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'[EE]: Kits?'
2001\07\03@111652 by Sean Breheny

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Hi all,

I am now quite a bit of the way through the tutorial on wireless comms
for microcontrollers (which was discussed here back in March).  I was
planning on making the tutorial itself freely available on the web and
then sell kits for the major design examples.

I have been doing some research of FCC rules and I noticed that they make
a rather sharp distinction between purely home-build devices and kits.
Home-built devices do not need any kind of certification, provided that
you only build 5 of them and use good engineering practice to try to meet
the specs.

It appears, though, that if I were to sell kits, I would have to apply
for FCC certification for an intentional radiator (for the transmitters,
anyway) and possibly regular certification for any of the devices which
use frequencies higerh than 1.7MHz. Is this correct? I have bought quite
a few kits during my time as an electronic experimenter, and I never
remember any FCC data on them (even for transmittes). Is this rule
generally not enforced and ignored, or am I interpreting it correctly? If
it is ture, can I get around it by just selling a PCB and offering a
selection of parts which would just happen to allow you to build the
devices on the site? While I am putting a lot of effort into this and I
think the result will be very useful to people, I am working on a rather low
budget and I don't think I could afford to make all th measurements
needed for the certification process.

Thanks in advance for any advice,

Sean

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2001\07\03@113242 by J.Feldhaar

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Hi Sean,

I only can cover Europe in this statement, but I think it is certainly easier
for you to manufacture some kits for the ISM band (as a ham you may weep now,
for these are most certainly inside or next to HAM bands, e. g. 433MHz). These
kits may fall under a kind of "general license if by design you do not exceed
some limits for TX power or antenna gain - antenna directivity is also an issue.

So using 433, 886 or 2400 MHz will perhaps give you an easier life in the US of
A also.
One comment on your project: I think you are doing a great work, even I am going
to wait for the possibility to download the complete file. Lots of people will
profit from this work. I am also a HAM and my work is primarily RF circuitry,
and currently I am working on a compley book on most aspects of spectrum
analysis, covering schematics, methods, applications and theory. Benn writing
for 4 years now, phew.

So the best of luck for this project!

Greets (73)
Jochen Feldhaar DH6FAZ

Sean Breheny schrieb:

{Quote hidden}

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2001\07\03@143914 by dpharr53

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Sean:

Go to http://www.linxtechnologies.com/f_applic.html #00140 -- The FCC Road:
Part 15 from concept to approval, Adobe Acrobat PDF (35K).  This document
provides all the information on what is required for FCC certification of
license-free wireless devices.  I believe they will even perform the
necessary testing for certification if you're willing to pay the cost.

Good luck.

Dennis

{Original Message removed}

2001\07\03@203539 by Scott Stephens

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>It appears, though, that if I were to sell kits, I would have to apply
>for FCC certification for an intentional radiator (for the transmitters,
>anyway) and possibly regular certification for any of the devices which
>use frequencies higerh than 1.7MHz. Is this correct?

From my reading of part 15 and/or 97,  yes, unless it is test equipment, or
a prototype - but you can't sell prototypes. You can't even peddle a damn
PIC
product that clocks over a few KHz! :-(

> I have bought quite
>a few kits during my time as an electronic experimenter, and I never
>remember any FCC data on them (even for transmittes). Is this rule
>generally not enforced and ignored, or am I interpreting it correctly?

I believe it is not enforced, proceed at your peril! The FCC surely has lots
of better things to
do. Unless you make so much money you compete with a company that will
contribute to a politician that can sick their dogs on you - like if Linx
gets mad and complains about.

If they never hear of your gadgets, how can they persecute you? Now if you
made 50 or 5 KW amplifiers for CB radios or cellular phone jammer kits they
would probably find out. The FCC is suppose to promote such things as
amature radio and advancing the art, which your product and literature does.
Which would
make you in compliance with the spirit of the law if not the letter.


>it is ture, can I get around it by just selling a PCB and offering a
>selection of parts which would just happen to allow you to build the
>devices on the site?

