Petri Mähönen, Ljiljana Simić and I recently filed comments in the Spectrum Frontiers proceeding, FCC Docket No. 14-177 (filing page, pdf, docket on ECFS). We argued that the operating and propagation characteristics of mm-wave systems mean that non-exclusive licensing – meaning in this case, a limited number of large-area licenses assigned by auction – is an appropriate middle path between exclusive large-area licensing (which may lead to under-utilization) and unlicensed (which may not provide sufficient interference protection).