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Display Options  Commission Document Attachment       Grain
Management, LLC’s Request for Clarification or Waiver of Section
1.2110(b)(3)(iv)(A)  of the Commission’s Rules; Implementation
of the Commercial Spectrum Enhancement Act  and Modernization of
the Commission’s Competitive Bidding Rules and Procedures, WT
Docket No. 05-211; Expanding the Economic and Innovation
Opportunities of Spectrum  Through Incentive Auctions, GN Docket
No. 12-268; Amendment of the Commission’s Rules   2180 MHz
Bands, GN Docket No. 13-185.  I must respectfully dissent from
this waiver order that exempts Grain Management, LLC (and  other
similarly situated parties) from the bright-line trigger of the
attributable material relationship  (AMR) rule. I do so because
I am not persuaded that the standard for a waiver under section
1.925 of the  Commission’s rules has been met.1 I am also
concerned that today’s action sets in motion an effort to
undermine the designated entit