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                                   Before the

                       Federal Communications Commission

                              Washington, DC 20554

   In the Matter of C.T.S. Technology Co., Limited CTStechnologys.com
   Aiswa.com Shenzhen C.T.S Import and Export Co., Limited Shenzhen,
   Guangdong, People's Republic of China ) ) ) ) ) ) ) ) ) File No.:
   EB-SED-12-00005692 NAL/Acct. No.: 201432100017 FRN: 0023572043




             NOTICE OF APPARENT LIABILITY FOR FORFEITURE AND ORDER

                  ILLEGAL MARKETING OF SIGNAL JAMMING DEVICES

   Adopted: June 18, 2014 Released: June 19, 2014

   By the Commission:

   I. INTRODUCTION

    1. In this landmark enforcement action, we aggressively address the
       illegal marketing of GPS, cell, and other signal jamming devices to
       U.S. consumers over the Internet. Jamming devices pose tangible
       threats to the integrity of U.S. communications infrastructure. They
       can endanger life and property by preventing individuals from making
       9-1-1 or other emergency calls or disrupting the basic communications
       essential to aviation and marine safety. We find that C.T.S.
       Technology Co., Limited (C.T.S. Technology), a foreign manufacturer,
       illegally marketed nearly 300 models of signal jamming devices to
       consumers in the United States over more than two years. In some
       cases, the devices sold by C.T.S. Technology not only jammed the
       communications signals advertised, but also were potentially much more
       harmful, blocking communications far beyond the scope of those listed
       in their advertisements and marketing materials. C.T.S. Technology
       also apparently misled consumers, falsely claiming on its websites
       that certain signal jammers were approved by the FCC for consumer use.
       As confirmed by proactive market surveillance and an extensive
       undercover operation conducted by the FCC's Enforcement Bureau, these
       apparent violations are egregious, escalated over more than two years,
       and continue as of the date of this action. We therefore propose the
       maximum penalty permitted by statute of thirty-four million nine
       hundred and twelve thousand and five hundred dollars ($34,912,500).
       Given the relative ease with which U.S. consumers may purchase illegal
       jammers over the Internet, we will aggressively target the retail
       platforms, like C.T.S. Technology, that are conducting and enabling
       illegal activity.

    2. Signal jamming devices (also referred to as signal jammers) operate by
       transmitting powerful radio signals that overpower, jam, or interfere
       with authorized communications. While these devices have been marketed
       with increasing frequency over the Internet, they have no lawful
       consumer use in the United States.^ Jammers are not only designed to
       impede authorized communications and thereby interfere with the rights
       of legitimate spectrum users and the general public, their operations
       also place the safety of the public at risk. For example, jammers can
       disrupt critical public safety communications, placing first
       responders like law enforcement and fire fighting personnel--as well
       as the public they are charged with protecting--at great risk. In
       order to protect the public and preserve unfettered access to and use
       of emergency and other communications services, the Communications Act
       of 1934, as amended (Communications Act or Act), generally prohibits
       the importation, use, marketing, manufacture, and sale of jammers in
       the United States.^

    3. In issuing this Notice of Apparent Liability for Forfeiture and Order
       (NAL), we are mindful that jammer retailers and
       manufacturers--especially some based abroad--aggressively target U.S.
       consumers, offering free and expedited shipping deals and discounted
       prices, as well as incorrectly claim that jamming devices are legal in
       the U.S. Indeed, our market surveillance efforts reveal that these
       jammer retailers market devices that specifically jam U.S.-only
       wireless frequencies and misstate the intensity of the power levels
       and the frequencies of the signal jammers they offer. We are also
       aware that virtually every jammer available in this country originated
       elsewhere. Foreign entities therefore play a critical and primary role
       in facilitating the harms jammers cause domestically. It is thus
       critical to enforce our rules against offshore retailers and
       manufacturers who offer and sell such devices to consumers in the
       United States.

