Exhibit 10.7

Boingo Wireless, Inc.

2010 Management Incentive Plan

($ Mil)

I. Financial Objectives

Weighting

| Revenue |  | 60 | % |  |  |  |  |  |
| Adjusted EBITDA |  | 15 | % |  |  |  |  |  |
| Free cash flow |  | 20 | % |  |  |  |  |  |
| Net Income |  | 5 | % |  |  |  |  |  |
Targets ($ mil) |  |  |  |  |  |  |  |  |  |
|  |  |  | Plan |  |  | Cap |  |  | Floor |  |  |
| Revenue |  | $ | 79 | .3 | 120.0 | % | 90.0 | % |  |
| Adjusted EBITDA |  | $ | 19 | .3 | 120.0 | % | 70.0 | % |  |
| Free cash flow |  | $ | 9 | .7 | 120.0 | % | 70.0 | % |  |
| Net Income |  | $ | 8 | .1 | 120.0 | % | 70.0 | % |  |
Payout % of Salary at Targets |  |  |  |  |  |  |  |  |
| Plan |  | 100 | % |  |  |  |  |  |
| Cap |  | 170 | % |  |  |  |  |  |
| Floor |  | 30 | % |  |  |  |  |  |
Payouts % of Salary by Position |  |  |  |  |  |  |  |  |
| CEO |  | 60.0 | % |  |  |  |  |  |
| CFO |  | 50.0 | % |  |  |  |  |  |
| CTO & SVP BD & SVP Fin. |  | 35.0 | % |  |  |  |  |  |
II. Strategic Initiative Overlay |  |  |  |  |  |  |  |  |
| CEO, CFO, CTO, SVP BD & SVP Fin. | 20% of Salary |  |  |  |  |
| Criteria: To obtain full payout, 2 of 3 must be achieved |  |  |
Strategic Initiatives |  |  |  |  |  |  |  |  |  |
| 1. Device distribution expansion: Major wholesale or retail distribution expansion agreement is signed |
| 2. Expansion of managed and operated footprint: Incremental enplanements of at least 30M or significant foot traffic in a new business area such as fast food, mall, arena, etc. |
| 3. Establish service provider model: Sign an agreement whereby Boingo generates positive economics as the Wi-Fi service provider for a carrier or as the service provider in a free location |

All payments under the 2010 Management Incentive Plan are at the discretion of the Board of Directors