1].

The operating core business, by contrast, earns 16.4%, roughly ten percentage points above the cost of capital. That is an excellent figure, protected by the moat.

On top of that comes the reinvestment rate of −13%: depreciation and amortisation, largely the amortisation of acquisition intangibles, clearly exceeds maintenance capex. SiriusXM does not need to reinvest on a net basis to sustain operations. That is the textbook profile of a mature, capital-light business with high free cash flow, and it explains why the free cash flow yield is so high despite a mediocre overall ROIC.

The conclusion from this calculation is precise: future value creation must not come from the capital-intensive acquisition path, because there the spread is zero. It has to come from the capital-free core business with its positive spread. And that is where the advertising platform sits.

Where the profit comes from, and where the growth

The second quarter's segment split is instructive for the thesis in two ways [1].

On a half-year basis the ratio is 87 to 13: of $2,249m in segment gross profit, $1,947m came from SiriusXM and $302m from Pandora [1]. In the second quarter alone it shifts to 86 to 14, because Pandora's gross profit rose from $139m in Q1 to $163m while the satellite side moved only from $966m to $981m [3]. The satellite subscription remains the cash machine: mature, high-margin, under slow structural pressure. The advertising growth core is gaining share, but slowly.

On advertising revenue the picture brightened in the second quarter. Group-wide it rose 5% to $454m, and the classic satellite segment turned positive again at $41m against $38m, after shrinking 10% in Q1 [1]. Pandora and off-platform advanced to $413m [1].

The bet is therefore clearly framed: does this 14 percent block scale fast enough to offset the slowly eroding 86 percent subscription block, and do so at a reinvestment rate near zero, meaning without tying up new capital?

SiriusXM Media becomes an audio advertising platform

This is the part the consensus has not priced in, in my assessment, and it is the only value-creating path the ROIC analysis permits.

Under the SiriusXM Media banner the company is building a position that has little left in common with the old satellite business. The backbone is AdsWizz, its in-house ad-tech subsidiary for programmatic delivery, targeting and measurement. Three building blocks sit on top of it:

Podcasting grew 41% in 2025 [6] and a further 37% in Q1 2026 [2]. More telling than the rate is the how: programmatic podcast demand rose more than 92% year on year, meaning automated, data-driven, measurable [2]. By its own account SiriusXM is the largest adult podcast network, with roughly 170m listeners across digital audio [6].

Amazon DSP has made the inventory bookable with first-party data and clean-room technology since September 2025 [5]. I see that as the trigger for the jump in programmatic demand.

The Google/YouTube coup is the single most important announcement of the year: since April 2026 SiriusXM Media has been the exclusive audio advertising representative for YouTube in the United States [4]. YouTube is the world's largest podcast platform, with more than 212m monthly US audio users [4]. Through AdsWizz, advertisers can for the first time book guaranteed audio impressions against YouTube audiences.

One figure from this context deserves clarification, because it is easily misused. In its Q1 presentation SiriusXM writes that the agreement expands its own reach to roughly 255m monthly listeners [10]. That is the combined reach after the deal, not SiriusXM's own listenership, and not the same as the 212m YouTube audio users. Comparing the 255m against earlier reach figures of 160m to 170m measures a change of perimeter, not growth.

On timing the September correction stands: material revenue contributions are not to be expected before the second half of 2027. The deal remains the strongest qualitative evidence for the AdsWizz platform, but it is not a catalyst for the next twelve months.

What the advertising numbers do not show

Beneath the surface of the advertising growth sits a development I underestimated in the previous version. Pandora's user base is shrinking faster than monetisation is rising. In the second quarter, ad-supported listener hours fell 9% to 2.35bn and monthly active users fell 7% to 39.8m. Revenue per thousand listener hours rose only 2%, to $87.67 [1].

The segment's advertising growth therefore comes from podcasting and programmatic demand while the music streaming core loses reach. Growth on a shrinking base with better monetisation has a different durability than growth from gains in reach. For the thesis that means the podcast and platform part must not merely grow; it must also absorb the erosion of the Pandora core before anything is left over on a net basis. That pushes back the point at which the 14 percent block carries the 86 percent block. It does not refute the thesis, but it lengthens it.

The merger option: iHeartMedia, the AM Act and FM

In April 2026 several outlets reported that music mogul Irving Azoff was considering combining SiriusXM and iHeartMedia into a single audio entity. The strategic logic lay not in AM radio but in podcasting: both are growing strongly there (iHeart +25.6% to $563.7m in 2025 [7]; SiriusXM +41% [6]).