    4. In addition to paying or contesting the proposed forfeiture, C.T.S.
       Technology should immediately implement any necessary measures to
       ensure compliance with the Act and the Federal Communications
       Commission's (Commission or FCC) rules (Rules). Without limiting the
       measures C.T.S. Technology can take, such compliance measures may
       include removing jamming devices from online displays that are
       accessible to U.S. consumers; expressly excluding consumers in the
       United States and its territories as potential customers in any online
       or print marketing material; implementing technical limitations that
       prevent any order processing system from accepting U.S. addresses for
       shipment; declining to otherwise complete any sales transaction
       involving consumers in the United States and its territories; and
       removing statements on its websites, directed to U.S. or other
       consumers, that the signal jammers it advertises for sale are
       certified or otherwise approved by the FCC, when, in fact, they are
       not. ^ ^

    5. We also again warn U.S. consumers that importing a cell, GPS, or other
       signal jamming device (i.e., purchasing such a device online and
       having it shipped into the United States via the U.S. mail or other
       transport or courier service) is unlawful and may subject them to
       civil and criminal penalties.^ While the Commission has typically
       issued a warning to consumers who violate its importation rules, in
       the case of signal jammers, the Communications Act permits us to take
       a more aggressive approach--imposing monetary penalties in the first
       instance. We are prepared to do so.

   II. Background

    6. C.T.S. Technology is a manufacturer and retailer of wireless
       communication products, including signal jamming devices.^ C.T.S.
       Technology advertises these products on the Internet through websites
       such as CTStechnologys.com and Aiswa.com, and on various third party
       platforms.^ As part of its market surveillance efforts, the Spectrum
       Enforcement Division (Division) of the Enforcement Bureau (Bureau)
       observed numerous cell phone jammers and other signal jamming devices
       manufactured by C.T.S. Technology and offered for sale on the
       Aiswa.com website. C.T.S. Technology has also increased threefold the
       number of signal jammers it has advertised for sale to U.S. customers,
       first marketing 78 signal jammers, then 113 and, in September 2013,
       increasing to its current total of 285 different models.^ The company
       has even gone so far as to falsely claim in its marketing materials
       that certain of its signal jammers have been approved by the FCC.^

    7. These product offerings include GPS blockers for vehicles, high-tech
       signal blockers with remote control capabilities, jammers disguised as
       cigarette packs, other small, easily concealable cell phone jammers,
       as well as high-powered industrial jammers that have the potential to
       disrupt radio signals spanning areas larger than ten football fields.^
       In its online marketing materials, C.T.S. Technology emphasizes that
       its 100 watt GPS jammer is effective up to a distance of 1000 meters,
       which is more than one-half mile.^ C.T.S. Technology further claims
       that the signal jammers it offers target various frequencies,
       services, and/or technologies, such as GPS, vehicle tracking systems,
       satellite radio, Code Division Multiple Access (CDMA), Global System
       for Mobile Communications (GSM), Wi-Fi, Bluetooth, Universal Mobile
       Telecommunications System (UMTS-3G), Long Term Evolution (LTE-4G),
       Integrated Digital Enhanced Network (iDEN), the Personal Handy-phone
       System (PHS), Digital Cellular Service (DCS), and General Packet Radio
       Service (GPRS).^ And, it expressly claims specialized expertise in
       manufacturing cell phone jammers, touting its success in delivering
       such devices to consumers in the United States.^

    8. In addition to aggressively advertising illegal signal jammers to U.S.
       consumers, C.T.S. Technology also sold illegal signal jammers to
       undercover Division personnel. Specifically, in 2012, Division
       personnel--using various aliases and posing as U.S. consumers--ordered
       a total of 10 high-powered signal jammers from the Aiswa.com website,
       providing U.S. billing and delivery addresses. C.T.S. Technology
       completed the online transactions, accepted payment, and shipped the
       signal jammers to the United States. Upon receipt of the signal
       jammers, the Commission's Office of Engineering and Technology
       conducted detailed tests of the signal jammers' capabilities and
       confirmed that the devices blocked authorized communications signals.
       Additional forensic testing conducted by external engineers also
       confirmed that the devices blocked authorized communications signals,
       including some frequencies beyond the scope of those listed in the
       advertisements.

