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                                January 28, 2008



   Ms. Murina C. Bollaro, President

   Mr. Rocco A. Bollaro, Jr., Secretary

   Garden State Investigations and Security

   2 Overlook Drive

   Jackson, New Jersey 08527-4849

   Re: File No. EB-07-SE-347

   Dear Ms. and Mr. Bollaro:

   This is an official CITATION, issued pursuant to Section 503(b)(5) of the
   Communications Act of 1934, as amended ("Act"), 47 U.S.C. S: 503(b)(5), to
   Garden State Investigations and Security ("Garden State") for marketing in
   the United States unauthorized radio frequency devices in violation of
   Section 302(b) of the 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. 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.

   By letter of inquiry dated October 2, 2007, the Spectrum Enforcement
   Division of the Commission's Enforcement Bureau ("Division") initiated an
   investigation into whether Garden State is marketing in the United States,
   an unauthorized radio frequency jamming or blocking device listed as the
   "GPS Blocker." The Division observed an advertisement for the GPS Blocker
   jammer device on Garden State's web site,, on September 25, 2007.

   In Garden State's October 9, 2007 response, you admit that you imported 15
   units of the GPS Blocker jammer device into the United States and began
   advertising this device on your web site,, in August 2007. You also admit to the
   sale of eight of the GPS Blocker jammer devices to clients within the
   United States. You state that upon receipt of the Division's October 2,
   2007 letter of inquiry, you ceased all advertisement of the GPS Blocker
   jammer device. You further state that you destroyed your remaining
   inventory of seven devices.

   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 pursuant 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, 47 C.F.R. S: 2.803(g),
   provides in pertinent part that:

   [R]adio frequency devices that could not be authorized or legally operated
   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 this 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
   Commission's certification procedures prior to the initiation of marketing
   in the U.S. It does not, however, appear that the above-cited jammer
   device is capable of receiving a grant of certification. In this regard,
   the main purpose of the jammer device is to block or interfere with radio
   communications. Such use is clearly prohibited by Section 333 of the Act,
   47 U.S.C. S: 333, which states that "[n]o person shall willfully or
   maliciously interfere with or cause interference to any radio
   communications of any station licensed or authorized by or under this Act
   or operated by the United States Government." Moreover, the GPS Blocker
   operates within restricted frequency bands listed in Section 15.205(a) of
   the Commission's rules. Thus, these devices cannot comply with the FCC's
   technical standards and therefore cannot be certified or marketed.
   Finally, you note that you received inquiries and had purchases from local
   law enforcement and federal law enforcement bureaus. While radio frequency
   devices intended for the federal government or agencies thereof are exempt
   from the Commission's rules, there is no similar exemption for sales to
   state and local law enforcement. Accordingly, it appears that Garden State
   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 for certification.

   If, after receipt of this citation, Garden State  Investigations and
   Security  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

   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 Garden
   State Investigations and Security is taking to ensure that it does not
   violate the Commission's rules governing the marketing of radio frequency
   jamming devices in the future.

   The nearest Commission field office is the Philadelphia, Pennsylvania
   office. 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

   Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
   Enforcement Bureau, to Garden State Investigations and Security (October
   2, 2007).

   Letter from Murina C. and Rocco A. Bollaro, Jr., Garden State
   Investigations and Security, to Jacqueline Johnson, Spectrum Enforcement
   Division, Enforcement Bureau (October 9, 2007).

   Section 15.3(o) of the Rules defines an "intentional radiator" as a
   "device that intentionally generates and emits radio frequency energy by
   radiation or induction." 47 C.F.R. S: 15.3(o).

   Section 2.803(e)(4) of the Rules defines "marketing" as the "sale or
   lease, or offering to sale or lease, including advertising for sale or
   lease, or importation, shipment or distribution for the purpose of selling
   or leasing or offering for sale or lease." 47 C.F.R. S: 2.803(e)(4).

   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 GPS Blocker (which operates in the 1450 MHz to 1600 MHz
   bands) intentionally transmits radio frequency energy on restricted

   See 47 U.S.C. S: 302(c); 47 C.F.R. S: 2.807(d).

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

   Federal Communications Commission DA  08-155


   Federal Communications Commission DA 08-155


                            WASHINGTON, D.C.  20554