On 31 May 2026 the New York Times reported that the talks had failed over terms, for now [8]. A revival is not ruled out. CEO Jennifer Witz had already pre-emptively deflected the topic on the Q1 call.

The merger was always the option, never the foundation. An important piece of context: the AM Radio for Every Vehicle Act, which I put at an 85–90% probability of passing, compels the automakers to fit AM tuners, not SiriusXM. It does stabilise iHeartMedia, whose terrestrial business (AM and FM, together 860+ stations, 278m listeners) would otherwise erode faster under roughly $5bn of debt [7].

A merger would not be a forced transaction but an opportunistic one: in a distress scenario SiriusXM would bring podcast reach, the entire FM inventory and iHeart's AudioGraph data under one AdsWizz roof, meaning full control of the value chain instead of revenue sharing. After 31 May, though, I treat that as a bonus rather than an expectation.

The spectrum: 10 MHz that are not free

Spectrum regularly comes up as hidden value in discussions of SiriusXM. The company holds 35 MHz of contiguous mid-band spectrum, carried as an indefinite-lived intangible asset at $8.610bn [1]. Of that, 25 MHz belongs to the Sirius and XM satellite networks and the remaining 10 MHz to the WCS C and D blocks acquired in 2024, which flank the core on either side [1].

Those 10 MHz are taken to be the unencumbered part. On closer inspection that is wrong. The FCC approved the transfer from AT&T to SiriusXM in November 2024 only conditionally, and for the stated purpose of building a satellite-based emergency communications service for public agencies [12]. AT&T had held the blocks under build-out obligations and, after abandoning its smart-grid plan, faced losing the licences.

The conditions are strict. SiriusXM must provide the service to FEMA free of charge, actively market it, and connect a growing number of agencies through to the end of 2029. The interim step of at least 200 end users outside FEMA fell due on 26 May 2026. If the company misses any one of the conditions, both licence blocks terminate automatically [12]. In March 2026, two months before that deadline, SiriusXM was still recruiting participants for the service at a training session of the US public-safety communications association APCO [13].

Whether the condition was met cannot be established publicly, and that will remain so for now: the conditions do not require a first filing with the FCC — the construction notifications for both blocks — until 10 December 2029 [12]. In the quarterly reports for 31 March and 30 June 2026 the terms FEMA, emergency and public safety do not appear once [1]. The history belongs in any assessment of the forfeiture risk: the same licences have faced termination twice before. In 2017 the FCC granted AT&T a waiver with a deadline of September 2021, and 2024 brought the conditional relief that moved the blocks to SiriusXM [12]. The forfeiture clause has not yet bitten on these licences.

A second FCC proceeding covering the same band points in the opposite direction. In April 2026, under Docket 26-54, the FCC proposed opening the 25 MHz of satellite radio spectrum between 2320 and 2345 MHz on a secondary basis for spacecraft command uplinks, Earth-to-space only [15]. Anyone wanting to operate an earth station there would have to certify that the operation has been coordinated with and approved by SiriusXM. The FCC states explicitly that it is reasonable for SiriusXM to require financial compensation for this [15]. Comments closed on 11 May and replies on 8 June 2026.

The docket contains two submissions by SiriusXM itself on this proposal, dated 11 May and 8 June 2026 [18]. They make the company's position documented rather than inferred. SiriusXM supports the proposal on one condition, which it repeats three times: a leasing framework in which it has "the option – but not the obligation" to enter agreements. Any duty to lease or to coordinate is rejected, as is any use in the space-to-Earth direction. And when the agency asks whether the WCS C and D blocks should be opened as well, SiriusXM answers twice with "premature": the satellite band should serve as the test bed first, and the WCS blocks should be left alone until the company's own services are running there [18]. The company is therefore declining an additional way to monetise the 10 MHz in order to commercialise the 25 MHz first — a statement about management's priorities that appears in no annual report.

The S-band part has not been decided. The FCC meeting of 30 September 2026 handled Docket 26-54 bundled with four other proceedings and adopted an order on 12.7 and 42 GHz, a further notice on the Ku, Ka and D bands, and a second further notice adding more bands to the proceeding. On the satellite band, nothing was adopted [16]. The proceeding was broadened, not concluded.

