Mail Stop 3720

      June 14, 2006


J. Timothy Bryan
Chief Executive Officer
ICO Global Communications (Holdings) Limited
Plaza America Tower I
11700 Plaza America Drive, Suite 1010
Reston, VA 20190

	RE:  	ICO Global Communications (Holdings) Limited
		Registration Statement on Form 10
		Filed May 15, 2006
      File No. 0-52006

Dear Mr. Bryan:

	We have reviewed the above filing and have the following
comments.  Where indicated, we think that you should revise your
Form
10 in response to these comments.  If you disagree, we will
consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with information so that we may better understand your disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. Please note that the Form 10 goes effective by lapse of time 60
days after the original filing date, pursuant to Section 12(g)(1)
of
the Securities Exchange Act of 1934.  If our comments are not
addressed within this 60-day time period, you should consider
withdrawing the Form 10 prior to effectiveness and re-filing a new
Form 10 including changes responsive to our comments.  If you
choose
not to withdraw, you will be subject to the reporting requirements
under Section 13(a) of the Exchange Act.
2. Please update your financial statements and all applicable
sections.

Disclosure Regarding Forward-Looking Statements

3. Please revise to delete the second sentence of the second
paragraph, as it is inappropriate for you to disclaim
responsibility
for statements made in your document.  Instead, you may caution
readers not to place undue certainty on any forward-looking
statements.

Business, page 1

General
4. Consider revising to disclose that your website is located at
www.ico.com.  See Item 101(e)(2) of Regulation S-K.

5. Revise to update the status of the various plans you disclose
throughout this section.  For example, disclose the status of your
exploration into the development of a new MEO business plan
outside
of North America, including the extent to which you have had
discussions with potential partners to provide funding.  Similarly
address the extent of your discussions with strategic partner
candidates to develop the infrastructure required for your MSS/ATC
System, including the number of parties contacted, whether you are
negotiating terms with any of these parties, etc.

Financial Information about Geographic Areas, page 14
6. We note that you have no assets listed in the line item,
"Foreign," for 2004 and 2005.  On page 11, you state that you have
a
network management center and a back-up center in Slough, United
Kingdom and a facility in Itaborai, Brazil.  Please revise or
advise.
Also, tell us why this disclosure is not required to be disclosed
in
your notes to the financial statements under paragraph 38(b) of
FAS
131.

Risk Factors, page 14

General
7. Please avoid the generic conclusion in the captions and
discussions that if a risk occurs, your business and results of
operations could be adversely affected or harmed.  Instead,
replace
this language with specific disclosure of the possible impact upon
your operating results, business, liquidity, cash flow, financial
condition, share price, etc.  Also revise other subheadings that
currently do not indicate a specific risk to you or your
investors,
such as "ATC spectrum access is limited by technological factors"
and
"We have not yet applied for ATC authorization."
8. To provide readers with a better understanding of the magnitude
of
the risks discussed, and to the extent practicable, please revise
your risk factors to quantify the possible impact on your
company`s
financial condition, results of operations, or liquidity if a risk
materializes.  For example:
* Disclose the degree to which your "capital requirements would be
even more substantial" if you were required to develop the
necessary
ATC ground infrastructure alone, as discussed in "We have no
significant operations..." on page 15;
* Clarify the amount you will need to pay for the launch insurance
policies summarized on page 11, insurance that would cover the
cost
of insurance, and the degree to which your premiums would rise if
you
failed to launch a satellite, as discussed in "There are
significant
risks associated with building, launching and operating the
satellite..." on pages 15 through 16;
* Estimate the amount of your possible tax liability if the IRS
determines that the company incorrectly offset the gain on the
disposition of certain securities with losses incurred in
connection
with the abandonment of assets associated with your MEO network,
as
discussed in "We are currently being audited by the IRS..." on
page
18;
* Quantify the amount of expenses the company has incurred in
connection with its litigation with Boeing, the amount it expects
to
incur in the future simply to pursue the litigation, and the
possible
amount of damages that you would owe if Boeing is successful in
its
litigation, as discussed in "We are engaged in litigation with The
Boeing Company..." on page 18.

These are examples only.  Also provide quantified discussions of
these factors in your MD&A where appropriate.

