Then by definition Orinoco cards (for example) are prohibited because
they use a standard connector.

...dtw


-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]] On Behalf Of Tim Pozar
Sent: Tuesday, November 26, 2002 7:42 AM
To: Enrique LaRoche
Cc: Dan Fitzpatrick; [EMAIL PROTECTED]
Subject: Re: [BAWUG] Rob should be getting a kickback...


On Mon, Nov 25, 2002 at 10:48:06PM -0800, Enrique LaRoche wrote:
> Illegal why?
> I didn't see any specs just anecdotal testimonials...
> No Gain specs etc..
> Is that why they are Illegal?

Glad you asked...

        15.203  Antenna requirement. - An intentional radiator shall
        be designed to ensure that no antenna other than that
        furnished by the responsible party shall be used with the
        device.  The use of a permanently attached antenna or of
        an antenna that uses a unique coupling to the intentional
        radiator shall be considered sufficient to comply with the
        provisions of this section.  The manufacturer may design
        the unit so that a broken antenna can be replaced by the
        user, but the use of a standard antenna jack or electrical
        connector is prohibited.
        [...]

        15.204  External radio frequency power amplifiers and antenna
        modifications.
        [...]
        (b)  A transmission system consisting of an intentional
        radiator, an external radio frequency power amplifier, and
        an antenna, may be authorized, marketed and used under this
        part.  However, when a transmission system is authorized
        as a system, it must always be marketed as a complete system
        and must always be used in the configuration in which it
        was authorized.  
        [...]
        (c)  Only the antenna with which an intentional radiator
        is authorized may be used with the intentional radiator.

In other words, APs, amplifiers and antennas cannot be mixed and
matched out side of the equipment they are certified with.  In the
Cantanna web site on the "How to Use It" page
(http://www.cantenna.com/howto.html) they have it shown plugged
into, what looks like, a Linksys BEFW11S4.  The antenna is not
certified to be used with any Linksys gear.  As far as I can tell,
it isn't even certified.

As the company is in San Diego and is marketing and selling it to
United States customers.

        15.1  Scope of this part.
        [...]
        (c)  Unless specifically exempted, the operation or marketing
        of an intentional or unintentional radiator that is not in
        compliance with the administrative and technical provisions
        in this part, including prior Commission authorization or
        verification, as appropriate, is prohibited under Section
        302 of the Communications Act of 1934, as amended, and
        Subpart I of Part 2 of this chapter.  The equipment
        authorization and verification procedures are detailed in
        Subpart J of Part 2 of this chapter.
        [...]

        Subpart C - Intentional Radiators
        15.201  Equipment authorization requirement. 
        [...]
        (b)  Except as otherwise exempted in paragraph (c) of this
        section and in 15.23 of this part, all intentional radiators
        operating under the provisions of this part shall be
        certificated by the Commission pursuant to the procedures
        in Subpart J of Part 2 of this chapter prior to marketing.

Now I have seen the argument that antennas alone are not "intentional
radiators".  Since under these rules (defined earlier) antennas are
seen as a part of a system that includes the transmitter, coax,
etc. they are considered part of an "intentional radiators".  As
such, the Cantenna folks are not in compliance with the FCC rules
as they are marketing and selling these antennas in the US without
certification.

This gets into why all the stink about this?  Folks need to be
warned that they are using equipment illegally as it is a liability
that they may not know they are carrying.  They may not know there
can be fines and/or confiscation of their equipment.

I fully understand why the FCC does this as they want a responsible,
knowledgeable party for the mis-operations of part 15 equipment.
Since the actual operator of the equipment is considered not
technically savvy and is not licensed, they need to regulate with
the manufacture.  I would love to see the FCC reconsider how they
treat part 15 devices and do away with the "system" concept.  They
really should just be certifying the antennas and transmitters
separately, much like they do for broadcast transmission systems,
so you can mix and match equipment.

Tim
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