   III. Applicable Law and Violations

    9. Federal law prohibits the advertising, sale, importation, and
       operation of signal jammers in the United States.^ Section 333 of the
       Act 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."^ 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."^

   10. The applicable implementing regulations regarding the marketing and
       use of radio frequency devices, which are set forth in Sections 2.803,
       2.805, 2.807, 15.1(c), 15.3(o), and 15.201 of the Rules, operate
       together to create a broad and robust framework to prevent the
       manufacture, importation, marketing, distribution (by sale or
       otherwise) and use of RF-generating devices, such as signal jammers,
       that can cause harmful interference to radio communications.^ Section
       2.803(b)(1) of the Rules provides in relevant part that:

   No person may market a radio frequency device unless . . . [f]or devices
   subject to authorization under certification, the device has been
   authorized in accordance with the rules in subpart J of this chapter and
   is properly identified and labeled as required by S 2.925 and other
   relevant sections in this chapter.^

   11. Moreover, pursuant to Section 15.201(b) of the Rules, intentional
       radiators^ like signal jammers cannot be marketed in the United States
       or its territories unless they have first been authorized in
       accordance with the Commission's certification procedures.^ Section
       2.803(a) of the Rules defines "marketing" as the "sale or lease, or
       offering for 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."^

   12. Signal jammers, however, cannot be certified or authorized because
       their primary purpose is to block or interfere with authorized radio
       communications. Indeed, Section 333 of the Act clearly prohibits the
       use of devices designed and built for such a purpose.^ Thus, signal
       jammers such as those offered by C.T.S. Technology cannot comply with
       the FCC's technical standards and therefore cannot be marketed
       lawfully to consumers in the United States or its territories. We
       again emphasize that under Section 302(b) of the Act, radio frequency
       devices like signal jamming devices are per se illegal because they
       are designed to compromise the integrity of the nation's
       communications infrastructure.^ As such, signal jammers may only be
       marketed pursuant to the narrow statutory exceptions in Section 302(c)
       of the Act.^ Furthermore, as the manufacturer of devices that require
       Commission authorization, C.T.S. Technology is obligated under our
       Rules to ensure that the devices complied with the Rules prior to
       marketing the devices to U.S. consumers.^

   13. The evidence gathered by the Bureau in this case demonstrates that
       C.T.S. Technology marketed 285 models of signal jamming devices to
       U.S. consumers via its Aiswa.com website^ over an extended period of
       time, utilizing a variety of advertising venues, including its
       alternate website CTStechnolgys.com. C.T.S. Technology indicates on
       the websites that it will ship (and has shipped) signal jammers to
       consumers within the United States.^ In fact, the evidence shows that
       C.T.S. Technology completed the sale of 10 high-powered signal jamming
       devices to undercover Division personnel posing as U.S. consumers, and
       successfully shipped the devices into the United States. Extensive
       testing of these devices confirmed that they were indeed signal
       jammers that in some instances disrupted signals even beyond their
       designated frequency bands. Accordingly, we find that C.T.S.
       Technology apparently violated Section 302(b) of the Act and Sections
       2.803 and 15.201(b) of the Rules by willfully and repeatedly marketing
       illegal radio frequency devices to consumers in the United States.^

   IV. PROPOSED FORFEITURE

   14. Section 503(b) of the Act provides that any person who willfully^ or
       repeatedly^ fails to comply substantially with the terms and
       conditions of any license, or willfully or repeatedly fails to comply
       with any of the provisions of the Act or of any rule, regulation, or
       order issued by the Commission thereunder, shall be liable for a
       forfeiture penalty.^ Pursuant to the Commission's Forfeiture Policy
       Statement and Section 1.80 of the Rules, the applicable base
       forfeiture amount for the marketing of unauthorized equipment involved
       in this case is $7,000 per violation.^

   15. The Commission retains the discretion, however, to issue a higher or
       lower forfeiture than provided in the Forfeiture Policy Statement or
       to apply alternative or additional sanctions as permitted by the
       statute.^ Pursuant to this statutory and regulatory authority, the
       Commission has promulgated (consistent with the requirements of the
       Debt Collection Improvement Act of 1996^) different maximum
       forfeitures, depending on the type of violator and violations.^ The
       maximum for violations of the signal jamming prohibition (including
       the marketing at issue here) is $16,000 for each violation.^ As
       provided in Section 1.80(b)(7) of the Commission's Rules, in the case
       of a continuing signal jammer prohibition violation, the Commission
       may impose up to $16,000 for each day of such continuing violation up
       to a maximum forfeiture of $122,500 for any single act or failure to
       act.^ For instance, the Commission may impose separate forfeitures for
       each signal jammer marketed and/or for each day on which a signal
       jammer is marketed, but only up to these statutory limits.