For the valuation I still assign no separate value to the spectrum, but no longer on the grounds that there is nothing there. The 10 MHz carry a service obligation with a forfeiture clause, the 25 MHz are tied to the installed base of roughly 33 million subscribers, and for exactly those 25 MHz there is a proposal on the table that would give SiriusXM a consent right and compensation for a secondary use. I conservatively assign no value to an undecided proceeding. There is no unencumbered block in this band, but there is an open revenue option.

Valuation: what the stock is worth

My DCF model uses the free-cash-flow-to-equity method: SiriusXM reports levered free cash flow after interest, so I discount directly at the cost of equity. The central insight is the high sensitivity to the discount rate, to terminal growth and, new in this version, to the cash flow base applied.

The scenarios below stand on the adjusted base I explain in the next section.

Apply company guidance of $1.375bn for 2026 and $1.5bn for 2027 unchanged instead of the adjusted base, and the same base case yields $38 rather than $34. That span of $34 to $38 is my fair-value statement; the difference between its two ends is purely a question of cash flow quality, not of discounting.

The bear case remains to be taken seriously

The SAC point deserves context, because it works against the growth thesis. Subscriber acquisition cost per installation rose 18% in the second quarter to $21.32, after an almost unchanged $18.80 in the first [3]. The filing names higher subsidy rates at certain automakers, more expensive chipsets and, for the first time explicitly, higher memory costs. The only new risk factor in the Q2 report addresses exactly this topic and cites AI-driven demand for memory among its drivers [1]. In absolute terms it barely registers yet, because installation volumes are falling: total SAC rose only from $107m to $109m. Should new-vehicle fitment pick up again, the cost pressure comes through in full.

Conclusion

SiriusXM is two companies in one. The balance-sheet picture, expensively bought and barely covering its cost of capital, justifies the market's scepticism. The operating core business at 16.4% ROIC, capital-free and with a growing advertising platform, does not.

The investment question is therefore precise: does the asset-light advertising business scale fast enough to offset the slowly eroding subscription block? My DCF-based value is $34–38 (base case $34 on an adjusted cash flow basis), roughly 29% to 44% above the price of $26.36 (06.10.2026). Against the 5 September version that is a cut, and it comes not from weaker operating performance but from a stricter reading of the reported cash flow.

The advertising platform story could push the value higher once the YouTube deal shows revenue, which on current information will not turn material until the second half of 2027. Buy the deal as a catalyst and you are buying a catalyst with a good year of lead time. The merger bull case has lost probability since 31 May but is not off the table.

Update log

• 08.10.2026 — Full reconciliation of every figure cited to [1] against the original Form 10-Q for the quarter ended 30.06.2026. All values confirmed, including the ROIC calculation (invested capital $21,197m, of which goodwill $12,390m), the cumulative goodwill impairment, every operating metric, the buyback figures, and the finding that FEMA, emergency and public safety do not appear once in the report. One correction: the first-quarter SAC of $18.80 is not in the Q2 report but in the Q1 10-Q — the footnote now points to source 3. No change of substance.
• 07.10.2026 (2) — Guidance contradiction resolved: the DCF model now anchors 2026 on the raised $1.375bn rather than $1.35bn, which lifts the adjusted base from $1.205bn to $1.230bn. The per-share values move by less than ten cents; fair value $34–38, base case $34 and the scenario values are unchanged. The accompanying Excel model now carries both cases and returns $38.19 on a guidance basis and $34.47 adjusted. Free cash flow yield therefore 13.8% to 15.5%. Position disclosure put in the first person, stats.color made uniform, the six missing source links supplied, and the date of the iHeartMedia release corrected to 02.03.2026.
• 07.10.2026 — Price basis updated from $25.88 (30.09.2026) to $26.36 (06.10.2026): market capitalisation $8.89bn, free cash flow yield 13.6% to 15.2%, distance to fair value 29% to 44%, scenario distances +6%, +29% and +52%. Deadline in the spectrum section corrected: the first filing with the FCC is the construction notifications due 10.12.2029, not 26.11.2029. The two SiriusXM submissions in Docket 26-54 added (source 18) and the description of the FCC meeting of 30.09. made precise. Missing links in sources 16 and 17 supplied. Fair value $34–38, base case $34, scenario values and rating unchanged.
• 01.10.2026 — Price basis updated from $29.15 (12.09.2026) to $25.88 (30.09.2026): market capitalisation $8.72bn instead of $9.83bn, free cash flow yield 13.8% to 15.5% instead of 12% to 14%, distance to fair value 31% to 47% instead of 17% to 30%, scenario distances +8%, +31% and +55% instead of −4%, +18% and +37%. The rating rationale has been rewritten because my 15% annual hurdle is now arithmetically reachable in the base case; rating unchanged at Hold. Spectrum section extended with FCC proceeding 26-54 (proposed coordination consent and compensation for SiriusXM), the 2029 filing date and the forfeiture history of the WCS licences; still no separate value for the spectrum. Increase of the 2026 FCF guidance to $1.375bn stated, not incorporated into the model. Fair value $34–38, base case $34 and scenario values unchanged.
• 12.09.2026 — Q2 2026 figures from the Form 10-Q fully incorporated (advertising revenue, segment gross profit, Pandora reach, SAC, debt, buybacks). Fair value cut from $35–40 to $34–38 and the base case from $38 to $34: the 2026 FCFE base was adjusted down by roughly $145m to $1.205bn, because the filing attributes that part of the cash flow increase to lower cash taxes and "favorable timing". Rating unchanged at Hold. Newly added: section on the WCS spectrum conditions, section on Pandora's reach erosion, companion-subscriptions context, SAC and memory-price risk. Price basis $29.15 (12.09.2026).
• 05.09.2026 — Language revision to house style, list of sources added; figures and valuation unchanged.
• 04.09.2026 — Q2 figures from the Form 10-Q for 30 June 2026 incorporated: ROIC 6.8% including and 16.4% excluding goodwill (previously 6.6% and 15.7%); YouTube deal timeline corrected to H2 2027 (previously autumn 2026). Price basis updated to $29.77 (03.09.2026).
• 02.06.2026 — First publication, based on the Q1 2026 report.
• 31.05.2026 — Addendum to the first version: talks on combining SiriusXM and iHeartMedia had failed for the time being, according to the New York Times; the merger option has been treated as a bonus rather than an expectation since.

