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   November 18, 2009

   VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED

   AND FACSIMILE TO COUNSEL AT 760-730-3863

   Jason Hsia

   Team Research, Inc.

   1911 Hartog Dr.

   San Jose, CA 95131

   Re: File No. EB-09-SE-136

   Dear Mr. Hsia:

   This is an official CITATION, issued to Team Research, Inc. ("Team
   Research") pursuant to Section 503(b)(5) of the Communications Act of
   1934, as amended ("Act"), for marketing a non-compliant radio frequency
   device, specifically, the Astak CM-918T2 wireless security camera ("Astak
   CM-918T2"), in the United States in violation of Section 302(b) of the
   Act, and Sections 2.803, 15.209 and 15.249(d) of the Commission's Rules
   ("Rules"). As explained below, future violations of the Commission's Rules
   in this regard may subject your company to monetary forfeitures.

   In March 2009, the Enforcement Bureau received a complaint alleging that
   the Astak CM-918T2 is causing harmful interference to Sprint Nextel's
   licensed operation of its iDEN network in the 800 MHz and 900 MHz bands.
   On August 17, 2009, staff from the Enforcement Bureau's Spectrum
   Enforcement Division ("Division") visited the Team Research web site at
   www.teamresearchinc.com. The staff observed that Team Research was
   marketing the Astak CM-918T2 model of wireless camera. Subsequently, the
   Enforcement Bureau provided samples of the Astak CM-918T2 to the FCC's
   Office of Engineering and Technology ("OET") Laboratory for testing. The
   OET Laboratory's tests demonstrated that the Astak CM-918T2 does not
   comply with the radiated emission limits specified in Sections 15.249(d)
   and 15.209 of the Rules. As part of the investigation, the Division sent a
   letter of inquiry ("LOI") to Team Research on September 2, 2009.

   In your September 25, 2009 response to the LOI, you admit that Team
   Research imports and markets the Astak CM-918T2 in the United States. You
   indicated, however, that Team Research does not manufacture the Astak
   CM-918T2 and has "no role in the development and design" of the camera."
   You also stated that Team Research "ceased marketing and selling" of the
   Astak CM-918T2 and recalled all unsold units on August 18, 2009 after it
   learned of citations issued to Costco Wholesale Corporation and Wal-Mart
   Stores, Inc.

   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
   provides in pertinent part that:

   [N]o 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.

   Intentional radiators, such as the transmitter component of the Astak
   CM-918T2 wireless security camera, are generally required by Section
   15.201 of the Rules, to be approved through the equipment certification
   procedures described in Sections 2.1031 - 2.1060 of the Rules prior to
   marketing within the United States. As an intentional radiator operating
   at 905 MHz and 924 MHz, the Astak CM-918T2 is also subject to the radiated
   emission limits specified in Section 15.249(a) of the Rules for operations
   within the 902-928 MHz band. In addition, pursuant to Section 15.249(d) of
   the Rules, except for harmonics, emissions from the Astak CM-918T2
   radiated outside the 902-928 MHz band must be attenuated by at least 50 dB
   below the level of the fundamental frequency or to the general radiated
   emission limits specified in Section 15.209 of the Rules, whichever is the
   lesser attenuation. The OET Laboratory's tests demonstrate that radiated
   emissions from the Astak CM-918T2 outside the 902-928 MHz band
   substantially exceed the limits specified in Section 15.209 of the Rules.
   Therefore, the Astak CM-918T2 does not comply with the radiated emission
   limits specified in Sections 15.249(d) and 15.209 of the Rules.

   Accordingly, it appears that Team Research violated Section 302(b) of the
   Act and Sections 2.803, 15.209, and 15.249(d) of the Rules by marketing in
   the United States the Astak CM-918T2 wireless security camera.

   If, after receipt of this citation, you violate the Communications Act or
   the Commission's Rules in any manner described herein, the Commission may
   impose monetary forfeitures not to exceed $16,000 for each such violation
   or each day of a continuing violation.

   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 you are taking to ensure that you
   do not violate the Commission's Rules governing the marketing and
   importing of radio frequency equipment in the future.

   The nearest Commission field office is the San Francisco Office, in
   Pleasanton, California. Please call Linda Nagel at 202-418-2145 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 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.

   Sincerely,

   Kathryn S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   Federal Communications Commission

   Copy to: Michael H. Ritter, Esq.

   Law Office of Michael H. Ritter

   3805 Shale Court

   Carlsbad, CA 92010

   47 U.S.C. S: 503(b)(5).

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

   47 C.F.R. S:S:2.803, 15.209 and 15.249(d).

   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).

   Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
   Enforcement Bureau, Federal Communications Commission, to Team Research,
   Inc. (September 2, 2009).

   Letter from Michael H. Ritter, Esq., Counsel for Team Research, Inc., to
   Kathryn S. Berthot, Chief, Spectrum Enforcement Division, Enforcement
   Bureau, Federal Communications Commission (September 25, 2009).

   Id. at 1.

   Id. at 3. See also Costco Warehouse Corporation, Citation, 24 FCC Rcd
   10836 (Enf. Bur., Spectrum Enf. Div., 2009) ; see also Wal-Mart Stores,
   Inc., Citation, 24 FCC Rcd 10839 (Enf. Bur., Spectrum Enf. Div., 2009).

   An intentional radiator is "[a] device that intentionally generates and
   emits radio frequency energy by radiation or induction." 47 C.F.R. S:
   15.3(o).

   See 47 C.F.R. S: 15.201.

   A certification is an equipment authorization issued by the Commission,
   based on representations and test data submitted by the applicant. See 47
   C.F.R. S: 2.907(a).

   47 C.F.R. S:S: 2.1031 - 2.1060.

   The Astak CM-918T2 is certified under FCC ID WQZCM-918T2 to operate at 905
   MHz and 924 MHz.

   See 47 C.F.R. S: 15.249(a).

   See 47 C.F.R. S: 15.249(d).

   See 47 C.F.R. S: 15.209.

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

   Federal Communications Commission DA 09-2426

   1

   2

   Federal Communications Commission DA 09-2426

                       FEDERAL COMMUNICATIONS COMMISSION

                            WASHINGTON, D.C.  20554