The undersigned organizations, representing the breadth of the RFID ecosystem, believe NextNav’s recent “test” video and accompanying blog post fall far short of addressing the documented coexistence and interference risks associated with high-power terrestrial operations in the lower 900 MHz band. Rather than providing a rigorous technical rebuttal, the materials rely on narrow, highly controlled scenarios that fail to reflect the real-world environments in which RFID systems operate. Ultimately, NextNav’s latest claims do more to expose gaps in the company’s coexistence strategy than to resolve the serious concerns already identified in the FCC record.

The materials released by NextNav lack the technical detail, methodology, and documentation necessary for meaningful independent evaluation. To the extent limited details are either provided or apparent from the video itself, the scenarios depicted reflect highly controlled conditions that bear little resemblance to the complex, interference-rich environments in which RFID systems operate across critical sectors of the economy.

Equally important, NextNav’s materials fail to address interference from widespread RAIN RFID operations into NextNav’s proposed network. This is a central coexistence concern that has been identified in independent technical analysis already submitted into the FCC record.

The undersigned organizations and companies remain committed to constructive, fact-based engagement on spectrum policy issues. Given the enormous economic importance of RFID systems and the critical industries that depend on them, coexistence questions require rigorous, transparent, and independently verifiable technical analysis grounded in real-world operating conditions. The performative, promotional materials released by NextNav do not provide that.