Only the top preditors in the food chain get away with with dissembling over
the meaning of the word 'is',
coaching witnesses and suborning perjury ("I was never alone with her Betty,
right? I never had the door shut Betty, right?). As Orwell said, "some
animals are more equal than others". You might want to find out who to make
a campaign contribution to in case you have any problems. Maybe an indirect
offer, something like "I'll be able to contribute regularly to your campaign
fund, as long as I'm capable of operating profitably, unharrassed by the
FCC". Most savy politicians probably wouldn't accept a direct quid-pro-quo
(but their
brothers might!). Its much easier for them to break the implicit 'deal' if
they can deny there ever was one!


>I don't think I could afford to make all th measurements
>needed for the certification process.

The FCC busted a bug peddler a while back for selling kits, IIRC. I remember
it was discussed. There were plenty of others to go after, and the bug
wasn't a sophisticated spread spectrum or matched filter device either. I
wonder what a laywer would have to say about selective enforcement of laws?
Once again, the system gets paid either way when you pay the lawyers.

Scott


****************************************************************
Freedom is pursuing your carrot, not running from a stick.
The mob only rules what its members are allowed to achieve.

How is it the cellular phone spectrum is divided so both service
providers have and equal hardware burden, yet the banking
monopolies can freely share your private credit card purchase
records with their subsidiaries for 'marketing' purposes?
I guess the banks and their oligarchs know how to bribe politicians
better than the cellular industry!
Quo Bono - Who Profits!
****************************************************************

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2001\07\03@211027 by Alexandre Domingos F. Souza

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>It appears, though, that if I were to sell kits, I would have to apply
>for FCC certification for an intentional radiator (for the transmitters,
>anyway) and possibly regular certification for any of the devices which
>use frequencies higerh than 1.7MHz. Is this correct? I have bought quite

       In Brazil you can sell anything that goes below 100mw and no certification is needed. If I'm not mistaken, FCC does the same


---8<---Corte aqui---8<----

Alexandre Souza
spam_OUTtaitoTakeThisOuTspamterra.com.br
http://planeta.terra.com.br/lazer/pinball/

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2001\07\03@211819 by David VanHorn

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At 10:10 PM 7/3/01 -0300, Alexandre Domingos F. Souza wrote:
> >It appears, though, that if I were to sell kits, I would have to apply
> >for FCC certification for an intentional radiator (for the transmitters,
> >anyway) and possibly regular certification for any of the devices which
> >use frequencies higerh than 1.7MHz. Is this correct? I have bought quite
>
>         In Brazil you can sell anything that goes below 100mw and no
> certification is needed. If I'm not mistaken, FCC does the same

This is NOT true of the US.  You have to part 15 cert, and there is another
section for intentional radiators.

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2001\07\03@212631 by Randy Glenn

picon face
I don't think it was the FCC... it might have been customs or the IRS,
shutting them down for designing products intended for "surrepitous use" or
something... I am, of course, referring to the Ramsey Electronics fiasco.

-Randy Glenn

Sure, Windows is stable. As stable as the install CD,
balanced on the edge of a ruler. In high winds.
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{Original Message removed}

2001\07\03@213036 by Alexandre Domingos F. Souza

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>I don't think it was the FCC... it might have been customs or the IRS,
>shutting them down for designing products intended for "surrepitous use" or
>something... I am, of course, referring to the Ramsey Electronics fiasco.

       What happened to Ramsey?


---8<---Corte aqui---8<----

Alexandre Souza
.....taitoKILLspamspam.....terra.com.br
http://planeta.terra.com.br/lazer/pinball/

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2001\07\03@215140 by Dan Michaels

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Alexandre Souza wrote:
>>I don't think it was the FCC... it might have been customs or the IRS,
>>shutting them down for designing products intended for "surrepitous use" or
>>something... I am, of course, referring to the Ramsey Electronics fiasco.
>
>        What happened to Ramsey?
>

This "exact" issue was discussed on piclist a few months ago.
You might search the archives because, as I recall, the resolution
of the situation was given there.

