Dear Treggers,

We are currently designing an Internet fax product that, amongst other
things (including a connection to the analog PSTN, subject to the usual
regulatory requirements, which are, in general, well known to us), needs to
connect to a standard group 3 facsimile machine to be located at up to a
specified distance -- several tens of metres -- from the product. The
product will supply DC loop voltage, detect the on-hook (idle) and off-hook
(active) states of the facsimile machine, interpret dialling signals from
the facsimile machine, deliver ringing signal to the facsimile machine, and
perform the ring trip function.

For economy's sake, the product is being designed to deliver a trapezoidal
ringing signal that meets BELLCORE standard TR909, which calls for a crest
factor (i.e., peak/RMS ratio) of between 1.2 and 1.6.

In order to enable versions of the same product to be sold outside the
United States, we are seeking information about the waveform of the ringing
signal that needs to be delivered in other countries, especially in Europe,
but also in Canada, Australia, and Pacific Rim countries. We are aware of
the fact that the frequency, amplitude and cadence of the signal may need
to be modified from one country to the next, in order to ensure that
subscribers' equipment will respond appropriately to ringing signals
generated by the product under design. For example, many fax machines in
Germany are designed to respond only to ringing signals that fall within a
specified frequency band. However, we are unclear about the regulatory
requirements that may govern the delivery of a ringing signal by a product
to subscribers' equipment that, from the functional standpoint, may be
limited to loop lengths of tens of metres, and in particular, whether and
to what degree, the signal may depart from the purely sinusoidal.

My questions are therefore as follows:

1. Which are the European national (German, British, French, etc.) or
international (ETSI) Standards that apply to the port connecting such a
product to subscribers' equipment (with a loop length limited to tens of
metres, if relevant)?

2. Is the trapezoidal waveform, as accepted by BELLCORE, also acceptable in
other countries, especially the European ones, either by default or by
being positively specified as acceptable for short loops? If not, how is
the required purity of the ringing waveform specified, and what are the
specified values?

3. Will the regulatory authorities place this product in the category of a
PBX because it has at least one port to the PSTN and at least one port to
subscribers' equipment, even though the product's function differs from a
PBX and is only expected to operate correctly when the wire loop connecting
it to the subscriber's device is limited to several tens of metres?

4. Which, if any, of the other functions mentioned (detect the facsimile
machine on-hook and off-hook states, interpret dialling signals, and ring
trip) in the context of the connection of the product to subscriber's
equipment, are subject to regulatory requirements for this type of
equipment, and where are the requirements to be found?

If any of you also have any cautionary tales, caveats, or other additional
advice about obtaining approval for this equipment category in Europe, and
elsewhere, we will be grateful for all information received.

As usual, I suggest that responses be posted on TREG, to the benefit of all
interested parties. However, if for any reason, some of you prefer to
provide the requested information without identifying yourselves to other
TREG members (and to the public at large, through the RCIC Web site, which
posts TREG correspondence), then I will be only too pleased to hear from
you personally.

I wish to take the opportunity to say how useful a channel TREG is for us,
and how happy we are to have this forum where we may provide and receive
regulatory information. I am unhappy about the recent posting of jokes,
which generally achieve the opposite effect from that intended, serving as
a bone of contention between members. I believe that I have already
suggested that no message ever be devoted solely to this subject, but that
humorous remarks be permitted within the context of a message whose stated
purpose (in the "subject line") lies within, or related to, TREG's domain.

In view of the current spate of messages on this subject, may I also
suggest to everyone that personal interests be maintained under a totally
different e-mail address from professional correspondence, preferably with
a separate mechanism for its retrieval and despatch, to minimise the
chances of unrelated and inappropriate mail leaking in embarrassing ways.
Of course this does not solve leaks of company confidential information,
which are not easily prevented, except perhaps by e-mail software designed
to separate the handling of specified "internal" addresses (i.e.,
confidants), and to warn the user when mail to one or more internal
addresses has also been addressed or forwarded to any address not in the
list of internal addresses. Does such mail software exist??

With sincere thanks in advance for your assistance, and best regards,

David Drori

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Novarex Enterprises Ltd.,
POB 2833, Jerusalem,
Israel 91028
Tel: +972 2 581 0995
Fax: +972 2 581 3750
Mobile: +972 5 067 8686
E-mail: [email protected]
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