Fellow List Peoples,

I have a product that takes in various signals and connects these to output
ports, something like an Ethernet switch (but does not meet the definitions
of the regulation for that). The product was not designed to monitor
"traffic" on any of the ports so it cannot know when the port/path is not
being used.

The product is configured and controlled only by an external controller.
When a path is not being used, the external controller sets the output
ports to null.

The controller is in constant communication with the product, much like a
ping on the network.

The product will go automatically into standby on power up if no controller
is connected.

The product is smart enough to know when all ports are set null and will go
into standby when it senses that.

The product will also go into standby if it loses communication with the
controller. But it cannot know if "traffic" is passing.

The key question here is, can we use the external controller to determine
when the product should go into standby? Is that a fair means to address
the "...must automatically go into a mode..." requirement? Does that meet
the requirements of the regulation?

What else am I not telling? Or I am missing?

I look forward to your comments on any side of the equation. And thank you
in advance to for them.

Best regards,
Scott

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