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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                    )                           
                                                                
                                    )   File No. EB-08-SE-144   
     In the Matter of                                           
                                    )   Acct. No. 200832100082  
     Wavetrend Technologies, Ltd.                               
                                    )   FRN No. 0007642531      
                                                                
                                    )                           


                                     ORDER

   Adopted: September 9, 2008 Released: September 11, 2008

   By the Chief, Spectrum Enforcement Division, Enforcement Bureau:

    1. In this Order, we adopt the attached Consent Decree entered into
       between the Enforcement Bureau ("Bureau") and Wavetrend Technologies,
       Ltd. ("Wavetrend"). The Consent Decree terminates an investigation by
       the Bureau against Wavetrend for possible violation of Section 302(b)
       of the Communications Act of 1934, as amended ("Act"), and Section
       2.803(a)(1) of the Commission's Rules ("Rules") regarding the
       marketing of certain radio frequency identification devices.

    2. The Bureau and Wavetrend have negotiated the terms of the Consent
       Decree that resolve this matter. A copy of the Consent Decree is
       attached hereto and incorporated by reference.

    3. After reviewing the terms of the Consent Decree and evaluating the
       facts before us, we find that the public interest would be served by
       adopting the Consent Decree and terminating the investigation.

    4. In the absence of material new evidence relating to this matter, we
       conclude that our investigation raises no substantial or material
       questions of fact as to whether Wavetrend possesses the basic
       qualifications, including those related to character, to hold or
       obtain any Commission license or authorization.

    5. Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the
       Communications Act of 1934, as amended, and sections 0.111 and 0.311
       of the Commission's Rules, the Consent Decree attached to this Order
       IS ADOPTED.

    6. IT IS FURTHER ORDERED that the above-captioned investigation IS
       TERMINATED.

    7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
       shall be sent by first class mail and certified mail, return receipt
       requested, to Jeffrey L. Sheldon, Esq., Counsel for Wavetrend
       Technologies, Ltd., McDermott Will & Emery LLP, 600 Thirteenth Street,
       N.W., Washington, D.C. 20005-3096.

   FEDERAL COMMUNICATIONS COMMISSION

   Kathryn S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                      )                           
                                                                  
                                      )                           
                                          File No. EB-08-SE-144   
     In the Matter of                 )                           
                                          Acct. No. 200832100082  
     Wavetrend Technologies Limited   )                           
                                          FRN No. 0007642531      
                                      )                           
                                                                  
                                      )                           


                                 CONSENT DECREE

   The Enforcement Bureau ("Bureau") and Wavetrend Technologies Limited
   ("Wavetrend"), by their authorized representatives, hereby enter into this
   Consent Decree for the purpose of terminating the Bureau's investigation
   into whether Wavetrend violated section 302(b) of the Communications Act
   of 1934, as amended, and section 2.803(a)(1) of the Commission's Rules
   regarding the marketing of certain radio frequency identification ("RFID")
   devices.

   I. DEFINITIONS

    1. For the purposes of this Consent Decree, the following definitions
       shall apply:

    a. "Act" means the Communications Act of 1934, as amended, 47 U.S.C. S:
       151 et seq.

    b. "Adopting Order" means an Order of the Bureau adopting the terms of
       this Consent Decree without change, addition, deletion, or
       modification.

    c. "Bureau" means the Enforcement Bureau of the Federal Communications
       Commission.

    d. "Commission" and "FCC" mean the Federal Communications Commission and
       all of its bureaus and offices.

    e. "Effective Date" means the date on which the Bureau releases the
       Adopting Order.

    f. "Investigation" means the investigation initiated by the  Bureau
       regarding whether Wavetrend violated the requirements of section
       2.803(a)(1) of the Rules in connection with its marketing of certain
       RFID devices.

    g. "OET" means the FCC's Office of Engineering and Technology of the
       Commission.

    h. "Parties" means Wavetrend and the Bureau.

    i. "Rules" means the Commission's regulations found in Title 47 of the
       Code of Federal Regulations.

    j. "Wavetrend" means Wavetrend Technologies Limited, and its
       predecessors-in-interest and successors-in-interest.