Sources

1. Sirius XM Holdings Inc., Form 10-Q for the quarter ended 30 June 2026, SEC filing dated 30.07.2026. Income from operations H1 2026, total debt, equity, cash, goodwill and cumulative goodwill impairment, segment gross profit Q2 and H1 2026, subscriber count, adjusted EBITDA, free cash flow and its drivers, self-pay net additions, churn, ARPU, SAC per installation and in absolute terms, advertising revenue by segment, Pandora listener hours, MAU and RPM, share buybacks, FCC licences and spectrum allocation, memory-cost risk factor, New York litigation. → https://investor.siriusxm.com/sec-filings/all-sec-filings/content/0000908937-26-000022/0000908937-26-000022.pdf
2. Sirius XM Holdings Inc., "SiriusXM Reports First Quarter 2026 Operating and Financial Results", earnings release dated 30.04.2026. Advertising revenue by segment Q1, podcast and programmatic growth, 2026 FCF outlook and 2027 target. → https://investor.siriusxm.com/news-events/press-releases/detail/2264/siriusxm-reports-first-quarter-2026-operating-and-financial
3. Sirius XM Holdings Inc., Form 10-Q for the quarter ended 31 March 2026, SEC filing of 20.04.2026. Segment gross profit Q1 2026, SAC per installation Q1. → https://investor.siriusxm.com/sec-filings/all-sec-filings/content/0000908937-26-000011/0000908937-26-000011.pdf
4. Sirius XM Holdings Inc., "SiriusXM Media Becomes Exclusive Audio Advertising Representative for YouTube in the United States", press release, April 2026. Exclusive representation, reach of more than 212m monthly US audio users, booking via AdsWizz. → https://investor.siriusxm.com/news-events/press-releases/detail/2261/siriusxm-media-becomes-exclusive-audio-advertising
5. Sirius XM Holdings Inc. / Amazon Ads, announcement of the Amazon DSP partnership, September 2025. First-party data and clean-room integration of SiriusXM Media inventory. Press release of 16.09.2025. → https://investor.siriusxm.com/news-events/press-releases/detail/2206/amazon-ads-and-siriusxm-media-announce-new-programmatic
6. Sirius XM Holdings Inc., fourth quarter and full year 2025 results, earnings release, February 2026. Podcast advertising growth in 2025 (+41%), reach of roughly 170m listeners across digital audio. → https://investor.siriusxm.com/news-events/press-releases/detail/2233/siriusxm-reports-fourth-quarter-and-full-year-2025
7. iHeartMedia, Inc., fourth quarter and full year 2025 results, earnings release of 02.03.2026. Podcast revenue 2025 (+25.6% to $563.7m), station count, reach, debt. → https://investors.iheartmedia.com/news/news-details/2026/iHeartmedia-Inc--Reports-Results-for-2025-Fourth-Quarter-and-Full-Year/
8. The New York Times, report on the collapse of the talks between SiriusXM and iHeartMedia, 31.05.2026. The original is paywalled; evidenced through Radio Ink’s report of the same day. → https://radioink.com/2026/05/31/report-iheart-and-siriusxm-merger-talks-hit-a-wall/
9. Market data (NASDAQ closing price), as of 06.10.2026: price $26.36, 337.07m shares outstanding (rounded to 337.1m in the model), market capitalisation $8,885m, dividend yield 4.1%; from which market capitalisation, free cash flow yield and distance to fair value. Previous price bases: $25.88 (30.09.2026), $29.15 (12.09.2026).
