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                               September 8, 2008


   AND FACSIMILE AT 302-361-2200

   MicroVideoX, LLC

   Attn: Greg Marston

   630 Maurine Lane

   Grand Junction, CO 81504

   Re: File No. EB-08-SE-034

   Dear Mr. Marston:

   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),
   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 Section
   2.803 of the Commission's Rules ("Rules"), 47 C.F.R. S: 2.803. As
   explained below, future violations of the Commission's rules in this
   regard may subject your company to monetary forfeitures.

   By letter of inquiry ("LOI") dated June 3, 2008, the Spectrum Enforcement
   Division of the Commission's Enforcement Bureau ("the Division") initiated
   an investigation into whether MicroVideoX, LLC, ("MicroVideoX") is
   marketing in the United States unauthorized radio frequency devices,
   specifically, the GPS Counter Track, and the GPS Counter Track Portable
   (also advertised as "GPS Counter Track handheld"). The Division observed
   advertisements for these two devices on your web site,, and by its associated eBay username "microvideox" on
   January 24, 2008. Both devices were described as being able to jam or
   block GPS signals. Additionally, on February 22, 2008, the Division
   observed a promotional digital video on the website by user
   "MicroVideoX" that demonstrated the GPS Counter Track blocking the GPS
   satellite signals from reaching a dashboard-mounted GPS navigation device.
   The video indicated that the GPS Counter Track is available at The Division also observed the video on July 11, 2008 on
   the website

   In your June 3, 2008 response to the LOI, you admit that MicroVideoX began
   marketing the GPS Counter Track and GPS Counter Track Handheld on August
   7, 2007. You state that you imported a total of 53 GPS Counter Track units
   and 24 GPS Counter Track Portable units, and sold approximately 48 of the
   devices. Your response also states that you continued marketing the
   devices on eBay and until about March 13, 2008. As noted
   above, however, the Division observed the promotional video still active
   at on July 11, 2008.

   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

   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 U.S.
   However, it does not appear that devices such as the GPS Counter Track,
   and the GPS Counter Track Portable, are capable of receiving a grant of
   certification. The devices operate in frequency bands used for GPS, which
   are within the restricted frequency bands listed in Section 15.205(a) of
   the Rules, 47 C.F.R. S: 15.205(a). Section 15.205(a) allows intentional
   radiators to transmit only spurious emissions in the restricted frequency
   bands. Moreover, the purpose of GPS jammers 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." Thus, a device such as a GPS
   jammer which operates in restricted frequency bands and intentionally
   interferes with radio communications is not eligible for certification.
   Accordingly, it appears that MicroVideoX has violated Section 302(b) of
   the Act and Section 2.803 of the Rules by marketing in the United States
   the GPS Counter Track and the GPS Counter Track Portable jammers.

   If, after receipt of this citation, MicroVideoX 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
   MicroVideoX is taking to ensure that it does not violate the Commission's
   rules governing the marketing of unauthorized devices in the future.

   The nearest Commission field office is the Denver Office in Lakewood,
   Colorado. Please call Gabriel Collazo at 202-418-1160 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

   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).

   47 C.F.R. S: 2.1 defines spurious emissions as "Emission 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."

   Furthermore, section 2.803(g) of the Rules provides that radio frequency
   devices that could not be authorized or legally operated under the 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." 47 C.F.R. S: 2.803(g).

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

   Federal Communications Commission DA 08-2051


   Federal Communications Commission DA 08-2051


                            WASHINGTON, D.C.  20554