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GeoLinks Ex Parte – 06.01.2020

June 1, 2020



Marlene H. Dortch, Secretary

Federal Communications Commission

445 12th Street, SW

Room TW-A325

Washington, DC 20554



Competitive Bidding Procedures and Certain Program Requirements for the Rural Digital Opportunity Fund Auction, AU Docket No. 20-34

Rural Digital Opportunity Fund, WC Docket No. 19-126

Connect America Fund, WC Docket No. 10-90


Dear Ms. Dortch:

On May 29, 2020, GeoLinks CEO Skyler Ditchfield, President and COO Ryan Adams and General Counsel and V.P. of Government Affairs and Education Melissa Slawson attended a telephone call Chairman Ajit Pai and Advisor Preston Wise.

During this call, GeoLinks expressed the importance of the Rural Digital Opportunity Fund (“RDOF”) auction and discussed the Company’s concerns regarding certain of the proposed rules set forth in the Draft Procedures Public Notice that, in the Company’s opinion, could lead to failures to perform or defaults if service providers are not adequately vetted.[1]  Specifically, GeoLinks expressed concern regarding allowing service providers with no operational history of providing Gigabit speeds to bid at the Gigabit Tier in the auction.  GeoLinks explained that while some companies, like GeoLinks, have been successful at offering and delivering Gigabit+ speeds to customers throughout their service territory, this is the result of stringent equipment vetting and detailed network design, particularly in rural and remote areas.

As GeoLinks explained, without real-world operating experience providing Gigabit services to customers, GeoLinks is concerned that some companies may rely blindly on manufacturers’ specifications and data sheets when designing a proposed RDOF network plan (and when developing an RDOF bidding strategy).  The possible result is companies defaulting on their RDOF obligations when RDOF funds end up not being sufficient to properly engineer and deploy the network necessary to offer Gigabit services.

GeoLinks explained that specific performance of individual equipment types is dependent on many factors including available spectrum, weather, topography, topology, the number of customers being served, oxygen absorption and, most importantly, engineering.  GeoLinks emphasized that it is prepared for scenarios that can affect throughput and has extensive, successful experience engineering a Gigabit+ network across numerous types of terrain (spanning some of California’s most challenging topographies and topologies) utilizing various equipment types and accounting for potential equipment shortfalls.  GeoLinks has also worked to develop relationships with equipment manufacturers to develop proprietary equipment offerings that offer higher throughputs and reduce the effects of various environmental conditions.  However, GeoLinks fears that this is likely not the case for inexperienced providers hoping to provide Gigabit+ speeds to unserved rural areas.

To avoid network operators without experience offering Gigabit services from potentially “biting off more than they can chew” during the Auction, GeoLinks proposed that the Commission return to its original proposal to prohibit certain service providers who have not previously offered Gigabit services to customers (and have not reported doing so via their Form 477s) from being able to bid the Gigabit Tier during RDOF.  In the alternative, GeoLinks strongly urged the Commission to ensure that the short-form vetting process is rigorous and relies on more than equipment manufacturers’ claims.

During the call, GeoLinks shared the question it received during its call with from the Rural Broadband Auction Task Force (“RBATF”) staff on May 27, 2020 regarding certain manufacturers’ claims that equipment may support Gigabit speeds under certain conditions.[2]  Specifically, RBATF staff asked GeoLinks to comment on the information set forth in Footnote 238 of the Public Notice.  GeoLinks explained to Chairman Pai and Mr. Wise that while the claims made regarding throughput are technically attainable, in GeoLinks’ experience, real world throughput, even in a very clean environment, never comes close to as-advertised over-the-air (“OTA”) link rates.  In fact, GeoLinks finds that, in general, the equipment it procures obtains about 1/3 to 1/2 the capacity of the manufacturer’s OTA rate in real world deployments with a 10% reduction for each additional client added.  It is simply not realistic to expect full modulation on every link, especially with point-to-multipoint (“P2MP”) deployments or as additional customer connections are added to the same equipment.

GeoLinks shared the following information with Chairman Pai and Mr. Wise regarding the claims cited in Footnote 238 of the Public Notice:



According to the specifications sheet GeoLinks was able to locate, the equipment referenced in Footnote 238 does not have a sector capacity of 1.6 Gbps but instead 1.2 Gbps.[3]  While GeoLinks is unclear whether this is a typo or outdated information, this is sector capacity and not applicable to end user speed.  To fully understand the capabilities of the Cambium cnMedusa (“450m”), one must look at the manufacturers’ specifications more closely.  Cambium states that the 450m has a maximum data rate of 172 Mbps, and can utilize Multi User Multiple in Multiple Out (“MU-MIMO”) to stream data to up to seven client radios simultaneously for a total sector capacity of 1200 Mbps (172mbps x 7 clients).  This means the maximum capacity per client is limited to 172mbps aggregate in perfect conditions.  However, not all connected clients will meet “perfect conditions.”



