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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                        )                           
                                                    
                        )   File No. EB-09-SE-122   
     In the Matter of                               
                        )   Acct. No. 201032100038  
     Kannad SAS                                     
                        )   FRN No. 0016726580      
                                                    
                        )                           


                                     ORDER

   Adopted: August 26, 2010 Released: August 27, 2010

   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 Kannad SAS ("Kannad").
       The Consent Decree terminates an investigation by the Bureau against
       Kannad for possible violations of Section 302(b) of the Communications
       Act of 1934, as amended ("Act"), and Section 2.803(a) of the
       Commission's Rules ("Rules"), regarding Kannad's marketing of
       406.0-406.1 MHz emergency locator transmitters ("406 MHz ELTs") that
       were not labeled in accordance with Section 87.199(f) the Rules.

    2. The Bureau and Kannad 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 Kannad 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 Act,
       and Sections 0.111 and 0.311 of the 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 counsel for Kannad, Daniel Brenner, Esq., Hogan Lovells
       US LLP, Columbia Square, 555 Thirteenth Street, NW, Washington, DC
       20004.

   FEDERAL COMMUNICATIONS COMMISSION

   Kathryn S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                        )                           
                                                    
                        )   File No. EB-09-SE-122   
     In the Matter of                               
                        )   Acct. No. 201032100038  
     Kannad SAS                                     
                        )   FRN 0016726580          
                                                    
                        )                           


                                 CONSENT DECREE

   The Enforcement Bureau ("Bureau") and Kannad SAS ("Kannad") by their
   authorized representatives, hereby enter into this Consent Decree for the
   purpose of terminating the Bureau's Investigation into whether Kannad
   violated Section 302(b) of the Communications Act of 1934, as amended
   ("Act"), and Section 2.803(a) of the Commission's Rules ("Rules"),
   regarding Kannad's marketing of 406.0-406.1 MHz emergency locator
   transmitters ("406 MHz ELTs") that were not labeled in accordance with
   Section 87.199(f) of the Commission's Rules.

   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. "Compliance Plan" means the program described in this Consent Decree
       at Paragraph 8.

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

    g. "Investigation" means the investigation commenced by the Bureau's
       September 29, 2009 Letter of Inquiry regarding Kannad's marketing of
       406 MHz ELTs that were not labeled in accordance with Section
       87.199(f) of the Rules.

    h. "Kannad" means Kannad SAS and its predecessors-in-interest and
       successors-in-interest.

    i. "Parties" means Kannad and the Bureau, and each a "Party".

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

   II. BACKGROUND

    2. Pursuant to Section 302(b) of the Act and Section 2.803(a) of the
       Rules, radio frequency devices may not be marketed in the United
       States unless such devices comply with the applicable technical and
       administrative provisions of the Rules. Section 87.199(f) of the Rules
       requires that, in addition to bearing the label required by the
       Commission's equipment certification rules in Sections 2.925 and
       2.926, each 406 MHz ELT must be provided on the outside with a clearly
       discernable permanent plate or label containing the following
       statement: "The owner of this 406.0-406.1 MHz ELT must register the
       NOAA identification code contained on this label with the National
       Oceanic and Atmospheric Administration (NOAA), whose address is:
       NOAA/SARSAT Beacon Registration, E/SP3, Federal Building 4, Room 3320,
       5200 Auth Road, Suitland, MD 20746-4304."

    3. On September 29, 2009, the Bureau's Spectrum Enforcement Division
       ("Division") issued a Letter of Inquiry ("LOI") to Kannad. The LOI
       directed Kannad, among other things, to submit a sworn written
       response to a series of questions relating to whether Kannad was
       marketing 406 MHz ELTs that were not labeled in accordance with the
       Commission's Rules. Kannad responded to the LOI on October 23, 2009.
       On March 18, 2010, the Division sent, via email, additional questions
       seeking clarification of statements Kannad made in its LOI Response.
       On April 6, 2010, Kannad responded to those questions.

   III. TERMS OF AGREEMENT

    4. 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.

    5. Jurisdiction. Kannad 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.

    6. Effective Date; Violations. The Parties agree that this Consent Decree
       shall become effective on the Effective Date. 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.

    7. 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 the
       Investigation. In consideration for the termination of said
       Investigation, Kannad agrees to the terms, conditions, and procedures
       contained herein. The Bureau further agrees that in the absence of new
       material evidence, the Bureau will not use the facts developed in this
       Investigation through the Effective Date, 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
       Kannad concerning the matters that were the subject of the
       Investigation. The Bureau also agrees that in the absence of new
       material evidence it will not use the facts developed in this
       Investigation through the Effective Date, 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 Kannad with
       respect to Kannad's basic qualifications, including its character
       qualifications, to be a Commission licensee or to hold Commission
       authorizations.

    8. Compliance Plan. In response to the Bureau's Investigation, Kannad
       initiated certain remedial measures and, for purposes of settling the
       matters herein, agrees to implement a Compliance Plan related to
       future compliance with the Act, the Rules, and the Commission's
       Orders. The Compliance Plan will include, but will not be limited to,
       the following components:

   (a) Compliance Officer. Within thirty (30) days of the Effective Date,
   Kannad will designate a Compliance Officer who will be responsible for
   administering the Compliance Plan.