   16. We are mindful of the serious public safety risks posed by the
       marketing of signal jamming devices and of the apparent need to
       provide greater incentives for individuals and businesses to cease
       marketing them to U.S. consumers altogether.^ Accordingly, we propose
       a separate forfeiture for each model of jamming device that was
       advertised for sale in violation of the Act and our Rules.^ Further,
       we will assess this forfeiture for each day on which the illegal
       marketing activity continued, up to the maximum forfeiture amount
       permitted by statute.

   17. Consistent with this approach, we find that C.T.S. Technology
       apparently committed 285 separate violations of the Act and our Rules
       through its documented advertisements to U.S. consumers. Based on the
       evidence in the record, we further find that the online jammer
       advertisements are continuing violations, with many lasting more than
       two years.^

   18. In assessing the appropriate monetary penalty for this misconduct, we
       must take into account the statutory factors set forth in Section
       503(b)(2)(E) of the Act, which include the nature, circumstances,
       extent, and gravity of the violations, and with respect to the
       violator, the degree of culpability, any history of prior offenses,
       ability to pay, and other such matters as justice may require.^ C.T.S.
       Technology marketed to U.S. consumers multiple radio frequency devices
       that are inherently illegal, designed for no purpose other than
       performing functions that violate U.S. law, and expressly prohibited
       for consumer use in the United States. These signal jammers could pose
       a critical public safety hazard by potentially blocking authorized
       communications, including essential 9-1-1 calls and law enforcement
       communications. Furthermore, C.T.S. Technology marketed several
       extremely high power jammers, including a 100 watt GPS jammer and a
       180 watt cell phone jammer with ranges exceeding 3,200 feet. And, even
       more troubling, C.T.S. Technology sought to mislead U.S. consumers,
       misrepresenting in its online marketing materials that certain of the
       devices were approved by this agency. We find this continuing
       misconduct to be particularly egregious and harmful, warranting a
       substantial upward adjustment of the base forfeiture amount.

   19. Therefore, applying the approach used in three recent Notices of
       Apparent Liability for Forfeiture involving the operation of signal
       jammers and reflecting the discretion afforded us by the Forfeiture
       Policy Statement, Section 1.80 of the Rules, and the statutory
       factors,^ we propose the maximum forfeiture authorized by statute for
       each of the 285 marketing violations. Specifically, consistent with
       Section 503(b)(2) of the Act, which authorizes separate forfeiture
       penalties for each day of a continuing violation, we will apply the
       $16,000 statutory maximum to each day on which these 285 violations
       continued up to the statutory maximum of $122,500 for each of the
       continuing violations.^ We therefore conclude that C.T.S. Technology
       is apparently liable for a total forfeiture in the amount of
       $34,912,500 for its apparent willful and repeated violations of
       Section 302(b) of the Act and Sections 2.803 and 15.201(b) of the
       Rules.

   20. C.T.S. Technology should immediately implement any necessary measures
       to ensure compliance with the Act and the Commission's rules.^ Without
       limiting the measures C.T.S. Technology can take, such compliance
       measures may include removing jamming devices from online displays
       that are accessible to U.S. consumers; expressly excluding consumers
       in the United States and its territories as potential customers in any
       online or print marketing material; implementing technical limitations
       that prevent any order processing system from accepting U.S. addresses
       for shipment; declining to otherwise complete any sales transaction
       involving consumers in the United States and its territories; and
       removing statements on its websites, directed to U.S. or other
       consumers, that the signal jammers it advertises for sale are
       certified or otherwise approved by the Federal Communications
       Commission, when, in fact, they are not.^

