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                                 April 19, 2007

   VIA CERTIFIED MAIL

   RETURN RECEIPT REQUESTED

   AND FACSIMILE AT 612-486-1398

   Chumbo Corporation

   221 North First Street

   Minneapolis, Minnesota 55401

   Re: File No. EB-07-SE-077

   Dear Sir or Madam:

   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 a police radar jamming device manufactured
   by Rocky Mountain Radar ("RMR"), specifically, the RMR-C450 device, in
   violation of Section 302(b) of the Act, 47 U.S.C. S 302a(b), and Sections
   2.803, 15.205 and 15.209 of the Commission's Rules ("Rules"), 47 C.F.R. SS
   2.803, 15.205 and 15.209. As explained below, future violations of the
   Commission's rules in this regard may subject your company to monetary
   forfeitures.

   On February 22, 2007, the Spectrum Enforcement Division ("Division") of
   the Enforcement Bureau received a complaint alleging that Chumbo.com is
   marketing the RMR-S201 and the RMR-C450 devices. On April 2, 2007, the
   Division staff visited Chumbo.com's internet web site at [1]www.Chumbo.com
   and observed that Chumbo.com is marketing the RMR-C450 device. The
   Division staff observed that Chumbo.com was not marketing the RMR-S201
   device at that time. The Division staff also observed that Chumbo
   Corporation is doing business as Chumbo.com.

   On January 31, 2007, the Division issued a Notice of Apparent Liability
   for Forfeiture ("NAL")  proposing a $25,000 forfeiture against RMR for
   marketing the RMR-C450 device in apparent willful and repeated violation
   of Section 302(b) of the Act and Sections 2.803, 15.205 and 15.209 of the
   Rules. In the NAL, we noted that the Commission's Office of Engineering
   and Technology ("OET") Laboratory had obtained a sample of the RMR-C450
   device directly from RMR for testing. Testing of the sample indicated that
   the unit is designed to emit a signal that intentionally interferes with a
   licensed radio service (police radar), and is indeed capable of
   interfering with police radar. Therefore, the OET Laboratory concluded
   that the device is an intentional radiator, as described in Section
   15.3(o) of the Rules, 47 C.F.R. S 15.3(o). In addition, the OET
   Laboratory's tests indicated that the RMR-C450 device produced a radiated
   emission at 11.23 GHz, a restricted frequency band listed in Section
   15.205 of the Rules, 47 C.F.R. S 15.205, and that this radiated emission
   substantially exceeds the radiated emission limits for intentional
   radiators specified in Section 15.209 of the Rules, 47 C.F.R. S 15.209.
   The OET Laboratory also concluded that the RMR-C450 device was improperly
   certified. In this regard, the OET Laboratory noted that the grant of
   certification issued for the RMR-C450 device indicates that the device was
   tested as an "unintentional radiator." As explained above, however, the
   OET Laboratory found that the device is an intentional radiator.

   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 Rules,
   47 C.F.R. S 2.803(a)(1), 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
   chapter.

   Pursuant to Section 15.201 of the Rules, 47 C.F.R. S 15.201, intentional
   radiators must ordinarily be authorized in accordance with the
   certification procedure prior to marketing. Section 2.803(g) of the Rules,
   47 C.F.R. S 2.803(g), however, 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.

   Further, Section 333 of the Act, 47 U.S.C. S 333, prohibits any person
   from willfully or maliciously interfering with or causing interference to
   any radio communications of any station licensed or authorized by the
   Commission. Moreover, Section 15.205 of the Rules, 47 C.F.R. S 15.205,
   prohibits radiated emissions, other than spurious emissions, in any of the
   restricted frequency bands listed in that section. Thus, intentional
   radiators that cannot legally be operated - because, for example, they
   interfere with or jam licensed police radio facilities or operate in
   restricted frequency bands - are not eligible for a grant of equipment
   certification. Finally, Section 15.209 of the Rules sets forth the
   radiated emission limits applicable to intentional radiators.

   As noted above, contrary to the claims of RMR, the RMR-C450 device is an
   intentional radiator. The device is not, however, eligible for a grant of
   certification because the device's intended purpose is to interfere with
   Commission authorized radio facilities, specifically, licensed police
   radar, in violation of Section 333 of the Act, and the OET Laboratory has
   determined that the device in fact is capable of interfering with police
   radar. Moreover, there are two additional grounds for finding the
   marketing of the RMR-C450 device to be unlawful. The RMR-C450 device is
   not eligible for a grant of certification because it produces a radiated
   emission in the restricted frequency band at 11.23 GHz in violation of
   Section 15.205 of the Rules. This radiated emission also substantially
   exceeds the radiated emission limits for intentional radiators specified
   in Section 15.209 of the Rules.

   The record before us indicates that Chumbo.com apparently is and has been
   marketing the RMR-C450 device. Accordingly, it appears that Chumbo.com has
   violated Section 302(b) of the Act and Section 2.803 of the Rules by
   marketing the RMR-C450 device, which is not eligible for a grant of
   equipment certification because the device is intended to interfere with
   licensed police radar, in violation of Section 333 of the Act. Chumbo.com
   has also apparently violated Section 302(b) of the Act and Sections 2.803,
   15.205 and 15.209 of the Rules by marketing the RMR-C450 device, which is
   not eligible for a grant of equipment certification because it produces a
   radiated emission in the restricted frequency band at 11.23 GHz, and which
   produces emissions that substantially exceed the radiated emission limits
   for intentional radiators.

   If, after receipt of this citation, Chumbo.com  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
   Chumbo.com is taking to ensure that it does not violate the Commission's
   rules governing the marketing of intentional radiating jamming devices in
   the future.

   The nearest Commission field office is the St. Paul District Office in St.
   Paul, Minnesota.   Please call Peter Waltonen at 202-418-0097 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.

   Sincerely,

   Kathryn S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   The NAL  also  included the RMR-S201 device which is not relevant to this
   Citation.

   Rocky Mountain Radar, Notice of Apparent Liability for Forfeiture, 22 FCC
   Rcd 1334 (Enf. Bur., Spectrum Enf. Div., 2007) ("RMR").

   Id. at 1335.

   Id.

   Id. An intentional radiator is defined by Section 15.3(o) of the Rules, 47
   C.F.R. S 15.3(o), as "[a] device that intentionally generates and emits
   radio frequency energy by radiation or induction."

   RMR, 22 FCC Rcd at 1335.

   Id. RMR obtained certification for the RMR-C450 under FCC ID No. QKK-C03
   by representing to a Telecommunications Certification Body that the device
   was a radar detector. We note, however, that RMR marketed the device as a
   radar detector and a radar "scrambler."

   RMR, 22 FCC Rcd at 1335. An "unintentional radiator" is defined by Section
   15.3(z) of the Rules, 47 C.F.R. S 15.3(z), as:

   [a] device that intentionally generates radio frequency energy for use
   within the device, or that sends radio frequency signals by conduction to
   associated equipment via connecting wiring, but which is not intended to
   emit RF energy by radiation or induction.

   Section 2.1(c) of the Rules, 47 C.F.R. S 2.1(c), defines a spurious
   emission as "[e]mission 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."

   RMR, 22 FCC Rcd at 1337-8.

   Id. at 1338.

   Id.

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

   Federal Communications Commission DA 07-1754

   2

   Federal Communications Commission DA 07-1754

                       FEDERAL COMMUNICATIONS COMMISSION

                            WASHINGTON, D.C.  20554

References

   Visible links
   1. http://www.chumbo.com/