"The interests of our controlling stockholder may conflict with
your
interests...," page 25

9. Revise to clarify that Eagle River`s sole manager and member,
Mr.
McCaw, is also your chairman.




Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 28

10. The Commission`s Interpretive Release No. 33-8350, "Commission
Guidance Regarding Management`s Discussion and Analysis of
Financial
Condition and Results of Operations," located on our website at
http://www.sec.gov/rules/interp/33-8350.htm, recommends that
companies identify and disclose known trends, events, demands,
commitments and uncertainties that are reasonably likely to have a
material effect on financial condition or operating performance.
Please consider expanding your MD&A to address any known trends or
uncertainties that could materially affect your results of
operations
or liquidity in the future, providing detailed and quantified
disclosure to the extent practicable in place of some of the
generalized disclosure that currently appears in this section.
For
example, discuss and analyze:

* the payments owed to Loral in the 2006 and 2007 fiscal years, as
summarized on page F-23, as well as the amounts payable for the
provision of launch services for your GEO satellite and the
delivery
of certain gateway segment equipment, including how you intend to
pay
for them;

* the possible tax liability that you will owe if the IRS
determines
that the company incorrectly offset the gain on the disposition of
certain securities with losses incurred in connection with the
abandonment of assets associated with your MEO network, as
discussed
on page 18;

* the ongoing costs of litigation with Boeing, as summarized on
pages
11 and 52;

* the risks associated with launching your GEO satellites into
orbit,
the attendant costs for insuring launch and insuring the cost of
insurance, and the impact on the company going forward if a
satellite
was lost during launch;

* the increased costs you will incur if you fail to secure a
partner
to assist in the development of the necessary ATC ground
infrastructure; and

* the "substantial expenses" and "ongoing compliance costs"
associated with Sarbanes-Oxley regulatory compliance, as mentioned
in
your risk factor on page 19.
11. Detailed disclosure of the company`s future liquidity
requirements should also be provided, including quantified
disclosure, if possible.  Your liquidity section should discuss
the
cash requirements for beginning operations.  For example, your
liquidity section should provide detailed (and quantified, if
possible) disclosure regarding the expenses you expect to continue
to
incur in connection with your plans, including payments to the
manufacturer of your satellite, expenses related to your debt, the
costs of finding a partner to facilitate development of the
required
ATC infrastructure, and how those strategies will affect the
company`s cash needs.  Explain how such expansion plans will
affect
your capital expenditures and liquidity.
12. We note that the company faces numerous milestones imposed by
the
FCC and Ofcom that will force the company to incur significant
expenses in coming years and, if not met, may have a material
impact
on the company`s liquidity and financial condition.  Revise MD&A
to
set forth your numerous regulatory hurdles you face in order to
begin
operations not only in the U.S. (to provide MSS/ATC services) but
also in Europe.  For each regulatory requirement, specify the date
by
which you must be in compliance, quantify the expenses you will
need
to incur in order to meet each milestone (in this regard, we note
the
reference to "costs projected" on page 15), and quantify, to the
extent practicable, the impact on your liquidity and financial
condition if you fail to meet a regulatory milestone.

Overview, page 29

13. The purpose of an Overview section is to provide investors
with
an executive level introduction to ICO Global, its subsidiaries,
its
products and services, and the matters with which management is
concerned primarily in evaluating the company`s financial
condition
and operating results.  In providing this information, it is
important that it not merely duplicate the detailed information
provided in the Business section.  Rather, the Overview section
should provide investors with an executive level introduction of
the
economic or industry-wide factors that management views as most
relevant to the company as a whole and to each of its operating
subsidiaries.  Also, this discussion should provide insight into
challenges, risks and opportunities of which management is aware
of
and discuss any actions being taken to address the same.  This
latter
point seems particularly significant given your history of losses,
the numerous factors that could have an impact on the company`s
liquidity, and the significant regulatory hurdles the company
faces
in order to begin and continue operations.  For a more detailed
discussion of what is expected in this section, please refer to
Release No. 33-8350.
14. Discuss in more detail why you decided to revise your business
plan from the MEO satellite system to the MSS satellite system.

Results of Operations, page 32

15. Provide more specific and quantified (if possible) disclosure
about the "additional costs necessary to develop [y]our MSS/ATC
system."  Similarly address the sources and uses of the funds
necessary to complete the development of the MSS portion of the
system in the first paragraph under "Future Funding Requirements"
on
page 36.  Also revise the disclosure on page 36 to clarify why
your
subsidiary might need to incur additional indebtedness to complete
the MSS portion beyond the $525 million to $600 million as
currently
projected.
16. Please revise to present the interest income in parenthesis
and
the interest expense without parenthesis.