   21. In addition, we direct C.T.S. Technology to submit the information
       requested in non-public Appendix B hereto concerning C.T.S.
       Technology's signal jammer distribution channels and sales, including
       the purchasers of each illegal signal jamming device sold to consumers
       in the United States or its territories, the websites that C.T.S.
       Technology has used to market the devices to consumers in the United
       States or its territories, and the corrective actions C.T.S.
       Technology has taken, is taking, or will take as required by this
       NAL.^ We direct C.T.S. Technology to submit its response within
       forty-five (45) calendar days after service of this NAL.

   V. ORDERING CLAUSES

   22. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the
       Communications Act of 1934, as amended, and Section 1.80 of the
       Commission's rules, C.T.S. Technology Co., Limited is hereby NOTIFIED
       of this APPARENT LIABILITY FOR A FORFEITURE in the amount of
       thirty-four million nine hundred twelve thousand and five hundred
       dollars ($34,912,500) for apparent willful and repeated violations of
       Section 302(b) of the Communications Act of 1934, as amended, and
       Sections 2.803 and 15.201(b) of the Commission's rules.^

   23. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the
       Commission's rules, within thirty (30) calendar days after the service
       of this Notice of Apparent Liability for Forfeiture and Order, C.T.S.
       Technology Co., Limited SHALL PAY the full amount of the proposed
       forfeiture or SHALL FILE a written statement seeking reduction or
       cancellation of the proposed forfeiture.

   24. IT IS FURTHER ORDERED that, pursuant to Sections 1, 4(i), 4(j),
       302(b), and 403 of the Communications Act of 1934, as amended,^ and
       also Sections 2.803 and 15.201(b) of the Commission's rules,^ C.T.S.
       Technology Co., Limited SHALL COMPLY with the directive set forth in
       paragraph 20 above; and within forty-five (45) calendar days after the
       service of this Notice of Apparent Liability for Forfeiture and Order
       SHALL SUBMIT the information requested in non-public Appendix B hereto
       concerning C.T.S. Technology Co., Limited's signal jammer distribution
       channels and sales, including the purchasers of each illegal signal
       jamming device sold to consumers in the United States or its
       territories, the websites that C.T.S. Technology Co., Limited has used
       to market the devices to consumers in the United States or its
       territories, and a detailed statement about the corrective actions
       C.T.S. Technology Co., Limited has taken, is taking, or will take as
       required by this Notice of Apparent Liability for Forfeiture and
       Order.  Further, the required written response (as well as any
       correspondence with the Federal Communications Commission concerning
       this Notice of Apparent Liability for Forfeiture and Order) shall be
       mailed to Federal Communications Commission, Enforcement Bureau,
       Spectrum Enforcement Division, ATTN: EB-SED-12-00005692, 445 12th
       Street, S.W., Washington, DC 20554.  C.T.S. Technology Co., Limited
       also shall e-mail the written response to: jammerinfo@fcc.gov.

   25. Payment of the forfeiture must be made by check or similar instrument,
       wire transfer, or credit card, and must include the NAL/Account Number
       and FRN referenced above. C.T.S. Technology Co., Limited. shall also
       send electronic notification on the date said payment is made to
       jammerinfo@fcc.gov. Regardless of the form of payment, a completed 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). Below are additional instructions CTS Technology
       Co., Limited should follow based on the form of payment it selects:

     * Payment by check or money order must be made payable to the order of
       the Federal Communications Commission. Such payments (along with the
       completed Form 159) must be mailed to Federal Communications
       Commission, P.O. Box 979088, St. Louis, MO 63197-9000, or sent via
       overnight mail to U.S. Bank - Government Lockbox #979088, SL-MO-C2-GL,
       1005 Convention Plaza, St. Louis, MO 63101.

     * Payment by wire transfer must be made to ABA Number 021030004,
       receiving bank TREAS/NYC, and Account Number 27000001. To complete the
       wire transfer and ensure appropriate crediting of the wired funds, a
       completed Form 159 must be faxed to U.S. Bank at 1-314-418-4232 on the
       same business day the wire transfer is initiated.

