----- Original Message ----- 
From: "Jack Unger" <[EMAIL PROTECTED]>
To: "WISPA General List" <[email protected]>
Sent: Wednesday, April 25, 2007 12:21 PM
Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s
Rules for unlicensed devices and,equipment approval


> Tim,
>
> I read the 2nd Report and Order and I don't see where it is saying that
> a certified mini PCI radio can be put into any "base" unit.
>

did you read?  Come on Jack... Here's paragraph three of the background
section:
============================================================
3. In recent years, manufacturers have developed Part 15 transmitter modules
(or “single”

modules) that can be incorporated into many different devices. These modules
generally consist of a

completely self-contained radio-frequency transmitter (transmission system)
missing only an input signal

source and a power source to make it functional. Once the modules are
authorized by the Commission

under its certification procedure, they may be incorporated into a number of
host devices such as personal

computers (PCs) or personal digital assistants (PDAs), which have been
separately authorized.2 The

completed product generally is not subject to requirements for further
certification by the Commission.

Therefore, modular transmitters save manufacturers the time and any related
expenses that would be

incurred if a new equipment authorization were needed for the same
transmitter when it is installed in a

new device.

_____________________


I dunno about you, but if that  does not address mini-pci modules on a
single board computer, I dunno what would.   That's about as clear and
specific as they could get!   They CLEARLY are talking about rf network
devices.

It takes no imagination whatsoever to very effectively create mini-pci cards
and certify them under these rules.   They even state that the 'enclosure'
no longer matters, nor does the device the "module" is connected to, unless
it can make the device operate out of bounds.    The software, if it uses
the drivers from the manufacturer, or elements of the manufacturer's
software, that are approved as far as SDR's go, for TPC and DFS,  then yes,
it obviously complies with this, because those are certified by the chipset
manufacturers.

And further, they went on to state that this can be applied to a wide array
of rf devices... and they address various types of modulation, frequencies,
blah blah.   We're talking part-15 based networking devices, they're talking
walkie talkies, they're talking about a huge array of devices.

I see it as sea change, and take that from the language they use.

The requirements are:  self contained shielding so it's not dependent on
enclosure for unintentional radiation control,  has its own power control,
can be certified separately from the rest of the device.   The worst that
can happen, is that we submit a mini-pci and antenna combination for
certification and it gets rejected, but it appears to me we CAN certify it.
As far as the "unique connector" rule, I don't know how this is interpreted,
but every laptop and mini-pci put in it now has the same connector.






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