According to Siklu’s specifications sheet for its MultiHaul P2MP product,  maximum data rates, as advertised, are 2300 Mbps OTA and 1000 Mbps aggregate with a footnote stating that “actual throughput varies with traffic patterns.”[4]  An aggregate throughput of 1000 Mbps is not sufficient to meet the Commission’s 1000 Mbps/ 500 Mbps service tier.



In its Ex Parte filing from May 15, 2020, the Wireless Internet Service Providers Association (“WISPA”) states that JAB Wireless, Inc. is using equipment manufactured by IgniteNet that operates in the 57-71GHZ bands.[5]  GeoLinks has extensive experience working with IgniteNet and its executive team.  Specifically, the Company worked with IgniteNet for over 3 years trying to get spectrum utilization in the upper 60 GHz and lower 70 GHz bands.  In GeoLinks’ experience, and based on their own documentation, their equipment only supports use to 65 GHz, thus vastly limiting the broadcast distance.[6]  While IgniteNet claims 2.4 Gbps of sector capacity,[7] its use of an 802.11ac based chipset makes it subject to differential in its OTA and TCP/IP throughput rates. In GeoLinks own internal testing, IgniteNet devices obtained a capacity of about 1/3 the layer 1 OTA link rate.  The best GeoLinks was able to achieve was approximately 650 Mbps aggregate.



In GeoLinks’ experience, Ericsson’s data rates of 4.3 Gbps in a single one-way session is accurate with 800mhz of available spectrum.  However, to the best of GeoLinks’ knowledge, Ericsson does not make this equipment commercially available today.  Moreover, Footnote 238 notes that the speeds cited were achieved in a trial – not a real-world deployment scenario.



As noted in Footnote 238, Starry’s equipment uses an 802.11ac chipset.  As discussed in detail below, 802.11ac chipsets only achieve actual end user speeds of about 1/3 of their OTA link rate capacity.  Therefore, GeoLinks estimates actual capacity at a full 160 MHz channel is closer 566 Mbps. Thus, the claim of 6.9 Gpbs of sector capacity, while technically accurate, is not relevant to end user speed.


As exemplified by the above, there is a distinct difference between what certain equipment manufacturers claim to be capable of (and may be in laboratory-type settings) vs. what they are more likely capably of in real-world settings.  GeoLinks asserts that the above information shows clearly why the Commission cannot rely on information provided by service providers wishing to bid the Gigabit tier what simply parrot the information provided from the manufacturer(s) whose equipment they plan to utilize, and which is also not applicable to end user speed (as discussed below).  Instead, as emphasized during the call, if the Commission is to allow service providers with no experience providing Gigabit services to bid in the Gigabit tier, it must hold them to strict scrutiny regarding their network engineering plans.

During the call, Mr. Wise asked GeoLinks what information the Company suggested the Commission look to when undertaking its short-form review process to ensure it is robust.  Similar to GeoLinks’ response to the same question posed by RBATF staff, GeoLinks emphasized the need for strong vetting procedures.  In furtherance of the information offered during the call with Chairman Pai and Mr. Wise, GeoLinks asserts that the Commission consider the claimed capacities of client premises equipment (“CPEs”) offered by various equipment manufacturers in addition to actual aggregate TCP/IP capacity.  Notably, CPE capacity is not discussed in Footnote 238, however GeoLinks believes that information regarding the speeds that can be supported by various manufacturers’ CPEs is a vital component to determining whether Gigabit+ services can be supported by a proposed network engineering plan.

GeoLinks asserts that client radio capacity needs to be a minimum of 1000 Mbps/ 500 Mbps true TCP/IP throughput in order to effectively ensure delivery of Gigabit service speeds.  This is how all standardized and Commission testing is done.  However, as discussed above, many manufacturers, such as Starry, utilize 802.11ac Chipsets.  With adequate spectrum (160 MHz), 802.11ac chipsets are capable of OTA link rates of up to 1700 Mbps per client radio (layer 1 OTA rate) and can utilize MU-MIMO to stream data to up to four client radios simultaneously for a total sector capacity of 6800 Mbps. (1700 Mbps to each of four clients).  However, this doesn’t mean a sector has 6800 Mbps of TCP/IP throughput (actual customer throughput) nor does the 1700 Mbps OTA rate translate to a TCP/IP capacity of 1700 Mbps.  These are layer 1 OTA link rates and are typically used for marketing and are not applicable for TCP/IP throughput.  In GeoLinks’ experience, in real-world observed applications, 802.11ac-based devices typically have a layer 2 (customer) capacity of about 1/3 of their layer 1 OTA link rate.  In other words, the links rates claimed by 802.11ac-based devices do not translate to the speeds an end-user actually receives.[8]  To further corroborate the above, according to support information available on Netgear’s website, “user activities like file transfer and web content browsing happen at the application layer. The rate obtained at the application layer will be much lower than the physical layer rate. In fact, [an OTA] link rate of ‘300 Mbps’ usually corresponds to 50 to 90 Mbps speed on the TCP/UDP layer.”[9] Notably, none of the discussion cited in Footnote 238 mentioned end user capacity.

It is GeoLinks’ strong suggestion, based on the forgoing, that the Commission implement the following to ensure stringent short-form review during the RDOF process.  First, the Commission should only allow for equipment that has a capacity of at least 1500 Mbps aggregate on the client device, so that full 1000 Mbps/500 Mbps data rates can be achieved in all real-world applications.  A higher threshold of 1750 Mbps aggregate to ensure adequate headroom for varying link conditions would be ideal.  Second, the Commission should require all applications to make a showing that throughput capacity of their intended end user equipment meets or exceed the above standards in TCP/IP testing.

Pursuant to Section 1.1206(b) of the Commission’s rules, I am filing this letter electronically in the above referenced dockets.  Please contact me directly with any questions.




/s/ Skyler Ditchfield


Skyler Ditchfield

Chief Executive Officer




Chairman Ajit Pai

Preston Wise



[1] Public Notice, Rural Digital Opportunity Fund Phase I Auction Scheduled for October 29, 2020; Notice and Filing Requirements and Other Procedures for Auction 904, AU Docket No. 20-34 and WC Docket Nos. 19-126 and 10-90, FCC CIRC2006-01 (May 19, 2020) (“Draft Procedures Public Notice”).

[2] Public Notice at para. 103.

[3] Available at:

[4] Available at:

[5] Comments of the Wireless Internet Service Providers Association, AU Docket No. 20-34 (filed. March 27, 2020), at 13.

[6]Available at:, citing channel 4.5 support its highest frequency (65 GHz)

[7] See Id.

[8] For instance, assuming good wireless conditions and the 1700 Mbps link rate is achieved, actual TCP/IP capacity will be somewhere around 566 Mbps, not the 1500 Mbps aggregate required for 1000 Mbps/ 500 Mbps levels of service needed for RDOF “Gigabit Tier” service.



Get to Know GeoLinks Business Sales Consultant, Jacques Lee

1. Let’s start with something simple, what’s your role at GeoLinks?

I am a business sales consultant. I generate and close new business. I also educate clients on the solutions we provide.

2. What’s your favorite part about working for GeoLinks?

My favorite part is the camaraderie and the inviting, welcoming vibe we have here. The environment makes me want to come to work every day. Everybody has fun, it feels like home. Feels like I’ve known these people forever.

3. What was the most interesting job you had before working at GeoLinks? 

I worked for MTV in their production department as a production assistant and eventually a production coordinator. I’d scout locations, contact talent, set up for production. It was a pretty fun, exciting, sometimes wild job.

4. What makes GeoLinks’ ClearFiber™ network different from other fixed wireless networks?

Simply put, we’re the best. It’s our customer service. We’re always available to help you. It’s also a dynamic network. We’re constantly evolving and engineering innovative solutions for businesses.

5. Outside of work, what is your favorite past time or hobby?

Hanging out with my kids. I help my youngest son with his sports. I’m a pretty family oriented person so I keep it close to home.

6. What’s something most of your coworkers don’t know about you?

I would say most of them don’t know that I’m an avid snowboarder.

7. What does an average day as a GeoLinks Sales Consultant look like?

We’re always prospecting for new business. I’m following up with potential clients, learning about their business so that I can figure out how I can customize the best solutions for them. At the same time, I’m calling on new opportunities and building new relationships, building our client network.

8. You are allowed to do anything you want, anywhere in the world, for one whole day…what do you do, and where do you go?

I would go to the Giza pyramids with my sons. I just want to feel the energy of that region.

9. Do you have a favorite quote or mantra you live by? Please share!

Mine is a Bible Verse. Matthew 6: 14-15

For if you forgive men their trespasses, your heavenly Father will also forgive you. But if you don’t forgive men their trespasses, neither will your Father forgive your trespasses.

That changed my life.

10. What’s next…what are you most excited for when you think of your future with GeoLinks?

Scalability. The company is growing in the right direction. There are a ton of great opportunities that come with that. As we grow, I want to continue to grow along with the company and continue to be a valuable asset for our customers and for GeoLinks.

GeoLinks Welcomes Technology Veteran Randy Chapman as New Sales Director for Direct, Channel and Wholesale Sales

Networking Expert to Lead Consultative Sales of GeoLinks’ Dedicated Internet, SD-WAN, Hosted Voice, IoT and Cloud Connectivity Services

June 15, 2020 1:30 PM Eastern Daylight Time

CAMARILLO, Calif.–As GeoLinks continues its strong growth trend, the company is pleased to welcome telecommunications industry veteran Randy Chapman as its Director of Sales. With nearly 15 years of experience in the technology sales sector, Chapman will oversee day-to-day and long-term sales strategy for all of the company’s business sales channels, including direct, channel and wholesale.

“In the midst of our rapid growth, this was really the prefect time to bring Randy onto our team,” said GeoLinks Chief Strategy Officer Phillip Deneef. “The experience and knowledge he brings to the table will allow us to execute on our short-term goals to accelerate sales to businesses, while continuing to plan for what we expect to be an extended period of expansion.”

