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   September 21, 2007



   AND FACSIMILE   212-431-2622

   Reuben Weinstein, President

   387 Canal Street

   New York, New York 10013

   Re: File No. EB-07-SE-042

   Dear Mr. Weinstein:

   This is an official CITATION, issued to
   ("Surveillance-Video") 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 and wireless
   camera converters, specifically, 10 Watt, 1.2 GHz Cantek Wireless Camera
   and Camera Converter Transmitter Receivers ("1.2 GHz wireless camera
   transmitter receivers"), that are not eligible to receive a grant of
   equipment certification, in violation of Section 302(b) of the
   Communication Act, 47 U.S.C. S: 302a(b), and Sections 2.803 and 15.205(a)
   of the Commission's rules, 47 C.F.R. S:S: 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 February 6, 2007, staff in the Enforcement Bureau's Spectrum
   Enforcement Division ("Division") visited the internet store for
   Surveillance-Video products,
   ("Surveillance-Video online store"). The Surveillance-Video online store
   listed the 1.2 GHz wireless camera and camera converter for sale with
   pre-order links to purchase the devices. Further, the item descriptions
   for the wireless camera and camera converter indicated that they transmit
   on frequency

   1.2 GHz. The 0.960 - 1.215 GHz band is a restricted frequency band under
   Section 15.205(a) of the rules that is allocated for aeronautical
   navigation use.

   On March 13, 2007, the Division issued a letter of inquiry ("LOI") to
   Surveillance-Video requesting information as to whether Surveillance-Video
   was marketing the 1.2 GHz wireless camera transmitter receivers in the
   United States.

   In its response to the Division's LOI, Surveillance-Video admitted
   marketing the 1.2 GHz wireless camera transmitter receivers at its on-line
   store and through its mail-order catalog but indicated that it does not
   know the name or location of either the manufacture or the importer of the
   devices. Surveillance-Video stated that it began marketing the 1.2 GHz
   wireless camera to end users in the summer of 2005 and has sold 500 units.
   Further, Surveillance-Video explained that it did not know that the
   devices required FCC authorization. Finally, Surveillance-Video noted that
   it discontinued marketing and selling the 1.2 GHz wireless camera
   transmitter receivers through its on-line store and its mail-order catalog
   on March 13, 2007, upon receipt of the Division's inquiry.

   Subsequently, on July 11, 2007, the Division staff observed
   Surveillance-Video's on-line store and found that the links previously
   directing customers to the 1.2 GHz wireless camera transmitter receivers
   had been removed.

   Section 302(b) of the Communication's 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 rules 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 Commission's 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 Commission's rules, 47 C.F.R. S:
   15.201(b), intentional radiators, such as wireless cameras, 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 Commission's rules. Thus, the wireless camera
   cannot comply with the FCC's technical standards and therefore cannot be
   certificated or marketed. Accordingly, it appears that Surveillance-Video
   has violated Section 302(b) of the Communications Act and Sections 2.803
   and 15.205(a) of the Commission's rules by marketing in the United States
   radio frequency devices that are not eligible to receive a grant of

   If, after receipt of this citation, Surveillance-Video 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
   Surveillance-Video 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 New York Office in New York,
   NY. Please call Jacqueline  Johnson at 202-418-2871 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

   445-12th 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, Chief, Spectrum Enforcement Division,
   Enforcement Bureau, Federal Communications Commission, to (March 13, 2007).

   See Letter from Reuben Weinstein, President, to
   Jacqueline Johnson, Spectrum Enforcement Division, Enforcement Bureau
   (April 16, 2007).

   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 07-3974


   Federal Communications Commission DA 07-3974


                            WASHINGTON, D.C.  20554