Letterhead of Chadbourne & Parke LLP
                              30 Rockefeller Plaza
                            New York, New York 10112
                                 (212) 408-5100

                                  May 12, 2006

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re:     ORBCOMM Inc.
        Registration Statement on Form S-1

Ladies and Gentlemen:

          For the purpose of registering under the Securities Act of 1933, as
amended (the "Securities Act"), shares of Common Stock, par value $0.001 per
share, of ORBCOMM Inc., a Delaware corporation ("ORBCOMM"), with a maximum
aggregate offering price of $150,000,000, transmitted herewith is ORBCOMM's
Registration Statement on Form S-1 (the "Registration Statement") and the
exhibits thereto.

          In connection with the filing of the Registration Statement, ORBCOMM
is also submitting a request, pursuant to Rule 406 under the Securities Act and
Rules 80(b)(3) and 80(b)(4) under the Freedom of Information Act, for an order
granting confidential treatment to certain portions of certain exhibits to the
Registration Statement.  On behalf of ORBCOMM, we respectfully request that the
review of the Registration Statement and the request for confidential treatment
by the staff of the Securities and Exchange Commission be considered on the
same time schedule.

          Should you have any questions or comments concerning the Registration
Statement, please telephone collect Sey-Hyo Lee at (212) 408-5122, Alejandro San
Miguel at (212) 408-8009 or James Laws at (212) 408-5547 of this office.

                                                          Very truly yours,

                                                          Chadbourne & Parke LLP



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