TRENDS in FCC ENFORCEMENT | Equipment Manufacturer Violations 2006-2013

TRENDS IN FCC ENFORCEMENT | Equipment Manufacturer Violations 2006-2013

2006 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Ramsey Electronics, Inc. 1/25/06 Offering uncertified devices for sale 4 FM broadcast transmitters $28,000 Downward adjustment of $3,000 based $25,000 and RF power amplifiers on history of overall compliance Shenzhen Ruidian 3/3/06 Failing to respond to Enforcement N/A N/A $4,000 N/A $4,000 Communication Co. Bureau directive to supply documents Gibson Tech Ed, Inc. 3/21/06 Offering uncertified devices for sale 2 FM broadcast transmitters $14,000 N/A $14,000 ACR Electronics, Inc. 3/23/06 Offering uncertified device for sale; 1 Personal location beacon $75,000 Downward adjustment of $10,000 based on $65,000 extensive advertising and falsely prior history of overall compliance; proposed stating the device was approved forfeiture amount based on ability to pay and knowingly conducting substantial media cam- paign promoting unauthorized equipment to the general public Hawking Technologies, 4/17/06 Stating in marketing material that the 1 RF power amplifier $22,000 Proposed forfeiture includes $15,000 upward $17,600 Inc. device attaches to any wireless device adjustment for substantial economic gain; with a removable antenna when the further downward adjustment of $5,400 equipment authorization provided that for prior history of overall compliance the device may be used only with wireless access points authorized under FCC ID# NDD9572030410 OleumTech Corporation 5/11/06 Marketing an intentional radiator 1 Wireless transmitter- $5,600 Proposed forfeiture includes $1,400 $5,600 device prior to obtaining Commission oil and gas pipeline downward departure for good faith effort equipment authorization monitoring device to bring the transmitter into compliance- submitting device for certification testing prior to receiving the LOI Pilot Travel Centers LLC 5/11/06 Offering non-certified CB transmitters 13 displays CB transmitters $125,000 Proposed forfeiture includes $34,000 $90,000 for sale of non- upward adjustment for pattern of (Consent certified violations following nine citations Decree) models Travel Centers of America 6/29/06 Offering non-certified CB transceivers 1 CB transmitters $7,000 N/A $7,000 for sale American Medical Alert 7/11/06 Labeling violations, emissions in excess 9 Personal emergency N/A N/A $75,000 Corporation of Part 15 limits and other unspecified response equipment (Consent voluntary disclosures of “compliance Decree) issues” Applied Wireless 8/1/06 Unspecified voluntary disclosures of Undisclosed Unspecified RFID devices N/A N/A $40,000 Identifications Group, non-compliance with technical standards (Consent Inc. and labeling requirements Decree)

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 1 2006 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Clegg Industries, Inc. 9/29/06 Importing and marketing “Space 1 FM broadcast receiver $7,000 N/A $7,000 Needle” model radios prior to their verification and without the proper labeling Love’s Travel Stops and 9/29/06 Offering non-certified CB transceivers 3 displays CB transmitters $25,000 Proposed forfeiture includes $4,000 upward $25,000 Country Stores, Inc. for sale of non- adjustment for a “pattern of intentional certified non-compliance with and apparent disregard models for these rules” Vitec Group 10/31/06 Advertising devices in magazine, 2 Digital wireless $14,000 $2,800 downward adjustment based on $11,200 Communications Limited displaying devices at trade show, intercom systems history of overall compliance and offering devices for sale on the Internet before obtaining certification AboCom Systems, Inc. 11/9/06 Marketing devices which produced 1 Wireless access points $25,000 Proposed forfeiture amount includes $25,000 a spurious emission “substantially $18,000 upward adjustment based on exceeding” permissible limits and (i) substantial number of devices sold, that could operate beyond the (ii) continuing nature of violations over authorized frequency range 17 months, and (iii) ability to pay

Boston Scientific 12/7/06 Investigation whether devices produced 3 product CRM implantable cardiac N/A N/A $25,000 Corporation RF emissions in the 90-110 kHz band families devices (Consent and whether required equipment Decree) authorizations were obtained GI Joe’s Radio Electronics 12/11/06 Offering non-certified devices for sale 8+ CB transceivers and $21,000 N/A $21,000 and GI Joe’s CB Radio external RF power amplifiers American Future 12/14/06 Marketing devices to the general public 2 Computers $14,000 N/A $14,000 Technology Corporation prior to obtaining a Declaration of d/b/a iBuypower Conformity Multispectral Solutions, 12/14/06 Marketing unauthorized RF devices 1 Ultra-wideband N/A No devices marketed within the applicable Admonishment Inc. localization system statute of limitations period only Gambler’s CB & Ham 12/21/06 Offering non-certified devices for sale 2 CB transceivers $7,000 N/A $7,000 Radio Sales & Service Total 2006 $478,400

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 2 2007 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Metamerchant 2/2/07 Offering non-certified devices for sale 2 VHF and UHF transceivers $14,000 N/A $14,000 via Ebay Communications 3/1/07 Marketing devices in excess of radiated 1 Pet locator transmitter $7,000 Details of downward adjustment not dis- $5,600 Specialists, Inc emission limits which did not comply closed with periodic operation limits due to continuous transmission 1 Stop Communications / 3/2/07 Offering non-certified devices for sale 1 CB transceivers $7,000 N/A $7,000 1 Stop CB Shop Candy Electronics 3/16/07 Offering non-certified devices for sale 10+ CB transceivers and $14,000 $7,000 forfeiture issued collectively for each $14,000 external RF power of transceivers and amplifiers amplifiers Ramko Distributors, Inc. 3/30/07 Marketing non-certified radio transceiv- 17 CB transceivers $150,000 $31,000 upward adjustment for pattern of $150,000 ers intentional non-compliance and disregard for FCC rules Hawking Technologies, 4/2/07 Marketing devices as being able to 1 RF power amplifier $50,000 $43,000 upward adjustment based on $50,000 Inc. connect to any wireless device, and (i) substantial number of amplifiers sold, packaging the device with a connector (ii) violations continuing over 12-months, enabling universal use and (iii) previous issuance of a forfeiture for violating the same rule Trimble Navigation, 4/24/07 Design change to the power circuitry 1 Spread Spectrum $4,000 N/A $4,000 Limited causing the RF conducted power to Transmitter (Consent exceed the peak power limits by approxi- Decree) mately 1.4 dB Pine Telephone Company, 5/22/07 Failure to comply with the labeling 2 Digital wireless handsets $16,000 N/A $16,000 Inc. d/b/a Pine Cellular requirements for digital wireless Phones, Inc. hearing aid-compatible handsets Regent U.S.A., Inc. 5/30/07 Importing and interstate shipment of 1,182 units Televisions $63,650 Proposed forfeiture amount based on $63,650 televisions without DTV receivers per-unit/tier system Behringer USA, Inc. 6/1/07 Importing and marketing non-verified 50 Digital audio music devices $1,000,000 Proposed forfeiture includes $650,000 upward $1,000,000 Class B devices adjustment for (i) continuing to import and market unauthorized devices for more than a year after representing that it would come into compliance; (ii) ability to pay; (iii) egregious nature of misconduct; and (iv) substantial economic gain Rocky Mountain Radar 8/16/07 Offering uncertified devices for sale 2 Police radar jamming $25,000 Proposed forfeiture includes upward adjustment $25,000 whose purpose is to interfere with devices of $11,000 for pattern of intentional non-com- licensed radio services pliance with and disregard for FCC rules