Chapman brings an extensive background in channel sales. His successful tenure as an agent saw him engineer voice, network security, cloud enablement and infrastructure solutions for a broad client base. He also has nearly ten years of experience as a Director of Sales for technology companies in Southern California.

“I’m ecstatic to be joining such a mission-driven team that is on an impressive trajectory of development and progress,” said Chapman. “My experience has taught me to continue pushing during periods of growth while preparing me to consistently evaluate strategy to optimize results.”

Chapman will manage the organization’s sales team, as well as the continued development of partner relationships in the wholesale and master agent channels. To reach him directly, please email [email protected].

About GeoLinks

Headquartered in Southern California, GeoLinks is a leading telecommunications company and competitive local exchange carrier (CLEC) public utility, nationally recognized for its innovative Internet and Digital Voice solutions. Ranked three-years running on Inc. Magazine’s Inc. 5000 Fastest Growing Companies in America, GeoLinks delivers Enterprise-Grade InternetDigital VoiceSD-WAN, Cloud On-ramping, Layer 2 Transport, and both Public and Private Turnkey Network Construction expertly tailored for businesses and Anchor Institutions nationwide.

GeoLinks’ accelerated success is largely due to its flagship product, ClearFiber™, which offers dedicated business-class Internet with unlimited bandwidth, true network redundancy, and guaranteed speeds reaching up to 10 Gbps. Named “Most Disruptive Technology” in the Central Coast Innovation Awards, GeoLinks’ ClearFiber™ network is backed by a carrier-grade Service Level Agreement boasting 99.999% uptime and 24/7 in-house customer support. With an average installation period of 4 to 7 days, GeoLinks is proud to offer the most resilient and scalable fixed wireless network on the market.

8 Facts to Set the Record Straight About Fixed Wireless Internet

Fixed wireless is one of the most reliable, cost-effective connectivity solutions in the marketplace. Despite a proven track record, many misconceptions persist about fixed wireless service. Some of this confusion stems from the early iterations of fixed wireless, some is the product of Internet rumors and some is based on simple misunderstanding of the different types of wireless connections. In reality, today’s fixed wireless solutions can be game changers for business in terms of cost, reliability, redundancy, speed of deployment and scalability.

To set the record straight, we’ve prepared this quick guide to 8 key facts about fixed wireless Internet services.


Fact 1: Fixed Wireless is Not the Same as Satellite

Radio-based fixed wireless broadband connectivity is not the same as satellite-based Internet. There is far less latency with radio-based fixed wireless services and, perhaps more importantly, there’s no throttling that’s common with satellite services. Both are  vitally important at a time when bandwidth-sensitive video content already accounts for more than half of Internet traffic and will account for 80 percent in two years.


Fact 2: Fixed Wireless is Just as Reliable as Fiber

A persistent myth dating to the early days of wireless services is that fixed wireless is less reliable than fiber connections. Just as wired connections have moved passed the dialup days of listening to electronic “beeps” and “bongs,” followed by “You’ve got mail!”, wireless technology has undergone quantum leaps forward. A fixed wireless connection running on licensed spectrum is not only as solid as a fiber connection, it’s more reliable, because a jackhammer, backhoe, flood or other disaster (natural or manmade) won’t take it down.


Fact 3: Fixed Wireless is Not Only a Rural Solution

While it’s true that fixed wireless makes an excellent rural broadband solution, fixed wireless is a fast and reliable solution in city environments as well. And, it’s more affordable to boot.


Fact 4: Fixed Wireless Can Be Installed Rapidly
Due to the glacial installation speeds of bringing wireline broadband connections to new buildings and locations, there is sometimes a misperception that fixed wireless deployment is equally slow to install. In reality, fixed wireless connections can be turned up in days, not months. In fact, many businesses order fixed wireless connectivity as a stopgap while they wait for fiber installations and then find that they don’t need the fiber installation at all.


Fact 5: Fixed Wireless Radio Technology is Safe

Fixed wireless connectivity sometimes gets lumped in with Internet conspiracy theories about the supposed (but also mythical) dangers of wireless radiation from mobile phones, Wi-Fi, Bluetooth and other wireless connections. In reality, as you are reading this blog, your body is absorbing up to five times the signal from FM radio and TV stations than you would if you were sitting right next to a wireless base station.


Fact 6: Fixed Wireless is Much More Than a Backup Solution

With the world moving to cloud applications, network redundancy and business continuity solutions have become vital to businesses of all sizes. It’s true that, as hurricanes, wildfires and other disruptors have taken down wireline connections, businesses have increasingly turned to fixed wireless solutions for redundancy. But many, once they experience the speed and performance of fixed wireless solutions, turn to fixed wireless for their primary connections as well.


Fact 7: Fixed Wireless Is Secure

May people think fixed wireless solutions aren’t secure. This myth could not be further from the truth. Using our own company as a reference point, GeoLinks delivers the same military-grade encryption to business customers that it delivers under government contracts. Your connections are safe, reliable and secure.