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2001\07\04@002655 by David VanHorn

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At 10:31 PM 7/3/01 -0300, Alexandre Domingos F. Souza wrote:
> >I don't think it was the FCC... it might have been customs or the IRS,
> >shutting them down for designing products intended for "surrepitous use" or
> >something... I am, of course, referring to the Ramsey Electronics fiasco.
>
>         What happened to Ramsey?

It was the FCC.
They were selling bugging devices in kit form.
Granted they were the world's crappiest bugs, but that's what they were.
The FCC stepped in and said "no more".

They are doing enforcement these days.

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2001\07\04@014939 by Randy Glenn

picon face
No, it wasn't the FCC. It was the customs service:

http://slashdot.org/articles/00/01/04/2316228.shtml

-Randy Glenn

Sure, Windows is stable. As stable as the install CD,
balanced on the edge of a ruler. In high winds.
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{Original Message removed}

2001\07\04@053552 by Roman Black

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David VanHorn wrote:
>
> At 10:31 PM 7/3/01 -0300, Alexandre Domingos F. Souza wrote:
> > >I don't think it was the FCC... it might have been customs or the IRS,
> > >shutting them down for designing products intended for "surrepitous use" or
> > >something... I am, of course, referring to the Ramsey Electronics fiasco.
> >
> >         What happened to Ramsey?
>
> It was the FCC.
> They were selling bugging devices in kit form.
> Granted they were the world's crappiest bugs, but that's what they were.
> The FCC stepped in and said "no more".
>
> They are doing enforcement these days.


Is that for real?? In the US i'm guessing.
Here in Aust all the electronics stores sell
fm bug kits, they are a very popular beginner
kit.
-Roman

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2001\07\04@074104 by michael brown

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> No, it wasn't the FCC. It was the customs service:
>
> http://slashdot.org/articles/00/01/04/2316228.shtml
>
> -Randy Glenn

So, is Ramsey out of business or just paying large fines?  About 9-10 years
ago, the customs people shut down a local business that sold bugging devices
and other assorted "security" devices such as voice scramblers, bug
detectors, etc...  They were charged with smuggling because they imported
much of this stuff.  They didn't do it in any kind of secret or covert
manner, they just ordered the stuff from Asia and in it came.  It really was
nothing but a trumped up charge, since hundreds of other companies were
importing the same stuff.  IIRC the devices were legal to possess at the
time, just not legal to import (smuggle).

Ironic isn't it, since the major cities are installing traffic light spy
cams all over the place.  The locals here have the EZ-tag system for toll
road payment without stopping.  It is a passive device that identifies you
when you pass thru the automatic toll gates.  All around town, the freeways
(non toll roads) have EZ-tag readers installed under the guise of traffic
flow analysis and management.  These devices measure the time it takes for
an EZ-tag to make it from one reader to the next, and then calculating
vehicle speed as well as tracking you around town.  So far they are not
using it to send tickets out, but how long will that last?

michael

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2001\07\04@101536 by Bob Ammerman

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> At 10:31 PM 7/3/01 -0300, Alexandre Domingos F. Souza wrote:
> > >I don't think it was the FCC... it might have been customs or the IRS,
> > >shutting them down for designing products intended for "surrepitous
use" or
> > >something... I am, of course, referring to the Ramsey Electronics
fiasco.
{Quote hidden}

I have bought some stuff from Ramsey, and their catalog has an explanation
from their side. The products that they were forced to stop selling were
kits (what self-respecting James Bond is going to build a bug from a kit!)
for small FM transmitters that transmit to an ordinary FM radio. Not
particularly small, not particularly low in power consumption. In other
words, from Ramsey's point of view: not bugs! They were mostly sold to
experimenters and teachers and electronics club moderators.

Bob Ammerman
RAm Systems
(contract development of high performance, high function, low-level
software)

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2001\07\04@103032 by Bob Ammerman
picon face
Here in New York (USA) there was a big stink about the state sending
speeding tickets to truckers based on the entry and exit times from a toll
road as logged by an EZ-Pass system.

btw: I have an EZ-Pass tag on my car... hm....