   II. BACKGROUND

    2. Pursuant to section 302(b) of the Act and section 2.803(a)(1) of the
       Rules, radio frequency devices subject to certification may not be
       marketed unless authorized by the Commission in accordance with the
       applicable technical and administrative provisions of the Rules.
       Section 15.231(e) of the Rules requires that devices operating under
       the provisions of the section be provided with a means for
       automatically limiting operation so that the silent period between
       transmissions may be no less than 10 seconds in duration.

    3. On February 28, 2008, OET sent a letter to Wavetrend to inquire
       whether Wavetrend was marketing certain RFID devices that were
       previously certified for operation under section 15.231 of the Rules,
       and whether each device complied with the minimum silent period
       between transmissions as required by section 15.231(e) of the Rules.

    4. Wavetrend responded to the OET Letter on March 10, 2008.
       Representatives of Wavetrend met with staff of the Bureau and OET on
       March 19, 2008, to discuss the OET Letter and the Wavetrend response.
       On May 21, 2008, in response to an informal request by the Bureau,
       Wavetrend submitted additional information relating to the Bureau's
       investigation of this matter.

   III. TERMS OF AGREEMENT

    5. Adopting Order. The Parties agree that the provisions of this Consent
       Decree shall be subject to final approval by the Bureau by
       incorporation of such provisions by reference in the Adopting Order
       without change, addition, modification, or deletion.

    6. Jurisdiction. Wavetrend agrees that the Bureau has jurisdiction over
       it and the matters contained in this Consent Decree and has the
       authority to enter into and adopt this Consent Decree.

    7. Effective Date; Violations. The Parties agree that this Consent Decree
       shall become effective on the date on which the Bureau releases the
       Adopting Order. Upon release, the Adopting Order and this Consent
       Decree shall have the same force and effect as any other Order of the
       Bureau. Any violation of the Adopting Order or of the terms of this
       Consent Decree shall constitute a separate violation of a Bureau
       Order, entitling the Bureau to exercise any rights and remedies
       attendant to the enforcement of a Commission Order.

    8. Termination of Investigation. In express reliance on the covenants and
       representations in this Consent Decree and to avoid further
       expenditure of public resources, the Bureau agrees to terminate its
       investigation. In consideration for the termination of said
       investigation, Wavetrend agrees to the terms, conditions, and
       procedures contained herein. The Bureau further agrees that in the
       absence of new material evidence related to this matter, the Bureau
       will not use the facts developed in this investigation through the
       Effective Date of the Consent Decree, or the existence of this Consent
       Decree, to institute, on its own motion, any new proceeding, formal or
       informal, or take any action on its own motion against Wavetrend
       concerning the matters that were the subject of the investigation. The
       Bureau also agrees that it will not use the facts developed in this
       investigation through the Effective Date of this Consent Decree, or
       the existence of this Consent Decree, to institute on its own motion
       any proceeding, formal or informal, or take any action on its own
       motion against Wavetrend with respect to Wavetrend's basic
       qualifications to hold Commission licenses or authorizations.

    9. Compliance Plan. For purposes of settling the matters set forth
       herein, Wavetrend agrees to maintain a Compliance Plan related to
       future compliance with the Act, the Commission's Rules, and the
       Commission's Orders. The Plan will, at a minimum, include the
       following components:

    a. Software Development. Wavetrend agrees to develop new firmware for its
       RFID tags and new software and firmware for its RFID programmers
       intended for the U.S. market that will prevent its tags from being
       programmed for a repetition interval that does not comply with the
       Rules. Wavetrend will also revise its software licensing agreements
       for U.S. customers using such programmers to more clearly mandate that
       the programmers and software may not be used to configure devices
       outside of the Rules.

    b. Device Programmability. Wavetrend will offer each of its U.S.
       customers that previously purchased a programmer one of Wavetrend's
       new programmers in order to control tag programmability as specified
       in the Rules. Until the new software or modified programmers are
       available, Wavetrend will continue to program its customers' tags at
       no cost to ensure that its new tag orders comply with the Rules.