Fact 8: Fixed Wireless Works in Any Weather

With proper engineering, fixed wireless networks can withstand the elements. GeoLinks’ in-house engineering team begins a deployment by taking into account the terrain, historic weather patterns, rain fade and thermal ducting. Based on that data, the distance between radios and the required bandwidth, they choose the best frequency (or frequencies) and carrier-grade equipment for a weather-proof build. In addition, GeoLink’s adds multiple failover paths as well as a connection to a fiber optic backbone to ensure true network redundancy.

There you have it – just the facts about fixed wireless.


Now that you know the facts – Get fixed wireless Internet today!

Contact a GeoLinks ClearFiberTM solutions specialist

LTE + Destination Based Failover: How to keep your phones and POS system connected

The powerful cost benefits of Software-defined Wide Area Networking (SD-WAN) dominate conversations, so it’s easy to forget that impetus behind SD-WAN development was business continuity — Internet failover, to be specific.

Internet failover is just what it sounds like: When the primary Internet connection fails, experiences packet loss or latency spikes, SD-WAN technology switches traffic over to a secondary connection. At a time when your business is increasingly dependent upon Internet connections to access vital computing and communications infrastructure and applications, you can see why business continuity is critical. It’s not only essential to maintaining productivity, but also for the consistent delivery of service to your customers.

GeoLinks offers Fourth Generation Long Term Evolution (4G LTE) wireless service as the recommended choice for Internet failover for most businesses using fiber or our own dedicated fixed wireless network.


Why Choose 4G LTE Failover?

4G LTE wireless is particularly advantageous as an Internet failover connection for several reasons, including:

  • Diversity: 4G LTE wireless does not rely on last-mile wired connectivity and offers a completely diverse connection from a primary wireline connection.
  • Speed: 4G LTE is the wireless equivalent to a physical line with speeds averaging 10-20Mbps, with download speeds in the U.S. approaching 30Mbps and in some areas nearing 45Mbps, according to January 2020 research from Open Signal.
  • Responsiveness: 4G LTE wireless has both low latency and low idle-to-active times.
  • Cost Efficiency: From a failover perspective, the cost benefits of 4G LTE are considerable when compared to additional wireline connections.
  • Omnipresence: 94 percent of North American residents, and 98 percent of the U.S. population, in particular, have access to 4G LTE. The probability of 4G LTE reaching all of your business locations is very high, even in rural settings.
  • Simplicity: Deploying 4G LTE as a backup is plug and play.


How Can 4G LTE Failover Help You?

Having a disaster recovery plan is essential to today’s businesses. Human-caused outages (construction accidents, cyberattacks, etc.) and natural disasters like hurricanes and wildfires are on the rise. LTE-driven business continuity is a proven, affordable option for businesses of all sizes.

Here are the most critical use cases for SD-WAN with 4G LTE wireless:

Point of Sale (PoS): If your business is a retailer, restaurant, hospitality or entertainment business, processing electronic payments is the lifeblood of your business. If there’s a fiber cut, loss of power or any other disruption to your connection, 4G LTE can kick in so you can still accept credit cards or digital payments.

VoIP Calls: If your business is relying on data connections to carry voice calls (VoIP), then you need to ensure that those calls continue to stay connected with high clarity. With SD-WAN and 4G LTE Wireless as a failover option, you can continue to make calls if there’s a disruption. And, SD-WAN can enable primary and secondary circuits to be active at the same time, enabling calls to proceed uninterrupted (i.e., session persistence) even if one of the connections goes down.  (Plus, SD-WAN offers quality of service controls to make sure you voice calls are high fidelity.)

At GeoLinks, we leverage a configuration that allows for destination-based failover to address these two mission-critical scenarios. As a Verizon Wireless Preferred Partner, GeoLinks offers a high-quality LTE connection via a commercial-grade machine-to-machine routers that plugs into our SD-WAN device at the customer location. Because VoIP and PoS systems are low bandwidth applications, GeoLinks is able to offer this solution for $49 per month without incurring data overages.

Ready to Disaster-Proof Your VoIP or PoS Connection?

Contact Us Today!


Not All Connections Are Created Equal

With the sudden surge in remote work and distance learning, internet connectivity has been put to the test. As we predicted, shared circuits in residential areas have been stretched beyond their limits with web surfing and video streaming competing for bandwidth with videoconferencing and large data uploads.

These slowdowns are not unexpected. Most residential internet circuits were not designed to accommodate the increased levels of activity they’re experiencing, which rivals that of enterprise-grade broadband circuits typically used by businesses.

Additionally, the vast majority of residential internet customers share a connection with their neighbors so bandwidth must be divvied up amongst all the households that are connected to it. While these connections fit the needs of residential customers under most normal circumstances, conditions are far removed from normal at the moment.