10. Sirius XM Holdings Inc., first quarter 2026 earnings presentation, 30.04.2026, page 3. Expansion of reach to roughly 255m monthly listeners through the YouTube agreement. → https://d1io3yog0oux5.cloudfront.net/_d961087def3bce806fe30366de143a7c/siriusxm/db/2244/21575/presentation/SiriusXM+1Q26+Earnings+Presentation+-+Final.pdf
11. Sirius XM Holdings Inc., transcript of the first quarter 2026 earnings call, 30.04.2026. Companion subscriptions contributing 124,000 self-pay net additions, comment on the maturity of take rates. → https://www.investing.com/news/transcripts/earnings-call-transcript-sirius-xm-beats-q1-2026-forecasts-stock-dips-93CH-4649717
12. Federal Communications Commission, Order DA 24-1176, 26.11.2024. Conditional approval of the assignment of the WCS C and D blocks from AT&T to Sirius XM, purpose restricted to satellite-based emergency communications, milestones and automatic licence termination on failure. → https://docs.fcc.gov/public/attachments/DA-24-1176A1.pdf
13. APCO International, "Using Satellite Spectrum for Public Safety", web seminar of 25.03.2026. Description of the service and recruitment of participants by Sirius XM. → https://www.apcointl.org/courses/using-satellite-spectrum-for-public-safety-webinar-80070/
14. Sirius XM Holdings Inc., presentation at the BofA Securities Media, Communications & Entertainment Conference, 09.09.2026. Characterisation of the free cash flow improvement as structural and not timing-driven by CFO Zac Coughlin. → https://www.investing.com/news/transcripts/siriusxm-at-bank-of-america-media-conference-growth-broadens-93CH-4893892
15. Federal Communications Commission, Notice of Proposed Rulemaking FCC 26-13, SB Docket 26-54 ("Spectrum Abundance for Weird Space Stuff"), Federal Register of 09.04.2026. Proposed secondary allocation of 2320–2345 MHz to the space operation service (Earth-to-space), coordination and approval requirement in favour of SiriusXM, financial compensation, comment (11.05.2026) and reply (08.06.2026) deadlines. → https://www.federalregister.gov/documents/2026/04/09/2026-06865/spectrum-abundance-for-weird-space-stuff
16. Federal Communications Commission, open meeting of 30.09.2026, agenda per the Sunshine Act notice in the Federal Register of 29.09.2026. Docket 26-54 bundled with four other proceedings; adopted were an order on 12.7 and 42 GHz, a further notice on the Ku, Ka and D bands, and a second further notice adding more bands. No decision on the S band. → https://www.federalregister.gov/documents/2026/09/29/2026-19920/sunshine-act-open-commission-meeting-wednesday-september-30-2026
17. Sirius XM Holdings Inc., "Sirius XM Holdings Reports Strong Second Quarter 2026 Results", earnings release of 30.07.2026. Full-year 2026 guidance raised by $25m each for revenue, adjusted EBITDA and free cash flow; FCF guidance $1.375bn. → https://d1io3yog0oux5.cloudfront.net/_c9fc831dbc5d04f0968b93d06eae1d10/siriusxm/db/2244/21588/earnings_release/SIRI+Q2+2026+Earnings+Release.pdf
18. Sirius XM Radio LLC, Comments of 11.05.2026 and Reply Comments of 08.06.2026 in SB Docket 26-54, FCC Electronic Comment Filing System. The company's position on the leasing framework, rejection of any duty to lease and of the space-to-Earth direction, request to defer the WCS C and D blocks. → https://www.fcc.gov/ecfs/search/docket-detail/26-54