The company bought licenses for Channel 55 in many U.S. media markets several years ago to build the MediaFLO service, which delivers 15 channels of programming to cell phones equipped with special receivers. Both AT&T and Verizon offer MediaFLO services and handsets. MediaFLO is available in 65 U.S. markets already, but it can't go nationwide until analog TV stations on Channels 54 through 56 go off the air, he wrote. Qualcomm plans to turn on 100 more transmitters on Feb. 18 to bring MediaFLO to 15 new markets and expand services in 25 others.

"We believe that it would be unfair, unjust, and inappropriate to delay the DTV transition beyond February 17, 2009," Jacobs told the lawmakers. Qualcomm does support legislation to help deliver enough coupons for converter boxes to Americans who are still using traditional analog TV sets, Jacobs wrote. He noted that Qualcomm has aired thousands of public service announcements alerting consumers to the digital TV transition, ironically over the cutting-edge MediaFLO digital broadcasting service.

If the general deadline is pushed back, Qualcomm wants the government to force stations in four select markets, where the bulk of the 40 million added potential users live, to abide by the Feb. 17 date. Those nine analog stations in the San Francisco, Houston, Boston and Miami areas would interfere with the company's next planned expansion, according to Qualcomm.

One of the broadcasters that would be singled out by Qualcomm's proposal said it would comply with the law but its first concern is for viewers.

"We are prepared for the digital transition, from a technical standpoint, but I think the big question in the air is, is the public prepared?" said Scott Walton, executive director of communications at Northern California Public Broadcasting, which operates KTEH, Channel 55, in the San Francisco Bay Area.