Subscribers to GeoLinks’ ClearFiber network have not experienced any slowdown, whatsoever. Our Fixed Wireless service provides every customer with a dedicated connection, eliminating the need to share and guaranteeing high speeds that are unaffected by the activity of any neighboring circuits.

Clearly, not all internet connections are created equal. GeoLinks’ Fixed Wireless guarantees speeds and provides residential and business customers with additional advantages, such as fast installation (5-7 days) and 99.999 percent uptime.

To learn more about how you can benefit from Fixed Wireless internet, contact us at (888) 225-1571 or  visit our Youtube channel to watch a three-minute video primer.

Keeping You Connected: Beacons of Growth and Recovery

As we continue to navigate our way through the Coronavirus pandemic, we would like to take a moment to connect with you, our customers and partners. While the situation continues to evolve, as does our way of life along with it, one thing remains unchanged — our commitment to keeping you connected.

In March, GeoLinks joined the Federal Communications Commission’s pledge to Keep Americans Connected and we are steadfast in our commitment to do so. This formal pledge is our vow to ensure that our customers remain connected to vital information infrastructure during these uncertain times.

Over the last several weeks, we have worked closely with our partners and clients to honor this commitment. When possible, we have granted temporary speed bumps to residential clients who are working remotely due to the “safer at home” guidelines. We have differed billing for clients experiencing difficulties paying their bill due to the loss of business and steady income. We have been diligent in ensuring that no clients’ service is suspended due to an inability to pay their bill because of economic difficulties caused by the pandemic.

“As a telecommunications company, we have been in the fortunate position of continuing our growth trend during a time when many industries have been hit extremely hard by the economic toll of the pandemic,” said GeoLinks CEO Skyler Ditchfield. “Our customers are the heart of our company and are driving our success. In kind, we are committed to fueling their continued success and their return to economic vitality in a very real way by keeping them connected to the networks that keep their businesses running.”

While many businesses have been forced to make difficult decisions such as closing for indeterminate timeframes, we have continued to see a high demand for connectivity over the last several weeks. “Our country has weathered many challenges over its history, and what has inevitably led us through each one has been the resilience and ingenuity of our entrepreneurial and business communities,” said Ditchfield. “We have seen signs of recovery over these last few weeks as our network has continued to grow, connecting new customers on a daily basis.”

As we move forward, please remember that we’re here to help. Whether you need help with a disruption to your business caused by the pandemic or you’re looking to connect a new business, we’re your partners in connectivity and nothing is going to change that.

Network downtime can be a thing of the past

IT downtime can cost businesses on average $9,000 per minute, or $540,000 per hour, according to a 2016 study by Ponemon Institute. Think it won’t happen to you? Think again.

With thousands, if not millions, of dollars on the line, it’s imperative to closely examine your service level agreement (SLA) when choosing your ISP. Ninety-nine percent uptime sounds great, but it means you’ve agreed to up to 87.66 hours of annual unplanned downtime. At GeoLinks , we guarantee 99.999% uptime, which promises no more than 5.25 minutes of unplanned downtime throughout the year.

Nearly half (46%) of companies experienced more than four hours of downtime over 12 months, with estimated costs ranging from $12,000 to more than $1 million per hour, according to a 2017 study of 400 IT decision makers. While this number may seem high, keep in mind that Delta airlines was forced to cancel 280 flights due to an outage in 2017, with losses exceeding $150 million.

So What’s the Solution

Guaranteed five 9s uptime is a great place to start. But you can take business continuity a step further by incorporating SD-WAN into your planning.

SD-WAN (or Software-defined Wide Area Networking) can ensure connectivity in the event your primary circuit fails by using at least two circuits for every connection.  The secondary connection can be on standby and kick in when the primary fails or in more critical scenarios, SD-WAN also gives you the option use connections simultaneously so that if one drops, your application doesn’t.

SD-WAN can work with your private networks or widely available low-cost broadband. And, with the ability to combine up to four internet connections, SD-WAN can boost your bandwidth cost-effectively.

So while you may have heard that 100% uptime is not realistic, with strong SLAs and SD-WAN, network downtime truly can be a thing of the past. And with the high cost associated with network downtime, SD-WAN’s cost-effectiveness makes it a no-brainer as a solution for your business.

GeoLinks Comments on Competitive Bidding Procedures


California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these Comments on the Public Notice, seeking input on proposed pre-auction and bidding processes proposed for Phase I of the upcoming Rural Digital Opportunity (“RDOF”) reverse auction.[1]


GeoLinks is one of the fastest growing Internet and phone providers in America and the #1 fastest growing fixed wireless service provider in California.[2]  While the Company had previously focused on business and enterprise customers, in 2016, GeoLinks began expanding its customer base to include unserved and underserved areas throughout California and beyond.  GeoLinks was the largest construction grant winner for California K-12 schools and libraries in 2016 and 2017, providing highspeed broadband to rural school districts and surrounding communities throughout the state that previously had not had access to any high-speed broadband service.  In 2019, GeoLinks was awarded Connect America Fund Phase II (“CAF”) Auction funding to connect more than 11,000 unserved locations making it the largest CAF winner in California and the fifth largest overall.

