If the FCC doesn't let LightSquared build its network, the agency will be breaching its agreement with the carrier and violating its constitutional rights, according to LightSquared.

The proposed FCC action would "strip away the approval it granted and leave LightSquared and its investors holding the bag for billions of dollars of losses," the filing said. That could violate their constitutional right to due process under the law, Carlisle said.

The FCC's change of heart over whether LightSquared can build a nationwide terrestrial network will undermine confidence in the FCC's policies and lower the value of spectrum across the wireless industry through uncertainty, the company said. LightSquared said it would be "one of the most disastrous 'bait-and-switch' episodes in the history of telecommunications regulation."

The filing reiterated arguments the carrier has already made repeatedly, saying any interference is not LightSquared's fault, interference tests have been flawed, and the FCC granted LightSquared's predecessor company the right to build a land-based cellular network almost seven years ago.

"This is the one place where all of those different strands of fairness, of law, of technology and policy, are being brought together in one document," Carlisle said.