Bob Ammerman
RAm Systems
(contract development of high performance, high function, low-level
software)

{Original Message removed}

2001\07\04@104527 by Andy Jancura

picon face
Hi,

have one question. What would happen if they wrote in the manual something
like the big companies like TI have. I mean : if you use our components in
any critical aplication... Or other: This device are designed only for
experimental and laboratory use. In any other case, the end-user should
warranty all necessary law norms.

Cheers,

A.
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2001\07\04@123010 by David VanHorn

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>
> > They are doing enforcement these days.
>
>
>Is that for real?? In the US i'm guessing.
>Here in Aust all the electronics stores sell
>fm bug kits, they are a very popular beginner
>kit.
>-Roman

It's for real all right.

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2001\07\04@123627 by John Waters

picon face
Nowadays most of the microcontroller clocks will be higher than 10 MHz, it
will surely emit some r.f., but I found many of these microprocessor based
devices in the market are not having fcc approval (I didn't see the fcc logo
attached), does it mean they are exempted or they simply ignore fcc?


>From my reading of part 15 and/or 97,  yes, unless it is test equipment, or
>a prototype - but you can't sell prototypes. You can't even peddle a damn
>PIC
>product that clocks over a few KHz! :-(

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2001\07\04@124919 by David VanHorn

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At 12:36 PM 7/4/01 -0400, John Waters wrote:
>Nowadays most of the microcontroller clocks will be higher than 10 MHz, it
>will surely emit some r.f., but I found many of these microprocessor based
>devices in the market are not having fcc approval (I didn't see the fcc logo
>attached), does it mean they are exempted or they simply ignore fcc?

Sounds like a problem to me.

For kits, you can test a properly built kit, and there's a procedure where
you put language in the manual that says that when built as instructed, the
kit is expected to conform.

You can self-certify (declaration of conformity) but if there's a problem,
you'd really rather have results from an independent test lab in hand.

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2001\07\04@125126 by Robert A. LaBudde

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At 07:35 PM 7/4/01 +1000, Roman wrote:
{Quote hidden}

I believe the seizure was done by the FBI and the original stories quoted
the Terrorist Control Act as the authority.

There are two obvious explanations for the event:

1. Promoting the device as a "bug" in contravention of anti-tapping laws, or
2. Importing of circuits that violated custom rules.

Ramsey Electronics did not seem too adversely impacted by the event.

================================================================
Robert A. LaBudde, PhD, PAS, Dpl. ACAFS  e-mail: RemoveMEralEraseMEspamEraseMElcfltd.com
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2001\07\06@132418 by Harold M Hallikainen

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       Probably ignoring...  See
http://www.hallikainen.com/cgi-bin/section.pl?section=15.103 for exempted
devices. See http://www.hallikainen.com/cgi-bin/section.pl?section=15 for
all of part 15.

Harold


On Wed, 4 Jul 2001 12:36:27 -0400 John Waters
<RemoveMEjohn_fm_watersTakeThisOuTspamspamHOTMAIL.COM> writes:
> Nowadays most of the microcontroller clocks will be higher than 10
> MHz, it
> will surely emit some r.f., but I found many of these microprocessor
> based
> devices in the market are not having fcc approval (I didn't see the
> fcc logo
> attached), does it mean they are exempted or they simply ignore fcc?
>

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2001\07\06@132425 by Harold M Hallikainen

picon face
       Back in high school (a little over 30 years ago), we saw a movie in
math. It was an introduction to calculus that was based on a guy getting
a speeding ticket based on his time on and off a toll road. They had the
police guy explaining the "mean value theorem" to the motorist...

Harold


On Wed, 4 Jul 2001 10:27:18 -0400 Bob Ammerman <EraseMERAMMERMANspamspamspamBeGonePRODIGY.NET>
writes:
{Quote hidden}

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