GeoLinks largely supports the pre-auction and bidding procedures and processes for the Rural Digital Opportunity Fund (“RDOF”) proposed in the Public Notice and believes they strike the right balance to ensure a fair and successful auction.  However, GeoLinks believes that some of the proposals set forth in the Public Notice risk allowing certain bidders to participate that should either be limited in what tiers they can bid or excluded from the auction all together.  GeoLinks provides these comments to provide input into the Commission’s proposed RDOF pre-auction and bidding processes.


The Commission Should Limit Satellite Providers and Those That Have Never Filed a Form 477 From Bidding Gigabit and Above Baseline Performance Tiers

In the Public Notice, the FCC proposes to limit “geostationary satellite providers from bidding in the Gigabit and Above Baseline performance tiers.”[3]  In doing so, the Commission explains that there is “no evidence that geostationary satellite providers already offer service that meets all the requirements for these performance tiers.”[4]  As the Commission notes, satellite technologies generally cannot achieve speeds of at least 100/20 (noting that the only satellite provider that has reported via its Form 477 that it can offer 100 Mbps of downstream service only bid at the 10/1 and 25/3 speed tiers in the CAF auction).[5]  For this reason, it makes sense to limit these service providers from bidding in the Gigabit and Above Baseline performance tiers because there is no reported basis for believing the technology could achieve Gigabit and Above Baseline speeds.   Therefore, GeoLinks supports this proposed limitation.   In addition, GeoLinks urges the Commission to extend this limitation to low-earth orbit satellite service, as well.  Similar to other satellite providers, to the best of GeoLinks knowledge, there are no Form 477 filings to show that any low-earth orbit satellite operators have successfully offered Gigabit or Above Baseline speeds.  For the same reasons the Commission seeks to limit geostationary satellite providers from bidding the higher speed tiers, GeoLinks asserts that low-earth orbit satellite service should be limited, as well.

Along this vein, GeoLinks urges the Commission to implement one additional limitation in the RDOF auction.  GeoLinks asserts that the Commission should exclude service providers that have never filed a Form 477 from bidding the Gigabit and Above Baseline speed tiers.[6]  Only service providers with a track record for providing broadband service (and for complying with regulatory reporting requirements) understand the rigors associated with designing, deploying, and supporting high-speed broadband networks.  Limiting participation at these tier levels to only providers who have previously filed Form 477s will protect RDOF funding and save Commission resources by weeding out companies that may not be able to meet the rigors of the long form application process before they take part in the auction.

DOF Rules Must Prohibit Service Providers from “Double Dipping”

In addition to the above, the Commission should also be asking whether certain providers should be prohibited for another very important reason – if they have already received some incentive from the Commission to deploy high-speed broadband facilities to serve the areas eligible for RDOF funding (i.e. double dipping).  Specifically, GeoLinks believes that service providers that have received spectrum rights, deployment rights, merger approval, etc. from the Commission contingent upon buildout obligations that overlap with RDOF funding areas should not be eligible for grant funding for those areas.

GeoLinks uses SpaceX as its prime example.  SpaceX has been an active participant in the RDOF proceeding, undoubtedly with the goal of being able to participate in the auction.  However, SpaceX has already received hefty spectrum rights and operating authority from the Commission for extensive satellite deployments that will purportedly result in global broadband deployment.  Because these would presumably be the same satellites that SpaceX would use for any RDOF-related services, allowing SpaceX to participate in RDOF for the same deployment would essentially allow it to “double dip” from the Commission, resulting in wasteful use of limited RDOF funding.

In 2018, the Commission granted SpaceX authorization to “construct, deploy, and operate” its proposed satellite system, “comprising 4,425 satellites for the provision of fixed-satellite service (FSS) around the world” and the rights to do so over certain spectrum within the Ku- and Ka-band frequencies.[7]  In exchange for these rights and authorizations, the Commission mandated that SpaceX meet certain conditions related to, among other things, deployment milestone and geographic coverage requirements.[8]   Specifically, the Commission’s rules require SpaceX to launch and operate “50 percent of the total number of satellites in the constellation” no later than 6 years after grant of the authorization” and “to provide service coverage to (i) all locations as far north as 70 degrees latitude and as far south at 55 degrees latitude for at least 75% of ever 24-hour period and (ii) on a continuous basis through the fifty states, Puerto Rico, and the U.S. Virgin Islands.”[9]

SpaceX has made clear that by utilizing the authorizations and rights already granted by the Commission, it will launch thousands of satellites and “once fully deployed,” will “provide full time coverage to virtually the entire planet.”[10]  Moreover, SpaceX has repeatedly explained to the Commission that it is already actively deploying its satellites.[11]  SpaceX’s commitments were all made without the promise of RDOF funding.  In fact, these commitments were all made before the RDOF auction was even contemplated.[12]  SpaceX should not now be permitted to seek RDOF funding to complete commitments it has already made to the Commission.

GeoLinks urges the Commission to craft its rules in a way that protects RDOF funding from would-be bidders that seek to subsidize broadband infrastructure that they have already made commitments to the Commission to deploy in exchange for something of value (i.e.  operating authority, merger approval, usage rights, etc.).  While GeoLinks does not oppose making RDOF funding available for service providers proposing new projects in RDOF-eligible areas (separate and apart from any previously made commitments), GeoLinks believes that allowing service providers to apply for RDOF funds to complete commitments already made would result in wasteful use of finite universal service support and promote “double dipping.”


GeoLinks largely supports the pre-auction and bidding procedures and processes proposed in the Public Notice.  However, GeoLinks urges the Commission to take steps to protect RDOF funds by limiting satellite providers and those that have never filed a Form 477 from bidding Gigabit and Above Baseline performance tiers and precluding service providers from participating in the auction if they have already received some incentive from the Commission to deploy high-speed broadband facilities to areas eligible for RDOF funding.


Respectfully submitted,

California Internet, L.P. DBA GeoLinks                                                  

/s/ Skyler Ditchfield, Chief Executive Officer

/s/ Melissa Slawson, General Counsel/ V.P of Government Affairs and Education


March 27, 2020


[1] See Public Notice, “Comment Sought on Competitive Bidding Procedures and Certain Program Requirements for the Rural Digital Opportunity Fund Auction (Auction 904),” AU Docket No. 20-34 and WC Docket Nos. 19-126 & 10-90 (rel. Mar. 2, 2020) (“Public Notice”).

[2] Inc. Magazine’s 37th Annual List of America’s Fastest-Growing Private Companies—the Inc. 5000 (

[3] Public Notice at paras. 49 and 50.

[4] Id. at para 50.

[5] Id.

[6] This includes low-earth orbit satellite providers such as SpaceX, who seek to participate in the RDOF auction.

[7] Memorandum Opinion, Order and Authorization, In the Matter of Space Exploration Holdings, LLC Application for Approval for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System; Application for Approval for Orbital Deployment And Operating Authority for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System Supplement, IBFS File Nos. SAT-LOA-20161115-0018, Call Sign S2983, and SAT-LOA-20170726-00110, Call Sign S3018 (released March 29, 2018) (“SpaceX Order”), at para. 1.

[8] SpaceX Order at paras. 31-33.

[9] Id. at paras. 31 and 33.

[10] SpaceX Order at para. 33.

[11] See SpaceX Notice of Ex Parte Communications, WC Docket No. 19-126, WC Docket No. 10-90 (filed January 20, 2020) stating that “SpaceX is targeting service in the Northern U.S. and Canada in 2020, rapidly expanding to near global coverage of the populated world by 2021.”  See also SpaceX Notice of Ex Parte Communications, WC Docket No. 19-126, WC Docket No. 10-90 (filed February 20, 2020) stating that “SpaceX has already launched over 300 satellites…and has an aggressive launch rate that will ensure full coverage to the entire United States.”

[12] The SpaceX Order was released on March 29, 2018 – 16 months before the Commission released its Notice of Proposed Rulemaking for RDOF.  See generally RDOF Order.

GeoLinks Joins Pledge to Keep Americans Connected

California-based telecommunications provider GeoLinks, has joined the Federal Communications Commission’s pledge to “Keep Americans Connected” during the coronavirus outbreak. The formal joining of the pledge is a vow from the company to ensure that its customers remain connected to vital information infrastructure during these uncertain times.

The Keep Americans Connected Pledge reads as follows:

Given the coronavirus pandemic and its impact on American society, GeoLinks pledges for the next 60 days to:

(1) not terminate service to any residential or small business customers because of their inability to pay their bills due to the disruptions caused by the coronavirus pandemic;

(2) waive any late fees that any residential or small business customers incur because of their economic circumstances related to the coronavirus pandemic; and

(3) open its Wi-Fi hotspots to any American who needs them.

“When my cousin (Chief Technical Officer, Ryan Hauf) and I founded GeoLinks in 2011, it was our mission to improve people’s lives by connecting them to information,” said CEO, Skyler Ditchfield. “We continue to stand behind that mission today and we are dedicated to making sure that our customers remain connected during this challenge.”

GeoLinks is also taking additional steps to ensure that its residential customers have access to enhanced levels of service by increasing speeds for customers who are working remotely due to social distancing guidelines, when possible.

In a news release, FCC Chairman Ajit Pai commended businesses such as GeoLinks for taking these additional steps. “I applaud those companies that have already taken the Keep Americans Connected Pledge” said Chairman Pai. “They are stepping up to the plate and taking critical steps that will make it easier for Americans to stay connected during this pandemic and maintain much-needed social distancing. I urge other companies to join them. This may be a difficult time for our nation, but if we all work together, I am confident that we can rise to the challenge.”

“As leaders in the business community, it is our duty to set the right tone,” concluded Ditchfield. “By showing that we are committed to helping our community, we can show the world how to make it through this difficult time, by working together.”