    c. Marketing. Wavetrend will revise its marketing materials in order to
       remove any confusion with regards to transmission rates and
       programmability of its tags.

    d. Compliance Officer. Wavetrend will place compliance with this Consent
       Decree under the direct supervision of Wavetrend's CEO, Mr. Saleem
       Miyan.

    e. Training. Wavetrend will retrain, and provide materials concerning
       Parts 2 and 15 of the FCC's Rules and the requirements of the Consent
       Decree to, all of its employees who are involved directly or
       indirectly in the design, development, testing, marketing, and
       distribution of radiofrequency products. Such training will address
       the equipment authorization requirements of the Act and the FCC's
       Commission's Rules applicable to RFID devices and accessories
       imported, marketed, and sold by Wavetrend in the United States.

    f. Compliance Reports. Wavetrend will file compliance reports with the
       Commission, ninety (90) days after the Effective Date, twelve (12)
       months after the Effective Date, and twenty-four (24) months after the
       Effective Date. Each report shall include a compliance certificate
       from the Compliance Officer asserting that the Compliance Officer has
       personal knowledge that Wavetrend has established operating procedures
       intended to ensure compliance with this Consent Decree, together with
       an accompanying statement explaining the basis for the Officer's
       compliance certification. All reports shall be submitted to Chief,
       Spectrum Enforcement Division, Enforcement Bureau, Federal
       Communications Commission, 445 12th Street, S.W. Washington, D.C.
       20554. All reports shall also be submitted electronically to Ricardo
       M. Durham at Ricardo.Durham@fcc.gov and Kevin M. Pittman at
       Kevin.Pittman@fcc.gov.

    g. Termination Date. Unless stated otherwise,  the requirements of this
       Consent Decree will expire twenty-four (24) months from the Effective
       Date.

   10. Voluntary Contribution. Wavetrend agrees that it will make a voluntary
       contribution to the United States Treasury in the amount of
       twenty-eight thousand dollars ($28,000). The payment will be made
       within thirty (30) days after the Effective Date of the Adopting
       Order. The payment must be made by check or similar instrument,
       payable to the order of the Federal Communications Commission. The
       payment must include the Account Number and FRN Number referenced in
       the caption to the Adopting Order. Payment by check or money order may
       be mailed to Federal Communications Commission, P.O. Box 979088, St.
       Louis, MO 63197-9000. Payment by overnight mail may be sent to U.S.
       Bank - Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza,
       St. Louis, MO 63101. Payment by wire transfer may be made to ABA
       Number 021030004, receiving bank TREAS/NYC, and account number
       27000001. For payment by credit card, an FCC Form 159 (Remittance
       Advice) must be submitted. When completing the FCC Form 159, enter the
       Account number in block number 23A (call sign/other ID), and enter the
       letters "FORF" in block number 24A (payment type code). Wavetrend will
       also send electronic notification on the date said payment is made to
       Ricardo M. Durham at Ricardo.Durham@fcc.gov and Kevin M. Pittman at
       Kevin.Pittman@fcc.gov.

   11. Waivers. Wavetrend waives any and all rights it may have to seek
       administrative or judicial reconsideration, review, appeal or stay, or
       to otherwise challenge or contest the validity of this Consent Decree
       and the Adopting Order, provided the Bureau issues an Adopting Order
       adopting the Consent Decree without change, addition, modification, or
       deletion. Wavetrend shall retain the right to challenge Commission
       interpretation of the Consent Decree or any terms contained herein. If
       either Party (or the United States on behalf of the Commission) brings
       a judicial action to enforce the terms of the Adopting Order, neither
       Wavetrend nor the Commission shall contest the validity of the Consent
       Decree or the Adopting Order, and Wavetrend shall waive any statutory
       right to a trial de novo. Wavetrend hereby agrees to waive any claims
       it may otherwise have under the Equal Access to Justice Act, 5 U.S.C.
       S: 504 and 47 C.F.R. S: 1.1501 et seq., relating to the matters
       addressed in this Consent Decree.