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 3 2007 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Ultimate Electronics, Inc. 10/15/07 Failing to place the required Consumer 3 Televisions $24,000 $8,000 base forfeiture amount per $24,000 Alert label on an analog broadcast televi- unlabeled model established sion tuner displayed or offered for sale Boscov’s, Inc. 10/15/07 Failure to place the required Consumer 2 Televisions $16,000 $8,000 base forfeiture amount per $16,000 Alert label on an analog broadcast tele- unlabeled model vision tuner displayed or offered for sale Fred Meyer Stores 10/15/07 Failure to place the required Consumer 3 Televisions $24,000 $8,000 base forfeiture amount per $24,000 Alert label on an analog broadcast tele- unlabeled model vision tuner displayed or offered for sale Gregg Appliances, Inc. 10/15/07 Failure to place the required Consumer 1 Televisions $8,000 $8,000 base forfeiture amount per $8,000 Alert label on an analog broadcast tele- unlabeled model vision tuner displayed or offered for sale Radio Shack Corporation 10/15/07 Failure to place the required Consumer 2 Televisions $16,000 $8,000 base forfeiture amount per $16,000 Alert label on an analog broadcast tele- unlabeled model vision tuner displayed or offered for sale Trans World Entertain- 10/15/07 Failure to place the required Consumer 1 Televisions $8,000 $8,000 base forfeiture amount per $8,000 ment Corporation d/b/a/ Alert label on an analog broadcast tele- unlabeled model F.Y.E. vision tuner displayed or offered for sale AST Telecom d/b/a/ Blue 10/22/07 Failure to comply with labeling require- 1 model in Digital wireless handsets $8,000 $8,000 assessed for each HAC $8,000 Sky Communications ments for hearing aid compatible violation labeling violation handsets Microwave Radio 10/26/07 Marketing uncertified devices on its web 1 4.9 GHz aeronautical $7,000 N/A $7,000 Communications LLC site transmitting equipment South Central Telephone 11/1/07 Failure to comply with labeling require- 3 models in Digital wireless handsets $24,000 $8,000 assessed for each HAC labeling viola- $24,000 Association, Inc. ments for hearing aid compatible violation tion handsets The Antique Radio 11/27/07 Offering uncertified devices for sale on 1 AM radio transmitters $7,000 N/A $7,000 Collector its website XIT Telecommunications 11/27/07 Failure to comply with inductive cou- 1 of 2 Digital wireless handsets N/A Monetary forfeiture precluded by the appli- Admonishment & Technology, Ltd. d/b/a pling hearing aid compatibility require- required cable statute of limitations only XIT Cellular ments models offered for sale

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 4 2007 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Austin Hughes 12/3/07 Marketing non-verified Class A digital 9 Keyboards, monitors, and $63,000 N/A $63,000 Solutions, Inc. devices keyboard-video-mouse switches and extenders

Broadcast Microwave 12/10/07 Marketing unauthorized devices 1 4.9 GHz Digital N/A N/A $5,000 Services, Inc. Wireless Camera (Consent System Decree) Total 2007 $1,571,250

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 5 2008 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

South Canaan Cellular 1/3/08 Failure to comply with inductive cou- 1 of 2 Digital wireless handsets $15,000 Base forfeiture amount of $15,000 $15,000 Communications pling hearing aid compatibility require- required per missing handset established Company, L.P. ments models offered for sale Ryzex, Inc. 1/29/08 Marketing devices modified by replacing 2 Portable data terminals $8,000 Proposed forfeiture includes $6,000 down- $8,000 the two mbps radio assemblies with ward adjustment because marketing an 11 mbps radio assemblies without improperly labeled device is not authorization from the grantee and as significant a violation as marketing without adequate labeling an unauthorized or technically non-compliant device AST Telecom d/b/a Blue 2/27/08 Failure to comply with inductive cou- 1 of 2 Digital wireless handsets $15,000 Base forfeiture amount of $15,000 $15,000 Sky Communications pling hearing aid compatibility require- required per missing handset ments models offered for sale Epic Touch Company, Inc. 2/28/08 Failure to comply with inductive cou- 0 of 2 Digital wireless handsets $30,000 Base forfeiture amount of $15,000 $30,000 pling hearing aid compatibility require- required per missing handset ments models offered for sale DBK Concepts, Inc. 2/29/08 Marketing devices modified by replacing 3 Portable data terminals $15,000 Proposed forfeiture includes $6,000 $15,000 the two mbps radio assemblies with downward adjustment for models 11 mbps radio assemblies without marketed with only an improper label; authorization from the grantee and no adjustment for the device that was both without adequate labeling unauthorized and improperly labeled Hauppauge Computer 3/5/08 Failure to respond to an Enforcement N/A N/A $11,000 Proposed forfeiture includes $7,000 upward $11,000 Works, Inc. Bureau Letter of Inquiry adjustment for failing to respond to multiple inquiries Global Microwave 3/7/08 Marketing unauthorized radio frequency 1 4.9 GHz aeronautical trans- N/A No devices marketed within applicable stat- Admonishment Systems, Inc. devices mitting equipment ute of limitations only CTC Telecom, Inc. 3/11/08 Failure to comply with inductive cou- 0 of 2 Digital wireless handsets $30,000 Base forfeiture amount of $15,000 per miss- $30,000 pling hearing aid compatibility require- required ing handset ments models offered for sale SLO Cellular, Inc. 3/13/08 Failure to comply with inductive cou- 1 of 2 Digital wireless handsets $45,000 Proposed amount includes $15,000 forfeiture $45,000 pling hearing aid compatibility require- required for failing to comply with acoustic coupling ments models compatibility requirements and $30,000 offered for forfeiture for failing to comply with inductive sale coupling compatibility requirements

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 6 2008 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Pine Telephone Company, 3/19/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets $16,000 Upward adjustment of $17,000 may $33,000 Inc. pling hearing aid compatibility require- be attributed to violations uncovered follow- (Consent ments ing issuance of additional Letter of Inquiry Decree) South Slope Wireless 3/20/08 Failure to comply with inductive cou- 0 of 2 Digital wireless handsets $15,000 Base forfeiture amount of $15,000 $15,000 pling hearing aid compatibility require- required per missing handset–forfeiture for ments models one missing handset precluded by offered for statute of limitations sale CB Shop & More, LLP 3/21/08 Offering non-certified device for sale 1 CB transceiver $7,000 N/A $7,000 Iowa Wireless Services, 3/21/08 Failure to comply with inductive cou- 1 of 2 Digital wireless handsets $22,500 Base forfeiture amount of $15,000 per miss- $22,500 LLC d/b/a i wireless pling hearing aid compatibility require- required ing handset; upward adjustment of $7,500 ments models based on comparative size and ability to pay offered for sale Cable & Communications 4/7/08 Failure to comply with inductive cou- 1 of re- Digital wireless handsets $15,000 Proposed forfeiture reduced per $12,000 Corp. d/b/a Mid-Rivers pling hearing aid compatibility require- quired adoption of compliance plan (Consent Cellular ments 2 models Decree) Syntax-Brillian 4/10/08 Importing and interstate shipment of 11,524 Televisions $2,899,575 Downward adjustment of $1,633,475 based on $1,277,100 Corporation televisions without DTV receivers units correction of number of non-compliant units shipped within the statute of limitations. Forfeiture Order includes additional $11,000 NAL for providing incorrect or misleading material factual information to the FCC Best Buy Co., Inc. 4/10/08 Failing to place the required Consumer 35 Televisions $280,000 N/A-$8,000 base forfeiture amount $280,000 Alert label on analog broadcast televi- per unlabeled model sion tuners displayed or offered for sale Circuit City Stores, Inc. 4/10/08 Failing to place the required Consumer 89 Televisions $712,000 N/A-$8,000 base forfeiture amount $712,000 Alert label on analog broadcast televi- per unlabeled model sion tuners displayed or offered for sale CompUSA, Inc. 4/10/08 Failing to place the required Consumer 21 Televisions $168,000 N/A-$8,000 base forfeiture amount $168,000 Alert label on analog broadcast televi- per unlabeled model sion tuners displayed or offered for sale Fry’s Electronics, Inc. 4/10/08 Failing to place the required Consumer 48 Televisions $384,000 N/A-$8,000 base forfeiture amount $38 4,0 0 0 Alert label on analog broadcast televi- per unlabeled model sion tuners displayed or offered for sale Polaroid Corporation 4/10/08 Interstate shipment of digital television 31 (estimat- Televisions $775,000 N/A-$25,000 base forfeiture amount $775,000 receivers without V-chips ed) exact per non-compliant model number not disclosed

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 7 2008 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Precor Incorporated 4/10/08 Importing and interstate shipment of Not Dis- Televisions $357,900 N/A-proposed forfeiture amount based $357,900 televisions without DTV receivers closed on per-unit/tier system Proview Technology, Inc. 4/10/08 Interstate shipment of digital television 12 (estimat- Televisions $300,000 N/A-$25,000 base forfeiture amount $ 3 0 0, 0 0 0 receivers without V-chips ed) exact per non-compliant model number not disclosed Sears Roebuck and Co. 4/10/08 Failing to place the required Consumer 137 (es- Televisions $1,096,000 N/A-$8,000 base forfeiture amount $ 1 , 0 9 6 , 0 0 0 and Kmart Corporation Alert label on analog broadcast televi- timated) per unlabeled model sion tuners displayed or offered for sale exact number not disclosed Consumer Electronics 4/10/08 Failing to place the required Consumer 37 Televisions $296,000 N/A-$8,000 base forfeiture amount $ 2 9 6, 0 0 0 Retailer (See www.fcc. Alert label on analog broadcast televi- per unlabeled model gov/eb/Orders) sion tuners displayed or offered for sale Wal-Mart Stores, Inc. 4/10/08 Failing to place the required Consumer 124 Televisions $992,000 N/A-$8,000 base forfeiture amount $992,0 0 0 and Sam’s West, Inc. Alert label on analog broadcast televi- per unlabeled model sion tuners displayed or offered for sale Audiovox Corporation 4/10/08 Interstate shipment of digital television Not Dis- Televisions N/A N/A $20,000 receivers without V-chips closed (Consent Decree) Panasonic Corporation 4/10/08 Interstate shipment of digital television Not Dis- Televisions N/A N/A $320,000 receivers noncompliant with V-Chip or closed (Consent DTV tuner requirements Decree) Philips Consumer 4/10/08 Interstate shipment of digital television Not Dis- Televisions N/A N/A $450,000 Electronics North America receivers without V-chips closed (Consent Decree) Vizio, Inc. 4/10/08 Interstate shipment of digital television Not Dis- Televisions N/A N/A $370,000 receivers without V-chips closed (Consent Decree) Westinghouse Digital 4/10/08 Interstate shipment of digital television Not Dis- Televisions N/A N/A $210,000 Electronics, LLC receivers without V-chips closed (Consent Decree) LG Electronics Inc. and 4/11/08 Interstate shipment of digital television Not Dis- Televisions N/A N/A $1,700,000 LG Electronics, USA receivers without V-chips closed (Consent Decree) Sanyo Corporation 4/11/08 Interstate shipment of digital television Not Dis- Televisions N/A N/A $375,000 receivers without V-chips closed (Consent Decree)

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 8 2008 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Alaska DigiTel, LLC 4/23/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets N/A N/A $15,000 pling hearing aid compatibility require- (Consent ments Decree) Value City Department 5/9/08 Failing to place the required Consumer 27 Televisions $216,000 N/A-$8,000 base forfeiture amount $216,000 Stores, Inc. Alert label on analog broadcast televi- per unlabeled model sion tuners displayed or offered for sale Toys “R” Us, Inc. 5/9/08 Failing to place the required Consumer 31 Televisions $248,000 N/A-$8,000 base forfeiture amount $248,000 Alert label on analog broadcast televi- per unlabeled model sion tuners displayed or offered for sale Edge Wireless Licenses, 5/9/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets N/A N/A $15,000 LLC pling hearing aid compatibility require- (Consent ments Decree) Custer Telephone 5/9/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets N/A N/A $12,000 Cooperative, Inc. pling hearing aid compatibility require- (Consent ments Decree) Digital Antenna, Inc. 5/12/08 Failure to respond fully to Enforcement Undisclosed Cellular and PCS boosters $11,000 Proposed amount includes $7,000 upward $11,000 Bureau Letters of Inquiry regarding and repeaters adjustment based on multiple infractions marketing of boosters and repeaters to unlicensed end users and potential interference Custer Telephone 5/21/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets N/A N/A $12,000 Cooperative, Inc. pling hearing aid compatibility require- (Consent ments Decree) Rajant Corporation 5/30/08 Unspecified self-reported violations of Not Dis- Wireless broadband N/A N/A $29,400 Parts 2 and 15 of the FCC’s rules closed network devices (Consent Decree) Farmers Cellular 6/4/08 Failure to comply with inductive cou- 0 of 2 Digital wireless handsets $30,000 Base forfeiture amount of $15,000 $30,000 Telephone, Inc. pling hearing aid compatibility require- required per missing handset ments models offered for sale SunCom Wireless, Inc. 6/4/08 Failure to comply with inductive cou- 0 of 2 Digital wireless handsets $60,000 Base forfeiture amount of $15,000 $60,000 pling hearing aid compatibility require- required per missing handset; proposed forfeiture ments models amount includes $30,000 upward adjustment offered for because violations of hearing sale aid compatibility handset requirements by Tier II carriers are more egregious than those committed by smaller Tier III carriers

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 9 2008 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

L.P. Ryan / 6/5/08 Marketing uncertified AM 1 AM radio transmitters $7,000 Downward adjustment of $6,390 based $610 Low Power Radio radio transmitters on the individual’s inability to pay due to disability and fixed income Choice Wireless, LC 6/10/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets N/A N/A $24,000 pling hearing aid compatibility require- (Consent ments Decree) Union Telephone 6/11/08 Failure to comply with inductive cou- 1 of 2 Digital wireless handsets $15,000 Base forfeiture amount of $15,000 $15,000 Company pling hearing aid compatibility require- required per missing handset ments models offered for sale BJ’s Wholesale Club, Inc. 6/12/08 Failure to place required Consumer Alert Undisclosed Televisions N/A N/A $20,000 label on analog broadcast television tun- (Consent ers displayed or offered for sale Decree) Big Lots Stores, Inc. 6/12/08 Failure to place required Consumer Alert Undisclosed Televisions N/A N/A $48,000 label on analog broadcast television tun- (Consent ers displayed or offered for sale Decree) Variety Wholesalers, Inc. 6/12/08 Failure to place required Consumer Alert Undisclosed Televisions N/A N/A $38,000 label on analog broadcast television tun- (Consent ers displayed or offered for sale Decree) PinPoint Wireless, Inc. 6/13/08 Failure to comply with coupling 0 of 2 Digital wireless handsets $30,000 Base forfeiture amount of $15,000 $30,000 compatibility requirements for hearing required per missing handset aid compatible handsets models offered for sale Conn’s, Inc. 6/13/08 Failure to place required Consumer Alert Undisclosed Televisions N/A N/A $70,000 label on analog broadcast television tun- (Consent ers displayed or offered for sale Decree) Rent-A-Center, Inc. 6/13/08 Failure to place required Consumer Alert Undisclosed Televisions N/A N/A $60,000 label on analog broadcast television tun- (Consent ers displayed or offered for sale Decree) Centennial 6/17/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets $40,000 Base forfeiture amount of $15,000 $40,000 Communications Corp. pling hearing aid compatibility require- per missing handset; forfeiture for one ments missing handset precluded by statute of limitations; $30,000 upward adjustment because violations of hearing aid compatibility handset requirements by Tier II carriers are more egregious than those committed by smaller Tier III carriers

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 10 2008 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Blanca Telephone 6/18/08 Failure to comply with inductive cou- 0 of 2 Digital wireless handsets $15,000 Base forfeiture amount of $15,000 $15,000 Company pling hearing aid compatibility require- required per missing handset; forfeiture for one miss- ments models ing handset precluded by statute offered for of limitations sale Funai Corporation, Inc. 7/10/08 Interstate shipment of televisions Undisclosed Televisions $7,745,687 Downward adjustment of $7,410,687 $335,000 without V-chips due in part to incorrect information supplied (Consent to FCC in LOI response concerning compliant Decree) status of certain models used to calculate initial proposed forfeiture NE Colorado Cellular, Inc. 7/14/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets N/A N/A $12,000 d/b/a Viaero Wireless pling hearing aid compatibility require- (Consent ments Decree) IT&E Overseas, Inc. 7/28/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets $16,000 Upward adjustment due to additional viola- $54,000 pling hearing aid compatibility require- tions discovered since issuance (Consent ments of initial proposed forfeiture Decree) Michael Kersnowski d/b/a 7/30/08 Marketing and offering for sale 2 CB transceivers $7,000 N/A $7,000 radioactiveradios.com non-certified CB transceivers Corr Wireless 7/31/08 Failure to comply with inductive cou- 1 of 2 Digital wireless handsets $30,000 Base forfeiture amount of $15,000 per miss- $30,000 Communications, LLC pling hearing aid compatibility require- required ing handset; upward adjustment ments models of $15,000 based on ability to pay and con- offered for tinuous violation for almost 1 year sale Airadigm 8/1/08 Failure to comply with inductive cou- Undisclosed Digital wireless handsets N/A N/A $11,000 Communications, Inc. pling hearing aid compatibility require- (Consent ments Decree) Sirius Satellite Radio, Inc. 8/5/08 Sale of non-compliant satellite receiv- Undis- Satellite radio receivers/ N/A N/A $2,200,000 ers in violation of Parts 2 and 15 and closed/11 terrestrial repeaters (Consent unauthorized construction and operation unauthor- Decree) of terrestrial repeaters in violation of ized repeat- Part 25 rules ers XM Satellite Radio, Inc. 8/5/08 Sale of non-compliant satellite receiv- Undis- Satellite radio receivers/ N/A N/A $17,394,375 ers in violation of Parts 2 and 15 and closed/ 479 terrestrial repeaters (Consent unauthorized construction and operation unauthor- Decree) of terrestrial repeaters in violation of ized repeat- Part 25 rules ers

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 11 2008 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Cardinal Broadband LLC 8/15/08 Providing incorrect material factual N/A N/A-VoIP service provider $25,000 Proposed forfeiture is less that the statutory $25,000 information to the Commission in maximum of $130,000 applicable to common response to an LOI carriers because there was no evidence of intentional misrepresentation and Cardinal subsequently provided correct information against its interest and prior to formal Com- mission action Invision Industries, Inc. 8/18/08 Importation and shipment of television 7 TV receivers $324,000 Forfeiture amount for non-compliant TVs $324,000 receivers that do not comply with DTV calculated using the tier-by-tier, per-unit reception capability rules; providing methodology set forth in the Syntax-Brillian incorrect material factual information and Regent NALs; $4,000 forfeiture imposed to the Commission in response to an LOI for supplying false information Data Capture Solutions, 8/25/08 Marketing noncompliant portable data Number of Portable data terminals $14,000 Proposed forfeiture includes a $3,000 $14,000 Inc. terminals modified by replacing the two noncompli- equipped with internal downward adjustment because marketing an mbps radio assembly with an 11 mbps ant models radio assemblies improperly labeled device is not as significant radio assembly without authorization marketed as marketing an unauthorized or technically from the manufacturer and affixing within non-compliant device labeling that did not include the FCC ID the SOL is unknown Leetek America, Inc. 8/25/08 Marketing unauthorized pager 2 Pager systems for $14,000 N/A $14,000 transmitter systems restaurants and hospitals Microboards Technology, 8/25/08 Marketing unauthorized and non- 2 CD and DVD duplicators $14,000 N/A $14,000 LLC compliant digital devices without the appropriate labels LCD Digital Electronics, 8/27/08 Displaying and offering for sale equip- 2 TV receivers $16,000 $8,000 base forfeiture for each $16,000 Inc. ment with an analog-only tuner without unlabeled model in violation of the required Consumer Alert label analog-only labeling requirements Hannspree North 8/28/08 Interstate shipment of television receiv- 249 units Televisions $12,450 Forfeiture assessed by using the tier-by-tier, $12,450 America, Inc. ers that do not comply with DTV recep- within the per-unit method set forth in other DTV tuner tion requirements statute of NALs limitations CoachComm, LLC 9/8/08 Marketing unauthorized radio frequency 1 Wireless intercom system $7,000 N/A $7,000 device Wavetrend Technologies, 9/11/08 Marketing devices without a means for Not Dis- RFID devices N/A N/A $28,000 Ltd. automatically limiting operation so that closed (Consent the silent period between transmissions Decree) may be no less than 10 seconds Sling Media, Inc. 9/12/08 Importation or interstate shipment of Not Dis- Televisions N/A N/A $42,500 video devices that receive over-the-air closed (Consent television signals without a DTV tuner Decree)

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 12 2008 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

TTE Technology, Inc. 9/12/08 Importation or interstate shipment of Not Dis- Televisions N/A N/A $12,500 video devices that receive over-the-air closed (Consent television signals without a DTV tuner Decree) ViewSonic Corporation 9/12/08 Importation or interstate shipment of Not Dis- Televisions N/A N/A $25,350 video devices that receive over-the-air closed (Consent television signals without a DTV tuner Decree) XLNT Idea, Inc. 11/4/08 Marketing unauthorized digital devices 2 Computer peripherals- $14,000 N/A $14,000 printers/publishers American Samoa Telecom- 11/5/08 Violating hearing aid compatibility sta- 0 of 2 Wireless handsets $6,000; Base forfeiture amount of $6,000 for failure $6,000 munications Authority tus report filing requirements; failing to required admonish- to file HAC reports; forfeiture for failing to offer at least two wireless handsets that models ment offer compliant handsets precluded by stat- meet HAC requirements for RF interfer- ute of limitations ence and inductive coupling Multi-Tech Systems, Inc. 12/10/08 Marketing an RF device without includ- 1 RF Transmitter $4,000 Proposed forfeiture includes a $3,000 down- $4,000 ing the required consumer disclosure in ward adjustment because marketing a device the user manual without the required consumer disclosure is not as significant a violation as marketing an unauthorized or technically non-compliant device Redflex Traffic Systems, 12/23/08 Marketing unauthorized RF devices 2 Radar speed meters N/A N/A $22,000 Inc. (Consent Decree)

Total 2008 $31,964,685

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 13 2009 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

AT&T Inc. 1/15/09 Violating terms of a DOJ order N/A N/A N/A N/A $2,380,000 (Consent Decree) Arkion Systems, LLC 1/15/09 Marketing uncertified devices 4 Utility meter transmitters N/A N/A $18,000 (Consent Decree) Silver Spring Networks 1/16/09 Marketing a device with an incorrect 1 Utility meter incorporating N/A N/A $4,000 (Consent exterior label a modular transmitter Decree) Proxim Wireless Corpora- 2/2/09 Marketing non-compliant and mislabeled 2 Wireless access points $14,000 $4,000 downward adjustment because mar- $11,000 tion devices keting an improperly labeled device deemed not as significant as marketing an unauthorized or technically non-compliant device

Pro Tech Monitoring, Inc. 2/9/09 Marketing unauthorized RF equipment 1 GPS tracking device N/A N/A $7,000 (Consent Decree) Audiovox Corporation 2/13/09 Marketing devices in violation of operat- Not Dis- Satellite radio receivers N/A N/A $5,000 (Consent ing bandwidth specifications and/or closed with wireless FM modula- Decree) radiated emission limits tors Humax Co., Ltd. 2/13/09 Importing and marketing devices in vio- Not Dis- Satellite radio receivers N/A N/A $15,000 lation of applicable technical standards closed with wireless FM modula- (Consent and labeling requirements tors Decree) Ki Ryung Electronics Co., 2/13/09 Importing and marketing devices in vio- Not Dis- Satellite radio receivers N/A N/A $30,000 Ltd. lation of applicable technical standards closed with wireless FM modula- (Consent and labeling requirements tors Decree) Wistron NeWeb Corpora- 2/13/09 Importing and marketing devices in vio- Not Dis- Satellite radio receivers N/A N/A $30,000 tion lation of applicable technical standards closed with wireless FM modula- (Consent and labeling requirements tors Decree) Power 7 Technology Cor- 2/19/09 Marketing unauthorized RF devices and 1 Automobile Full Channel $25,000 Proposed enforcement includes $18,000 $25,000 poration which exceeded Part 15 emissions limits FM Transmitter and iPOD upward adjustment in view of the number of Charger uncertified and non-compliant devices and 12-month period of violations PinPoint Wireless, Inc. 3/13/09 Failing to include in its digital wireless 0 of 2 Wireless handsets $30,000 $12,000 downward adjustment apparently $18,000 handset offerings at least two models required (6/13/2008 due to consent decree negotiations (Consent that comply with inductive coupling re- models NAL) Decree) quirements for hearing aid compatibility Hannspree North 3/26/09 Interstate shipment of television broad- 249 Televisions $12,450 Request for reduction in forfeiture amount $12,450 America, Inc. cast receivers noncompliant with the denied DTV reception capability rules

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 14 2009 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

N/A (Semiconductor 3/27/09 Undisclosed compliance issues with Parts Not Dis- Undisclosed equipment $25,000 N/A $25,000 manufacturer) 2, 15, and 68 closed including medical devices (Consent Decree) WorldNet, L.L.C. 4/3/09 Failure to respond to a LOI thereby N/A N/A $20,000 N/A $20,000 violating a Commission Order 1st United Tel-Com, Inc. 4/28/09 Failure to respond to an NAL thereby N/A N/A $4,000 N/A $4,000 violating an EB Directive Sennheiser Electronic 5/11/09 Marketing unauthorized RF devices 1 Wireless microphone $7,000 N/A $7,000 Corporation systems Panhandle Telecommuni- 5/13/09 Violating inductive coupling standards 0 of 2 Wireless handsets $9,000 N/A $9,000 cation Systems, Inc. for hearing aid compatibility required (Consent models Decree) Monster Cable Products, 5/15/09 Unspecified violations of Parts 2 and 15 Not dis- Wireless in-car FM trans- $12,500 N/A $12,500 Inc. concerning marketing of the Monster closed mitter (Consent iCarPlay Wireless device Decree) Orvac Electronics, Inc. 5/29/09 Marketing non-certified 2.4 GHz inten- 4 Wireless video transmitters $7,000 N/A—no clear explanation of why forfeiture $7,000 tional radiators and cameras imposed for only one model Mobilarm, Ltd. 6/12/09 Marketing uncertified RF devices 1 V100 transmitter $4,000 N/A $4,000 (Consent Decree) Honeywell International 6/15/09 Marketing uncertified RF devices and 1 Torque measurement device $10,000 N/A $10,000 Inc. violating field strength provisions (Consent Decree) Iftron Technologies, Inc. 6/29/09 Marketing an audio/visual transmit- 1 500 mW audio/video $5,600 Proposed enforcement amount includes $5,600 ter operating on a 2.4 GHz restricted transmitter $1,400 downward adjustment for good faith frequency not eligible for a grant of efforts to come into compliance prior to certification or marketing in the U.S. initiation of investigation Alco Electronics Ltd. 6/29/09 Marketing unauthorized RF devices and 2 DTV converter boxes N/A N/A $9,000 violations of labeling rules; test lab used (Consent by Alco may not have been accredited Decree) Alco Electronics Ltd. 7/10/09 Marketing authorized FM broadcast 4 RF transmitters and ampli- $22,000 Proposed forfeiture amount limited by 1-year $22,000 transmitters and external power amplifiers statute of limitations and reduction in base fiers forfeiture since the violation was deemed similar to marketing mislabeled equipment— a less serious offense

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 15 2009 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

CT Cube, Inc. d/b/a West 7/10/09 Failing to offer at least two digital wire- 0 of 2 re- Digital wireless handsets N/A N/A $14,000 Central Wireless less handset models with reduced emis- quired units (Consent sion levels by FCC deadline; inadequate at deadline; Decree) labeling and inserts re HAC compliance improper labeling on 3 of 4 units ultimately offered Technogym S.p.A. 7/10/09 Importation and interstate shipment of Not dis- TV broadcast receivers N/A N/A $30,000 broadcast TV receivers without digital closed incorporated in physical (Consent television reception capability fitness training equipment Decree) LawMate Technology Co., 7/15/09 Marketing unauthorized RF devices 2 Wireless video transmitters $14,000 N/A $14,000 Ltd. Pinnacle Systems, Inc. 7/30/09 Interstate shipment of PC digital Not dis- PC digital television tuners N/A N/A $25,000 television tuners in violation of V-Chip closed (Consent technology requirements Decree) Imation Corp. 10/16/09 Marketing unauthorized devices 1 or more DTV converter box and N/A N/A $7,000 (Consent other television interface Decree) devices Midland Radio Corpora- 10/16/09 Marketing transmitters with voice scram- 2 General Mobile Radio Ser- $21,000 Consent decree entered after issuance of $14,000 tion bling feature vice transmitters 6/25/2009 NAL reduced forfeiture by $7,000. (Consent Original proposed forfeiture included $7,000 Decree) upward adjustment for (1) substantial number of non-compliant devices; (2) violations continuing over a significant period; and (3) ability to pay Richfield Electronics 10/29/09 Marketing equipment noncompliant with 1 Whole House FM Transmit- $18,000 Proposed forfeiture includes $7,000 upward $18,000 (China) Ltd. emission limits and label requirements ter adjustment for the duration and extent of Richfield's emission limits violations and a $4,000 forfeiture for the labeling violation where the FCC said the marketing of non- labeled equipment is not as significant as marketing non-complaint equipment.

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 16 2009 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Uniden America Corpora- 11/5/09 Marketing transmitters with voice scram- 3 General Mobile Radio Ser- $23,000 Proposed enforcement includes upward $23,000 tion bling feature vice transmitters adjustment of $10,000 for continued marketing of products in violation after receiving guidance from FCC staff that voice scrambling is prohibited in the GMRS and downward adjustments of $5,000 and $3,000 citing Uniden’s record of overall compliance and corrective action taken before FCC notifica- tion of violations R.F. Technologies, Inc. 11/6/09 Marketing unauthorized RF device 1 Portable belt-pack trans- $7,000 N/A $7,000 ceiver connected to a headset Apple, Inc. 12/2/09 Violation of HAC status report filing 1 late-filed Reports for digital wireless $5,000 Proposed forfeiture includes $1,000 down- $5,000 requirements report handsets ward adjustment for Apple's demonstrated good faith effort and filing the report prior to FCC investigation XLNT Idea, Inc. 12/9/09 Marketing unauthorized digital devices 2 Printers and publishing $14,000 N/A $14,000 systems Total 2009 $2,861,550

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 17 2010 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Appalachian Wireless 1/14/10 Failing to timely file hearing aid compat- N/A Wireless services $5,000 Proposed forfeiture includes $1,000 down- $5,000 ibility status report ward adjustment for good faith attempt to file report on time Doro AB 1/14/10 Failing to file multiple hearing aid com- 2 omitted Wireless phones $12,000 N/A $12,000 patibility status reports reports ZTE Corporation 1/14/10 Failing to file multiple hearing aid com- 2 omitted Wireless phones $18,000 N/A $18,000 patibility status reports and violating reports web site posting requirements Airo Wireless, Inc. 1/14/10 Failing to file multiple hearing aid com- 2 omitted Wireless phones $12,000 N/A $12,000 patibility status reports reports Locus Telecommunica- 1/14/10 Failing to file hearing aid compatibility N/A Wireless services $12,000 N/A $12,000 tions, Inc. status report and violating web site posting requirements TCT Mobile, LTD. 1/14/10 Failing to file multiple hearing aid com- 2 omitted Wireless phones $16,000 Proposed forfeiture includes $4,000 penalty $16,000 patibility status reports and failing to reports for failing to respond to the FCC's LOI respond to an FCC LOI San Jose Technology, Inc. 2/16/10 Offering unauthorized devices for sale 4 GPS signal re-radiators $75,000 $25,000 downward adjustment pursuant $50,000 operating in restricted frequency bands to consent decree entered following 2007 (Consent forfeiture order; original forfeiture order Decree) included upward adjustments for (i) sale of devices operating in restricted frequency bands; (ii) potential interference with safety- of-life operations; (iii) distributing significant numbers of devices; and (iv) continuous nature of violations Enhanced Vision Systems, 4/7/10 Marketing class B digital devices in vio- Not dis- Vision assistance products N/A N/A $45,000 Inc. lation of FCC technical rules and labeling closed for the legally blind (Consent requirements Decree) Motorola, Inc. 4/14/10 Marketing Unlicensed National Informa- Not dis- U-NII devices N/A N/A $9,000 tion Infrastructure (U-NII) devices in closed (Consent violation of FCC technical rules and Decree) labeling requirements Airspan Networks (Is- 4/15/10 Marketing Unlicensed National Informa- Not dis- U-NII devices N/A N/A $10,000 rael), Ltd. tion Infrastructure (U-NII) devices in closed (Consent violation of FCC technical rules and Decree) labeling requirements

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 18 2010 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Phonejammer.com 4/20/10 Marketing RF devices designed to inter- 2 Phone jammers $25,000 Proposed forfeiture includes $11,000 upward $25,000 fere with licensed cellular and PCS adjustment for (i) disregarding previous cita- tion; (ii) intentional interference to licensed cellular and PCS frequencies, including those used for public safety; and (iii) marketing devices not capable of being authorized Entone, Inc. 5/14/10 Marketing class B digital devices in vio- Not dis- Television interface devices N/A N/A $35,000 lation of FCC technical rules and labeling closed (Consent requirements Decree) Fox Television Stations, 6/3/10 Failing to respond to an LOI and follow- N/A N/A $25,000 Proposed forfeiture includes $21,000 upward $25,000 Inc. up letter adjustment based on Fox's ability to pay and egregious conduct exhibiting contempt for Commission authority Paisa 2 Car and Limousine 6/18/10 Failing to respond to an NAL or pay the N/A N/A $4,000 N/A $4,000 Service., Inc. proposed forfeiture amount Cellphone-Mate 7/6/10 Marketing of radio frequency devices 1 Dual band cellular/PCS $4,000 Proposed enforcement amount includes $4,000 that are not correctly labeled signal amplifier $3,000 downward adjustment because this violation is not a technical requirement Wireless Extenders, Inc. 7/6/10 Marketing of radio frequency devices 1 Dual band cellular/PCS $4,000 Proposed enforcement amount includes $4,000 that are not correctly labeled signal booster $3,000 downward adjustment because this violation is not a technical requirement Futurewei Technologies, 7/12/10 Failing to comply with hearing aid com- Not dis- Wireless handsets N/A N/A $9,000 Inc. d/b/a Huawei Tech- patibility regulations closed (Consent nologies Decree) Qomo HiteVision, LLC 7/20/10 Marketing of unauthorized radio fre- Not dis- Radio frequency response N/A N/A $12,000 quency devices closed system (Consent Decree) Kannad SAS 8/27/10 Marketing radio frequency devices that Not dis- Emergency locator trans- N/A N/A $7,200 are not correctly labeled closed mitters (Consent Decree) Oklahoma Independent 8/30/10 Failing to offer at least 50% of handset N/A Digital wireless handsets $15,000 N/A $15,000 RSA 5 Partnership models with an M3 rating for RF interference to meet hearing aid compatibility obligations TX-10 Licensee, LLC dba 8/30/10 Failing to offer at least 50% of handset N/A Digital wireless handsets $15,000 N/A $15,000 Cellular One models with an M3 rating for RF interference to meet hearing aid compatibility obligations

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 19 2010 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

OK-5 Licensee Co., LLC 8/30/10 Failing to offer at least 50% of handset N/A Digital wireless handsets $15,000 N/A $15,000 models with an M3 rating for RF interference to meet hearing aid compatibility obligations Callaway Golf Company 10/5/10 Marketing of devices that had not been 2 Hand-held range finding N/A N/A $10,000 properly tested and a battery charger on devices (Consent one model did not meet field strength Decree) limits VisionTek Products, LLC 10/14/10 Failing to comply with V-Chip technology 1 Digital television tuners N/A N/A $15,000 requirements (Consent Decree) Cbeyond Communications, 10/26/10 Failing to file hearing aid compatibility N/A Wireless phones $12,000 N/A $12,000 LLC status report and violating web site posting requirements IDT Telecom, Inc. 10/26/10 Failing to file hearing aid compatibility N/A Wireless phones $12,000 N/A $12,000 status report and violating web site posting requirements MGA Entertainment, Inc. 10/26/10 Failing to file hearing aid compatibility N/A Wireless phones $6,000 N/A $6,000 status report Total Call Mobile, Inc. 10/26/10 Failing to file hearing aid compatibility N/A Wireless phones $12,000 N/A $12,000 status report and violating web site posting requirements Lightyear Network Solu- 11/22/10 Failing to file hearing aid compatibility N/A Wireless phones $12,000 N/A $12,000 tions, LLC. status report and violating web site posting requirements East Buchanan Telephone 12/1/10 Failing to offer the required number of N/A Wireless phones $45,000 N/A $45,000 Cooperative digital wireless handsets that meet hearing aid compatibility standards RF Linx Corporation 12/8/10 Marketing unauthorized and non-com- N/A Radio frequency power $7,500 N/A $7,500 pliant external radio frequency power amplifiers (Consent amplifiers Decree) Maximum Communica- 12/27/10 Failing to offer the required number of N/A Wireless phones $7,500 N/A $7,500 tions Cellular, LLC digital wireless handsets that meet hear- (Consent ing aid compatibility standards Decree) Indigo Wireless, Inc. 12/30/10 Failing to offer the required number of N/A Wireless phones $39,000 N/A—Proposed forfeiture amount includes $39,000 digital wireless handsets that meet hear- $9,000 upward adjustment for extended ing aid compatibility standards period of non-compliance

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 20 2010 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

STi Prepaid, LLC 12/30/10 Failing to offer the required number of N/A Wireless phones $34,500 N/A—Proposed forfeiture amount includes $34,500 digital wireless handsets that meet hear- $7,500 upward adjustment for extended ing aid compatibility standards , failing period of non-compliance to file hearing aid compatibility status report and failing to meet web site posting requirements Epic Touch Co., Inc. 12/30/10 Failing to offer the required number of N/A Wireless phones $19,500 N/A—Proposed forfeiture amount includes $19,500 digital wireless handsets that meet hear- $4,500 upward adjustment for extended ing aid compatibility standards period of non-compliance Sandhill Communications 12/30/10 Failing to offer the required number of N/A Wireless phones $15,000 N/A $15,000 digital wireless handsets that meet hearing aid compatibility standards Champaign Telephone 12/30/10 Failing to file hearing aid compatibility N/A Wireless phones $6,000 N/A $6,000 Company d/b/a CT Com- status report munications, Inc. Total 2010 $612,200

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 21 2011 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

ACS Wireless, Inc. 1/19/11 Failing to file hearing aid compatibility N/A Wireless phones and $12,000 Downward adjustment of $3,500 from initial $8,500 status report and violating web site services FCC proposal in January 2010 (Consent posting requirements Decree) Cricket Communications, 2/1/11 Providing false information to the FCC N/A Microwave radio services $20,000 N/A $20,000 Inc. Shenzhen Tangreat Tech- 2/9/11 Marketing frequency jamming equipment 1 Wireless jamming device $112,500 FCC order for administrative hearing to deter- N/A nology Co., Ltd. and marketing an RF device different mine revocation of equipment authorization than was approved under FCC authoriza- and forfeiture amount up to $112,500 tion Utah Broadband 2/11/11 Operating intentional radiators in viola- 2 Unlicensed UNII transmis- $25,000 Proposed forfeiture includes $10,000 upward $25,000 tion of Part 15 rules and the devices' sion systems adjustment; FCC did not calculate the for- equipment authorization feiture on a per-device basis because of the particulars of this case AT&T, Inc. 2/17/11 Operating intentional radiators in viola- 1 Unlicensed UNII transmis- $25,000 Proposed forfeiture includes $10,000 upward $25,000 tion of Part 15 rules and the devices' sion system adjustment equipment authorization Pantech Wireless, Inc. 2/17/11 Noncompliance with digital wireless N/A Wireless phones $50,000 N/A $50,000 handset deployment requirements and (Consent failing to file hearing aid compatibility Decree) status report and violations of web site posting requirements PreSonus Audio Electron- 4/28/11 Marketing unauthorized devices N/A Class B digital audio RF $125,000 N/A $125,000 ics, Inc. devices (Consent Decree) Luxul Wireless, Inc. 5/20/11 Marketing unauthorized and non-compli- N/A External RF power ampli- $18,200 N/A $18,200 ant devices fiers (Consent Decree) SmartLabs, Inc. 6/1/11 Marketing unauthorized RF device 1 Wireless Remote Control $10,000 Proposed forfeiture includes $3,000 upward $10,000 adjustment based on the nature and duration of the violation Cincinnati Bell Wireless 6/9/11 Failing to offer handsets adequate to N/A Wireless phones $30,000 N/A $30,000 LLC meet hearing aid compatibility inductive (Consent coupling requirements Decree) ReconRobotics, Inc. 7/13/11 Marketing an RF device without an 1 Remote-controlled surveil- $17,500 N/A $17,500 equipment certification lance robot (Consent Decree)

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 22 2011 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Rapidwave, LLC 7/28/11 Operating intentional radiator in viola- 1 U-NII transmission system $25,000 Proposed forfeiture includes $5,000 for $25,000 tion of Part 15 rules and the device's operating unauthorized equipment, $10,000 equipment authorization, without a for operating without and instrument of license authorization, and a $10,000 upward adjustment for public safety risks associated with the device's interference with an FAA radar system Ayustar Corporation 7/29/11 Operating intentional radiator in viola- 1 U-NII transmission system $25,000 Proposed forfeiture includes $5,000 for $25,000 tion of Part 15 rules and the device's operating unauthorized equipment, $10,000 equipment authorization, without a for operating without and instrument of license authorization, and a $10,000 upward adjustment for public safety risks associated with the device's interference with an FAA radar system Sling Broadband, LLC 7/29/2011 Operating intentional radiator in 1 U-NII transmission system $20,000 Proposed forfeiture includes $10,000 for op- $20,000 (NAL); violation of Part 15 rules and without a erating without and instrument of authoriza- 9/19/2011 license tion and $10,000 upward adjustment for pub- (forfeiture lic safety risks associated with the device's order) interference with an FAA radar system. Marshall Amplification 8/30/11 Marketing Class B digital audio RF device 1 Digital audio music devices $7,200 Proposed forfeiture includes FCC’s consider- $7,200 PLC without mandatory disclosures in the ation and dismissal of a $3,000 downward user manual adjustment it has applied in similar cases of authorized devices marketed without required consumer disclosures in favor of a $7,200 forfeiture. The FCC stated that consistent with the Forfeiture Policy State- ment, large or highly profitable entities, such as Marshall, should expect forfeitures higher than those reflected in the base amounts. Kaplan Telephone Com- 9/28/11 Failing to offer required number of digi- 1 missing Wireless phones $19,500 Proposed forfeiture includes $4,500 upward $19,500 pany, Inc. d/b/a Pace tal wireless handsets that meet hearing adjustment for continuing nature of violation Communications aid compatibility standards over 7 month period Hauppauge Computer 10/14/11 Sale of television receivers without DTV 7 Analog-only televisions $175,000 $175,000 forfeiture proposed in 4/15/2009 $55,000 Works, Inc. reception capability NAL (Consent Decree) Keystone Wireless, LLC 10/28/11 Failing to offer required number of digi- 5 missing Wireless phones $100,000 Proposed forfeiture includes $25,000 upward $100,000 d.b.a. Immix tal wireless handsets that meet hearing adjustment for continuing nature of violation aid compatibility standards over 11 months Missouri RSA 5 Partner- 10/28/11 Failing to offer required number of digi- 4 missing Wireless phones $82,500 Proposed forfeiture includes $22,500 upward $82,500 ship d/b/a Chariton Valley tal wireless handsets that meet hearing adjustment for continuing nature of violation Wireless Services aid compatibility standards over 10 months

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 23 2011 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

OTZ Telecommunications, 11/9/11 Failing to offer required number of digi- Unknown Wireless phones $13,000 N/A $13,000 Inc. tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) Custom Interface Tech- 11/17/11 Manufacturing and marketing unauthor- 2 models Video assist transmitters $14,000 N/A $14,000 nologies ized radio frequency devices Net One International 12/9/11 Violating an Enforcement Bureau order N/A N/A $25,000 Proposed forfeiture includes $21,000 upward $25,000 to produce information and documents adjustment for conduct deemed egregious, in response to a Letter of Inquiry intentional, and continuous Sprocket Wireless, L.L.C. 12/14/11 Failing to offer required number of digi- Unknown Wireless phones $50,000 N/A $50,000 tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) Affordable Phone Ser- 12/23/11 Failing to offer required number of digi- 2 missing Wireless phones $30,000 N/A $30,000 vices, Inc. tal wireless handsets that meet hearing aid compatibility standards Airfire Wireless 12/23/11 Failing to offer required number of digi- 2 missing Wireless phones $30,000 N/A $30,000 tal wireless handsets that meet hearing aid compatibility standards Caprock Cellular Limited 12/23/11 Failing to offer required number of digi- 1 missing Wireless phones $15,000 N/A $15,000 Partnership tal wireless handsets that meet hearing aid compatibility standards i wireless 12/23/11 Failing to offer required number of digi- 2 missing Wireless phones $39,000 Proposed forfeiture includes $9,000 upward $39,000 tal wireless handsets that meet hearing adjustment for the duration of the viola- aid compatibility standards tion and potentially significant impact on consumers with hearing loss Big Sky Mobile 12/23/11 Failing to offer required number of digi- 1 missing Wireless phones $21,000 Proposed forfeiture includes $7,000 upward $21,000 tal wireless handsets that meet hearing adjustment for the duration of the violation aid compatibility standards General Communication, 12/28/11 Failing to offer required number of digi- 2 missing Wireless phones $51,000 Proposed forfeiture includes $21,000 upward $51,000 Inc. tal wireless handsets that meet hearing adjustment for the duration of the violation, aid compatibility standards GCI's ability to pay the proposed forfeiture, and the potentially significant impact on consumers with hearing loss Maximum Communica- 12/28/11 Failing to offer required number of digi- 2 missing Wireless phones $30,000 N/A $30,000 tions Cellular, LLC tal wireless handsets that meet hearing aid compatibility standards NEP Cellcorp, Inc. 12/28/11 Failing to offer required number of digi- 1 missing Wireless phones $25,500 Proposed forfeiture includes $10,500 upward $25,500 tal wireless handsets that meet hearing adjustment for the duration of the violation aid compatibility standards and history of non-compliance

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 24 2011 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Centennial Communica- 12/29/11 Failing to offer required number of digi- 2 missing Wireless phones $75,000 Proposed forfeiture includes $45,000 upward $75,000 tions Corporation tal wireless handsets that meet hearing adjustment for CCC's status as a Tier II aid compatibility standards carrier, ability to pay, history of noncompliance, and potentially significant impact on consumers with hearing loss Locus Telecommunica- 12/29/11 Failing to offer required number of digi- 1 missing Wireless phones $25,500 Proposed forfeiture includes $10,500 upward $25,500 tions, Inc. tal wireless handsets that meet hearing adjustment for the duration of the violation, aid compatibility standards Locus’s ability to pay, and the potentially significant impact on consumers with hearing loss MetTel 12/29/11 Failing to offer required number of digi- 2 missing Wireless phones $48,000 Proposed forfeiture includes $18,000 upward $48,000 tal wireless handsets that meet hearing adjustment for the duration of the violation, aid compatibility standards MetTel’s ability to pay, and the potentially significant impact on consumers with hearing loss Total 2011 $1,155,400

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 25 2012 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Hawking Technologies, 1/13/12 Marketing RF devices in a manner 1 External RF Power ampli- $50,000 Consent decree agreement entered after $50,000 Inc. inconsistent with Hawking's equipment fiers seeking reconsideration of initial $50,000 (Consent authorization and FCC rules forfeiture with a $43,000 upward adjustment Decree) for (i) the substantial number of amplifiers sold; (ii) continuous violations over 12-months, and (iii) previous forfeiture for violating the same rule LDC Telecommunications, 1/18/12 Failing to respond to an Enforcement N/A N/A $25,000 N/A $25,000 Inc. Bureau letter of inquiry US Jetting, Inc. 1/20/12 Marketing unauthorized RF devices 1 Wireless handheld remote $8,400 Proposed forfeiture includes $1,400 upward $8,400 controller for high-pressure adjustment for the duration of the violation water jetting equipment Epic Touch Company, Inc. 2/27/12 Failing to offer required number of digi- 2 missing Wireless phones $30,000 In 2008, the FCC issued a Notice of Apparent $22,500 tal wireless handsets that meet hearing Liability to Epic Touch for $30,000 aid compatibility standards American Music and 3/2/12 Marketing of unauthorized Class A digital Unknown Digital multitrack record- $72,000 N/A $72,000 Sound audio radio frequency devices ers, live recording mixers, (Consent and stereo rack monitors Decree) Insight Consulting Group 3/23/12 Operating unlicensed intentional radia- 2 Unlicensed U-NII transmis- $17,000 Previously proposed forfeiture of $17,000 $16,000 of Kansas City, LLC tors and not in accordance with Part 15 sion system is reduced by $1,000 based on Insight's in- rules ability to pay VPNet, Inc. 3/23/12 Operating unlicensed intentional radia- 1 Unlicensed U-NII transmis- $15,000 Proposed forfeiture includes a $5,000 upward $15,000 tors and not in accordance with Part 15 sion system adjustment for additional violation of FCC rules rules for use of an unauthorized antenna N/A - Internet Search 4/13/12 Failing to respond to an Enforcement N/A N/A $25,000 Proposed forfeiture includes a $21,000 $25,000 Provider Bureau letter of inquiry and related FCC upward adjustment for deliberate failure to requests for documents and information cooperate with FCC inquiries and ability to pay T-Mobile USA, Inc. 4/13/12 Failing to offer required number of digi- Up to 4 Wireless phones $819,000 Proposed forfeiture amount based on $819,000 tal wireless handsets that meet hearing missing per-month calculation of shortages plus aid compatibility standards during a $39,000 upward adjustment based on T- various Mobile's ability to pay reporting periods The Antique Radio Col- 4/13/12 Marketing unauthorized RF devices 1 AM radio transmitter kit $7,000 Consent decree agreement entered after $130 lector assemblies seeking reconsideration of initial $7,000 (Consent forfeiture based on inability to pay Decree) ETI Sound Systems, Inc. 5/11/12 Marketing unauthorized RF devices non- Unknown Guitar amplifiers, CD/MP3 $34,000 N/A $34,000 compliant with FCC technical standards players, and active speaker systems