Gain on Disposal of Assets, page 33
17. Please tell us the nature of the equipment exchanged.

Liquidity and Capital Resources, page 34

18. You state in the second paragraph that you believe your cash,
cash equivalents and available-for-sale investments will be
sufficient to fund your operational and capital requirements "at
least through the end of 2007."  However, your disclosure at the
bottom of page 29 about the lack of assurance that you will be
able
to obtain the funding necessary to complete the construction of
your
MSS/ATC System and fund your working capital requirements, as well
as
your first risk factor discussion on page 15, suggest that you
will
require significant funding.  Please revise to clarify the nature
and
timing of your financing needs.

19. Provide a discussion of your anticipated capital expenditures
in
addition to those related to the development of your MSS/ATC
System,
and quantify the expected amounts of capital expenditures for
2006.

20. Expand to discuss the nature of the indenture`s restrictions
on
ICO North America`s transactions with you or your affiliates.
Also
disclose the events that constitute events of default under the
7.5%
notes and the consequences of default.

Security Ownership of Certain Beneficial Owners and Management,
page
39
21. Revise the table to include the full number and percentage of
Class A shares that Eagle River and Mente, LLC, beneficially own.
22. Disclose the person(s) who has voting and/or investment
control
over the shares held by CDR-Satco LLC, to the extent it is not
widely
held.

Employment Agreements with Named Executive Officers..., page 49
23. Provide disclosure about the parameters that will be evaluated
in
determining whether bonuses are to be paid to your executive
officers, including whether bonuses are paid regardless of whether
or
not the company is profitable as measured by net income.

Certain Relationships and Related Transactions, page 52

24. Disclose the amount paid to Davis Wright Tremaine LLP for
legal
services during the last fiscal year.

Report of Independent Registered Public Accountant, page F-4
25. We note that the audits were conducted in accordance with the
auditing standards generally accepted in the United States of
America.  Please tell us why the audit report is not required to
refer to the standards of the Public Company Accounting Oversight
Board (United States).

Consolidated Statements of Changes in Stockholders` Equity, page
F-10
26. Please tell us the nature of your deferred tax liability
associated with the Nextel Communications, Inc. share
contribution.

Note 3. Use of Estimates, page F-13
27. Revise expand your disclosures in the "Critical Accounting
Policies" on page 30 to include your accounting policies for
depreciation, taxes, contingencies, and asset useful lives.

Note 5. Impairment of Long-Lived Assets, page F-20
28. In 2003, we note that you decided that you would no longer
provide full funding of the gateways for the MEO satellite system.
We also note that you wrote down the system to zero even though
you
are exploring "the development of a new MEO business plan outside
North America that would utilize both the Company`s physical and
regulatory MEO satellite assets."  On page 11, you disclose that
you
have one MEO satellite in orbit that provides data gathering
services.  On page 19, you disclose that you are still performing
under one of the agreements.  Please tell us how you determined
that
the assets should be written down to zero and your consideration
of
paragraph 28 of FAS 144.  Also, tell us why you are not
recognizing
any revenues related to the F2 satellite that is providing data
sharing services.




Note 8. Purchase Commitments, page F-23
29. Please tell us how you are accounting for the incentive
payments
and the basis for your accounting.  Include in your response
references to the appropriate accounting literature.

Note 9. Restricted Stock Awards, page F-26
30. Please tell us why it is appropriate to recognize the 1
million
shares of restricted Class A common stock granted to Eagle River
for
services provided in the prior five years as a stock dividend.
Also,
tell us how you determined the fair market value of $0.01 per
share.
Include in your response references to the appropriate accounting
literature.


*	*	*	*

      As appropriate, please amend your filing and respond to our
comments within 10 business days, or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
on EDGAR that keys your responses to our comments and provides any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that they
have
provided all information investors require.  Since the company and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments in the filing reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Michael Henderson, Staff Accountant, at (202)
551-3364, or Dean Suehiro, Senior Staff Accountant, at (202) 551-
3384, if you have questions regarding comments on the financial
statements and related matters.  Please contact Derek Swanson,
Staff
Attorney, at (202) 551-3366, or me at (202) 551-3810, with any
other
questions.



								Sincerely,

 								/s/ Michele M. Anderson
								Michele M. Anderson
								Legal Branch Chief

























cc:	John L. Flynn, General Counsel
	Via Facsimile: (703) 964-1401
J. Timothy Bryan
ICO Global Communications (Holdings) Limited
June 14, 2006
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE