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   October 13, 2006




   Kachun Wong

   LightObject d/b/a Actionbuy Trading Co.

   3069 Freeport Blvd.

   Sacramento, California 95818

   Re: File No. EB-05-SE-294

   Dear Mr. Wong:

   This is an official CITATION, issued pursuant to Section 503(b)(5) of the
   Communications Act of 1934, as amended ("Communications Act"), 47 U.S.C. S
   503(b)(5), for marketing in the United States certain wireless cameras,
   specifically, 10 Watt 1.2 GHz Wireless Camera Video AV Transmitter
   Receivers ("1.2 GHz wireless cameras"), that are not eligible to receive a
   grant of equipment certification, in violation of Section 302(b) of the
   Communications Act, 47 U.S.C. S 302a(b), and Sections 2.803 and 15.205(a)
   of the Commission's Rules ("Rules"), 47 C.F.R. SS 2.803 and 15.205(a). As
   explained below, future violations of the Commission's rules in this
   regard may subject your company to monetary forfeitures.

   On August 30, 2005, the Spectrum Enforcement Division ("Division") of the
   Enforcement Bureau received a complaint alleging that LightObject d/b/a
   Actionbuy Trading Co. ("LightObject") was marketing on eBay wireless
   cameras that operate in the .96 - 1.215 GHz band, a restricted frequency
   band under Section 15.205(a) of the Rules that is allocated for
   aeronautical navigation use.

   On September 1, 2005 and March 17, 2006, Division staff visited the
   internet store for LightObject products, [1]
   ("LightObject online store"). The LightObject online store listed the 1.2
   GHz wireless camera for sale with a pre-order link to purchase the device.
   Additionally, the staff visited LightObject's eBay store, "CoolEyesStore,"
   and observed that the wireless camera was offered for sale with an option
   to "Buy It Now." Further, the item description for the wireless camera
   indicated that it transmits on frequency 1.2 GHz.

   On March 20, 2006, the Division issued a letter of inquiry ("LOI") to
   LightObject requesting information as to whether LightObject was marketing
   the 1.2 GHz wireless camera in the United States.

   In its response to the Division's LOI, LightObject admitted that it
   markets the 1.2 GHz wireless camera but indicated that it does not
   manufacture the device. Rather, LightObject identified Shenzhen Germany
   Electronic Limited ("Shenzhen"), a company located in China, as the
   manufacturer. LightObject further stated that it began importing the
   wireless camera on December 29, 2004 and sold 20 units, but discontinued
   importing the device on January 21, 2005. Additionally, LightObject
   explained that the wireless camera was only marketed on eBay and listed on
   the LightObject online store, which it stated has been closed. LightObject
   also stated that it is not sure whether the wireless camera has received a
   grant of equipment certification and is unfamiliar with FCC regulations.
   Finally, LightObject stated that it currently does not market the wireless
   camera for sale in the United States and ceased to exist as a business
   entity in 2005.

   Subsequently, on August 23, 2006, the Division staff observed that
   LightObject's online store was still active. The staff found, however,
   that the links previously directing customers to the 1.2 GHz wireless
   camera had been removed. The staff also visited LightObject's active eBay
   store and did not find the 1.2 GHz wireless camera advertised for sale

   Section 302(b) of the Act provides that "[n]o person shall manufacture,
   import, sell, offer for sale, or ship devices or home electronic equipment
   and systems, or use devices, which fail to comply with regulations
   promulgated to this section." Section 2.803(a)(1) of the Commission's
   implementing regulations provides that:

   no person shall sell or lease, or offer for sale or lease (including
   advertising for sale or lease), or import, ship, or distribute for the
   purpose of selling or leasing or offering for sale or lease, any radio
   frequency device unless . . . [i]n the case of a device subject to
   certification, such device has been authorized by the Commission in
   accordance with the rules in this chapter and is properly identified and
   labeled as required by S 2.925 and other relevant sections in this

   Additionally, Section 2.803(g) of the Rules provides that:

   Devices that could not be operated or legally authorized under the current
   rules . . . shall not be operated, advertised, displayed, offered for sale
   or lease, sold or leased, or otherwise marketed absent a license issued
   under part 5 of the Chapter or a special temporary authorization issued by
   the Commission.

   Pursuant to Section 15.201(b) of the Rules, 47 C.F.R. S 15.201(b),
   intentional radiators must be authorized in accordance with the FCC's
   certification procedures prior to the initiation of marketing in the
   United States. However, the 1.2 GHz wireless camera operates within the
   restricted frequency bands listed in Section 15.205(a) of the Rules. Thus,
   the wireless camera cannot comply with the FCC's technical standards and
   therefore cannot be certificated or marketed. Accordingly, it appears that
   LightObject has violated Section 302(b) of the Act and Sections 2.803 and
   15.205(a) of the Rules by marketing in the United States radio frequency
   devices that are not eligible to receive a grant of certification.

   If, after receipt of this citation, LightObject violates the
   Communications Act or the Commission's rules in any manner described
   herein, the Commission may impose monetary forfeitures not to exceed
   $11,000 for each such violation or each day of a continuing violation.

   If you choose to do so, you may respond to this citation within 30 days
   from the date of this letter either through (1) a personal interview at
   the Commission's Field Office nearest to your place of business, or (2) a
   written statement. Your response should specify the actions that
   LightObject is taking to ensure that it does not violate the Commission's
   rules governing the marketing of radio frequency devices in the future.

   The nearest Commission field office is the San Francisco Office in San
   Francisco, CA. Please call Neal McNeil at 202-418-2408 if you wish to
   schedule a personal interview. You should schedule any interview to take
   place within 30 days of the date of this letter. You should send any
   written statement within 30 days of the date of this letter to:

   Kathryn S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   Federal Communications Commission

   445-12^th Street, S.W., Rm. 3-C366

   Washington, D.C. 20554

   Under the Privacy Act of 1974, 5 U.S.C. S 552(a)(e)(3), we are informing
   you that the Commission's staff will use all relevant material information
   before it, including information that you disclose in your interview or
   written statement, to determine what, if any, enforcement action is
   required to ensure your compliance with the Communications Act and the
   Commission's rules.

   The knowing and willful making of any false statement, or the concealment
   of any material fact, in reply to this citation is punishable by fine or
   imprisonment under 18 U.S.C. S 1001.

   Thank you in advance for your anticipated cooperation.


   Kathryn S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   Federal Communications Commission

   See Letter from Kathryn Berthot, Deputy Chief, Spectrum Enforcement
   Division, Enforcement Bureau, Federal Communications Commission, to
   LightObject d/b/a Actionbuy Trading Co. (March 20, 2006).

   See Letter from Kachun Wong to Neal McNeil, Spectrum Enforcement Division,
   Enforcement Bureau (April 24, 2006).

   Section 15.205(a) allows intentional radiators to transmit only spurious
   emissions in the restricted frequency bands. 47 C.F.R. S 2.1 defines
   spurious emissions as "[e]missions on a frequency or frequencies which are
   outside the necessary bandwidth and the level of which may be reduced
   without affecting the corresponding transmission of information. Spurious
   emissions include harmonic emissions, parasitic emissions, intermodulation
   products and frequency conversion products, but exclude out-of-band
   emissions." The 1.2 GHz wireless camera purposely transmits RF energy on
   restricted frequencies.

   See 47 C.F.R. S 1.80(b)(3).

   Federal Communications Commission DA 06-2019


   Federal Communications Commission DA 06-2019


                            WASHINGTON, D.C.  20554


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