   12. Severability. The Parties agree that if any of the provisions of the
       Adopting Order or the Consent Decree shall be invalid or
       unenforceable, such invalidity or unenforceability shall not
       invalidate or render unenforceable the entire Adopting Order or
       Consent Decree, but rather the entire Adopting Order or Consent Decree
       shall be construed as if not containing the particular invalid or
       unenforceable provision or provisions, and the rights and obligations
       of the Parties shall be construed and enforced accordingly. In the
       event that this Consent Decree in its entirety is rendered invalid by
       any court of competent jurisdiction, it shall become null and void and
       may not be used in any manner in any legal proceeding.

   13. Subsequent Rule or Order. The Parties agree that if any provision of
       the Consent Decree conflicts with any subsequent rule or Order adopted
       by the Commission (except an Order specifically intended to revise the
       terms of this Consent Decree to which Wavetrend does not expressly
       consent) that provision will be superseded by such Commission rule or
       Order.

   14. Successors and Assigns. Wavetrend agrees that the provisions of this
       Consent Decree shall be binding on its successors, assigns, and
       transferees.

   15. Final Settlement. The Parties agree and acknowledge that this Consent
       Decree shall constitute a final settlement between the Parties. The
       Parties further agree that this Consent Decree does not constitute
       either an adjudication on the merits or a factual or legal finding or
       determination regarding any compliance or noncompliance with the
       requirements of the Act or the Commission's Rules and Orders.

   16. Modifications. This Consent Decree cannot be modified without the
       advance written consent of both Parties.

   17. Paragraph Headings. The headings of the Paragraphs in this Consent
       Decree are inserted for convenience only and are not intended to
       affect the meaning or interpretation of this Consent Decree.

   18. Authorized Representative. Each party represents and warrants to the
       other that it has full power and authority to enter into this Consent
       Decree.

   19. Counterparts. This Consent Decree may be signed in any number of
       counterparts (including by facsimile), each of which, when executed
       and delivered, shall be an original, and all of which counterparts
       together shall constitute one and the same fully executed instrument.


     _______________________________    
                                        
     Kathryn S. Berthot                 
                                        
     Chief                              
                                        
     Spectrum Enforcement Division      
                                        
     Enforcement Bureau                 
                                        
     ________________________________   
                                        
     Date                               
                                        
     ________________________________   
                                        
     Saleem Miyan                       
                                        
     Chief Executive Officer            
                                        
     Wavetrend Technologies Limited     
                                        
     Parkshot House                     
                                        
     5 Kew Road                         
                                        
     Richmond, Surrey TW9 2PR           
                                        
     United Kingdom                     
                                        
     ________________________________   
                                        
     Date                               


   47 U.S.C. S: 302a(b).

   47 C.F.R. S: 2.803(a)(1).

   47 U.S.C. S: 154(i), 503(b).

   47 C.F.R. S:S: 0.111, 0.311.

   47 U.S.C. S: 302a(b).

   47 C.F.R. S: 2.803(a)(1).

   47 C.F.R. S: 15.231.

   See Letter from Raymond LaForge, Chief, Auditing and Compliance Branch,
   Office of Engineering and Technology, Federal Communications Commission,
   to Wavetrend Technologies, Ltd. (Feb. 28, 2008) ("OET Letter").

   See OET Letter.

   See Letter from Saleem Miyan, CEO, Wavetrend, to Raymond LaForge, Chief,
   Auditing and Compliance Branch, Office of Engineering and Technology,
   Federal Communications Commission (March 10, 2008).

   See Letter from Saleem Miyan, CEO, Wavetrend, to Kevin M. Pittman,
   Spectrum Enforcement Division, Enforcement Bureau, Federal Communications
   Commission (May 21, 2008).

   Federal Communications Commission DA 08-2052

   5

   Federal Communications Commission DA 08-2052