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 26 2012 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Ztar Mobile, Inc. 5/11/12 Failing to offer required number of digi- Unknown Wireless phones $33,600 N/A--Additional matters included in the $33,600 tal wireless handsets that meet hearing consent decree include CPNI violations aid compatibility standards Vision Latina Broadcast- 6/14/12 Knowingly making false statements to N/A N/A $25,000 N/A $25,000 ing, Inc. the FCC A Radio Company, Inc. 6/15/12 Failing to comply with the terms of an N/A N/A $25,000 N/A--FCC rejected A Radio, Inc.'s claims $25,000 FCC order and consent decree that it lacks the ability to pay the proposed $25,000 forfeiture Corr Wireless Communica- 7/6/12 Failing to offer required number of digi- 2 missing Wireless phones $30,000 Downward adjustment of $10,000 based on $20,000 tions, LLC tal wireless handsets that meet hearing Corr's atypical size for a Tier III carrier aid compatibility standards Elgato Systems LLC 7/13/12 Improper labeling of RF device 1 Broadcast television $2,800 N/A $2,800 receiver (Consent Decree) The Chamberlain Group, 7/31/12 Marketing unauthorized RF devices 4 Wireless portable intercoms $35,000 N/A $35,000 Inc. Wireless indoor/outdoor (Consent intercoms, Wireless front Decree) doorbell & intercom, Wire- less driveway alert Fender Musical Instru- 8/13/12 Marketing non-compliant and unauthor- Unknown Bass amplifiers, Pre-ampli- $265,000 N/A $265,000 ments Corporation ized digital RF devices and improper fiers, Tuners, Audio mixers, (Consent filing of Customs declaration forms Wireless microphones, Decree) Accessories Smith Bagley, Inc./Cel- 8/14/12 Failing to offer required number of digi- Unknown Wireless Phones $65,000 N/A $65,000 lular One tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) Silicondust USA, Inc. 8/20/12 Improper labeling of RF device 1 Broadcast television $2,800 N/A $2,800 receiver (Consent Decree) HTC America, Inc. HTC 9/19/12 Failing to offer required number of digi- Unknown Wireless Phones $515,000 N/A $515,000 Corporation" tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) AT&T, Inc. 9/27/12 Operation of interference-causing U-NII 1 U-NII equipment $25,000 Proposed forfeiture amount includes $10,000 $25,000 equipment in violation of FCC rules upward adjustment based on AT&T's ability to pay Skybeam Acquisition 9/27/12 Operation of U-NII equipment without a 1 U-NII equipment $15,000 N/A $15,000 Corporation license and in violation of FCC rules

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 27 2012 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

TelAlaska Cellular, Inc. 10/12/12 Failing to offer required number of digi- Unknown Wireless Phones $55,000 N/A $55,000 tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) American Samoa Telecom- 10/19/12 Failure to comply with hearing aid 7 missing Wireless Phones $6,000 Affirmation of prior proposed forfeiture; $6,000 munications Authority compatibility status report filing require- reports arguments to reduce the proposed $6,000 ments forfeiture amount were rejected by the FCC Leetek America, Inc. 11/2/12 Marketing unauthorized pager transmit- 1 Pager transmitter system $14,000 Affirmation of prior forfeiture decision $7,000 ter system where Leetek successfully argued that only 1 unauthorized transmitter model was offered for sale Inter Tech FM 12/4/12 Marketing unauthorized FM broadcast 1 FM broadcast transmitters $18,000 Affirmation of prior proposed forfeiture of $18,000 transmitter $7,000 for marketing violation and $11,000 for false representations LawMate Technology Co., 12/6/12 Marketing uncertified RF devices 4 Wireless video transmitters $14,000 Affirmation of prior proposed forfeiture; $14,000 Ltd. arguments to reduce the proposed $14,000 forfeiture amount were rejected by the FCC LOUD Technologies, Inc. 12/13/12 Marketing mislabeled and unauthorized Unknown Powered loudspeakers, $85,000 N/A $85,000 digital RF devices Non-powered mixers, Com- (Consent pact mixers, Active speaker Decree) systems Total 2012 $2,301,230

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 28 2013 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Directlink, LLC 1/3/13 Operating U-NII device not in accor- 1 U-NII device $15,000 Adjusted upward by $10,000 because opera- $25,000 dance with its equipment authorization tion posed public safety risks or Part 15 Inter Tech FM 1/16/13 Marketing without authorization Unknown FM broadcast transmitters $22,000 N/A $22,000

External RF power amplifiers Technical Communication 2/7/13 Failing to produce information and docu- N/A N/A $4,000 Adjusted upward because misconduct of $25,000 Network, LLC ments in response to LOI ignoring FCC was egregious, intentional and continuous Argos Net, Inc. 2/12/13 Operating unlicensed intentional radia- 2 Unlicensed U-NII transmis- $25,000 Proposed forfeiture includes a $5,000 upward $20,000 tors and not in accordance with Part 15 sion system adjustment for ignoring previous FCC warn- rules ings; subsequently reduced by $5,000 for prior history of compliance Kustom Musical Amplifi- 3/18/13 Marketing and importing digital RF Unknown Guitar amplifiers, Speaker $14,500 N/A $14,500 cation, Inc. d/b/a Hanser devices systems, Microphones, (Consent Music Group Footswitches Decree) N/A - Wireless Service 4/9/13 Failing to offer required number of digi- Unknown Wireless handsets $65,000 N/A $65,000 Provider tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) New Sensor Corporation 4/22/13 Marketing and importing digital RF Unknown Bass amplifiers, Pre-ampli- $450,000 N/A $450,000 d/b/a Electro Harmonix devices fiers, Bass pedals, Digital (Consent delay and loop carriers, Decree) Vocal processors Kyocera Communications, 5/1/13 Failing to timely file hearing aid compat- 1 missing Wireless handsets $12,000 Proposed forfeiture is adjusted upward from $12,000 Inc. ibility status report $6,000 because Kyocera has high revenues and ability to pay Pulse Mobile, LLC & Tele- 6/21/13 Failing to offer required number of digi- Unknown Wireless handsets $280,000 N/A $280,000 Guam Holdings, LLC tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) Aradigm Communications, 6/21/13 Failing to offer required number of digi- Unknown Wireless handsets $260,000 N/A $260,000 Inc. dba Airfire Mobile tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) Towerstream Corporation 8/6/13 Operating U-NII devices in a manner 7 U-NII devices/broadband $192,000 Upward adjustment due to causing interfer- $202,000 inconsistent with Part 15 wireless transceiver ence with public safety (TDWR systems) Puerto Rico Telephone 8/14/13 Failing to offer required number of digi- Unknown Wireless handsets $162,500 N/A $162,500 Company, Inc. d/b/a Claro tal wireless handsets that meet hearing (Consent aid compatibility standards Decree)

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 29 2013 Contact us: [email protected] or [email protected] Company Date Violation Number Type of device Proposed Adjustments Enforcement of Models Forfeiture Amount

Digital Antenna, Inc. 8/30/13 Failing to respond to FCC letter of inquiry Unknown Cellular boosters/repeaters $5,000 N/A $5,000 regarding marketing of cellular boosters/ (Consent repeaters Decree) Cordova Wireless Com- 9/13/13 Failing to offer required number of digi- Unknown Wireless handsets $35,000 N/A $35,000 munications, LLC tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) Northeast Telephone 9/24/13 Failing to timely file hearing aid compat- Unknown Wireless handsets $6,000 $6,000 base is adjusted downward for prompt $5,400 Services, Inc. ibility status report voluntary disclosure N/A - Wireless Service 9/25/13 Failing to offer required number of digi- Unknown Wireless handsets $100,000 N/A $100,000 Provider tal wireless handsets that meet hearing (Consent aid compatibility standards Decree) Gallien Technology, Inc. 11/14/13 Marketing digital radio frequency Unknown Digital devices such as bass $18,500 N/A $18,500 d/b/a Gallien-Krueger devices in violation of technical and amplifiers (Consent labeling requirements Decree) Ayustar Corporation 11/18/13 Operating U-NII device without required Unknown U-NII devices $6,000 N/A $6,000 DFS radar detection (Consent Decree) VPNet, Inc. 11/21/13 Operating U-NII device in a manner Unknown U-NII device $9,000 N/A $9,000 inconsistent with Part 15 and the equip- (Consent ment authorization Decree) Rane Corporation 12/23/13 Marketing of digital radio frequency Unknown Digital devices such as $61,500 N/A $61,500 devices, including failure to label and amplifiers, compressors, (Consent include consumer disclosure statements equalizers and mixers Decree) in user manuals Total 2013 $1,778,400

© Copyright 2014 Fish & Richardson P.C. These materials may be considered advertising for legal services under the laws and rules of professional conduct of the jurisdictions in which we practice. The material contained in this document has been gathered by the lawyers at Fish & Richardson P.C. for informational purposes only and is not intended to be legal advice. Transmission is not intended to create and receipt does not establish an attorney-client relationship. Legal advice of any nature should be sought from legal counsel. For more information about Fish & Richardson P.C. and our Fish practices, please visit www.fr.com. 30 Contact Us Fish & Richardson Communications and Spectrum Regulation Group

Terry G. Mahn Principal

Washington, DC

202-626-6421

[email protected]

Donna A. Balaguer, CIPP/US Principal

Washington, DC

202-783-5070

[email protected]

TRENDS in FCC ENFORCEMENT | Equipment Manufacturer Violations 2006­-2013

TRENDS in FCC ENFORCEMENT | Equipment Manufacturer Violations 2006-2013