   (b) Identification and Labeling of Noncompliant ELTs. Beginning in October
   2009, Kannad took steps to bring noncompliant labeled 406 MHz ELTs into
   compliance with Commission Rules. These steps included issuing a Service
   Bulletin and providing proper labels and instructions for affixing the
   missing labels to qualified Kannad service stations, where authorized
   agents of Kannad conduct annual reviews and repair or conduct mandatory
   inspections every six years (whichever comes first). Kannad also contacted
   all distributors of noncompliant 406 MHz ELTs to ascertain the end-user
   purchasers, and through its efforts to contact many of these purchasers
   about the need to affix the missing labels, has brought some purchased
   units into compliance. Kannad will continue its ongoing efforts to bring
   the remaining noncompliant Kannad 406 MHz ELTs that were sold in the
   United States into compliance by sending the Service Bulletin, proper
   labels, instructions for affixing the missing labels and a letter of
   explanation to known purchasers of these units. In addition, Kannad will
   re-send the Service Bulletin to all qualified Kannad service stations in
   the United States within 30 days of the Effective Date and again every
   twelve (12) months thereafter for the next twenty-four (24) months. The
   Service Bulletin will also indicate that additional labels are available
   if a service station needs additional labels.

   (c) Training. Kannad will provide training and materials concerning the
   labeling requirements for 406 MHz ELTs as provided for under Part 87 of
   the Commission's rules and the requirements of the Consent Decree to all
   of its employees who are involved directly or indirectly in the
   manufacturing and labeling of 406 MHz ELTs sold by Kannad. Further, within
   ninety (90) days of hire, Kannad will similarly provide training to all
   new employees involved directly or indirectly in the manufacturing and
   labeling of 406 MHz ELTs sold by Kannad.

   (d) Compliance Reports. Kannad 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 Compliance Report shall include a certification by the
   Compliance Officer, as an agent of and on behalf of Kannad, stating that
   the Compliance Officer has personal knowledge (i) that Kannad has
   established operating procedures intended to ensure compliance with the
   terms and conditions of this Consent Decree, and with Sections 2.803(a)
   and 87.199(f) of the Rules, together with an accompanying statement
   explaining the basis for the Compliance Officer's certification; (ii) that
   Kannad has been utilizing those procedures since the previous Compliance
   Report was submitted; and (iii) that Kannad is not aware of any instances
   of non-compliance. The certification must comply with section 1.16 of the
   Rules and be subscribed to as true under penalty of perjury in
   substantially the form set forth therein.  If the Compliance Officer
   cannot provide the requisite certification, the Compliance Officer, as an
   agent of and on behalf of Kannad, shall provide the Commission with a
   detailed explanation of: (i) any instances of non-compliance with this
   Consent Decree and the Rules, and (ii) the steps that Kannad has taken or
   will take to remedy each instance of non-compliance and ensure future
   compliance, and the schedule on which proposed remedial actions will be
   taken. All Compliance Reports shall be submitted to the Chief, Spectrum
   Enforcement Division, Enforcement Bureau, Federal Communications
   Commission, 445 12th Street, S.W. Washington, D.C. 20554, with a copy
   submitted electronically to Jennifer Burton at Jennifer.Burton@fcc.gov and
   to JoAnn Lucanik at JoAnn.Lucanik@fcc.gov.

   (e) Termination Date. Unless stated otherwise, the requirements of this
   Paragraph 8 of the Consent Decree will expire twenty-four (24) months from
   the Effective Date.

    9. Voluntary Contribution. Kannad agrees that it will make a voluntary
       contribution to the United States Treasury in the amount of seven
       thousand two hundred dollars ($7,200). The payment will be made within
       thirty (30) days after the Effective Date. 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). Kannad shall also send electronic
       notification to Jennifer Burton at Jennifer.Burton@fcc.gov and to
       JoAnn Lucanik at JoAnn.Lucanik@fcc.gov on the date said payment is
       made.

   10. Waivers. Kannad 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. Kannad 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
       Kannad nor the Commission shall contest the validity of the Consent
       Decree or the Adopting Order, and Kannad shall waive any statutory
       right to a trial de novo. Kannad 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.

   11. Invalidity. 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.

   12. 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 Kannad does not expressly
       consent) that provision will be superseded by such Commission rule or
       Order.

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

   14. 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.

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

   16. 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.

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

   18. 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

   ______________________________

   Jean Pierre Bardon

   Chief Executive Officer

   Kannad SAS

   ______________________________

   Date

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

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

   47 C.F.R. S: 87.199(f).

   47 U.S.C. S: 154(i).

   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).

   47 C.F.R. S: 87.199(f).

   Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
   Enforcement Bureau, Federal Communications Commission, to Jean-Pierre
   Bardon, CEO, Kannad (Sept. 29, 2009) ("Sept. 29, 2009 LOI").

   47 C.F.R. S:S: 2.925, 2.926.

   47 C.F.R. S: 87.199(f).

   See Sept. 29, 2009 LOI.

   See Letter from Daniel L. Brenner, Esq., Hogan & Hartson, counsel for
   Kannad, to Marlene H. Dortch, Secretary, Federal Communications Commission
   (Oct. 23, 2009) ("LOI Response").

   Email from Jennifer Burton, Esq., Spectrum Enforcement Division,
   Enforcement Bureau, Federal Communications Commission, to Daniel L.
   Brenner, Esq., Hogan & Hartson, counsel for Kannad (March 18, 2010).

   Email from Daniel L. Brenner, Esq., Hogan & Hartson, counsel for Kannad,
   to Jennifer Burton, Esq., Spectrum Enforcement Division, Enforcement
   Bureau, Federal Communications Commission (April 6, 2010).

   (...continued from previous page)

                                                              (continued....)

   Federal Communications Commission DA 10-1511

                                       2

   Federal Communications Commission DA 10-1511

                                       4