     * Payment by credit card must be made by providing the required credit
       card information on FCC Form 159 and signing and dating the Form 159
       to authorize the credit card payment. The completed Form 159 must then
       be mailed to Federal Communications Commission, P.O. Box 979088, St.
       Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank -
       Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
       Louis, MO 63101.

   26. Any request for making full payment over time under an installment
       plan should be sent to: Chief Financial Officer--Financial Operations,
       Federal Communications Commission, 445 12th Street, S.W., Room 1-A625,
       Washington, D.C. 20554.^ If you have questions regarding payment
       procedures, please contact the Financial Operations Group Help Desk by
       phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.

   27. The written statement seeking reduction or cancellation of the
       proposed forfeiture, if any, must include a detailed factual statement
       supported by appropriate documentation and affidavits pursuant to
       Sections 1.16 and 1.80(f)(3) of the Commission's rules.^ Mail the
       written statement to Federal Communications Commission, Enforcement
       Bureau, Spectrum Enforcement Division, ATTN: EB-SED-12-00005692, 445
       12th Street, S.W., Washington, DC 20554 and, include the NAL/Acct.
       Number referenced in the caption. C.T.S. Technology Co., Limited. also
       shall e-mail the written response to: jammerinfo@fcc.gov. The
       Commission will not consider reducing or canceling a forfeiture in
       response to a claim of inability to pay unless the petitioner submits:
       (1) financial statements prepared according to generally accepted
       accounting practices (GAAP); or (2) some other reliable and objective
       documentation that accurately reflects the petitioner's current
       financial status. Any claim of inability to pay must specifically
       identify the basis for the claim by reference to the financial
       documentation submitted.

   28. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability
       for Forfeiture and Order shall be served on C.T.S. Technology Co.,
       Limited in accordance with U.S. and international law at 3F, OCT
       Building, No. 2010, Shennan Road E., Shenzhen, Guangdong, Peoples
       Republic of China, 518000 and to C.T.S. Technology, Co., Limited at Rm
       4B128, Pacific Security Market Bldg, Huanqiang Rd (N.), Futian,
       Shenzhen, 518031, Guangdong, People's Republic of China.

   FEDERAL COMMUNICATIONS COMMISSION

   Marlene H. Dortch

   Secretary

                                   APPENDIX A

                Sample of Illegally Marketed Jamming - AISWA.COM

   Marketing Image Product Name/ Description Marketed Frequency/ Services
   Jammed Date Marketing First Observed

   GPS GSM JAMMER CTS-3000A FOR GPS L1/ L2 GSM /CDMA /3G GPS, UHF, LoJack,
   3G, GSM, CDMA, DCS, WiFi 10/14/2011
   1~5m 5-Band Cigarette Cell Phone Jammer EST-808SC GSM, DCS, PHS, 3G, CDMA
   10/14/2011
   Super GPS Jammers 100W output up to 500~1000M range GPS, GSM 10/14/2011
   32w High Power Cell Phone Jammer GSM, CDMA, PCS, DCS, 3G 10/14/2011
   100m Shielding Range High Power (45W) Indoor mobile Phone Jammer CDMA,
   GSM, DCS, 3G 10/14/2011
   High power 25w GPS Jammer - Anti tracking GPS 10/14/2011
   24/7 working 5 bands GPS GSM/CDMA JAMMERS CTS-JX5000E with built-in
   battery GPS, GSM, CDMA 10/14/2011
   150W Powerful Cell Phone Bomb Jammer/blocker CTS-VIP150 CDMA, GSM, DCS,
   3G, GPS 10/14/2011
   180W High Power VHF UHF Jammer Bomb Jammer GSM, DCS, 3G 10/14/2011
   25W 6 bands FM 434 868 MID 433/868 MHz Cell phone Jammers FM, GSM, CDMA,
   3G 10/14/2011
   70W High Power Cell Phone Jammer for 4G Wimax with Omni- directional
   Antenna CDMA, GSM, DCS, PCS, 3G, 4G 6/9/2013
   Car remote control Jammer 303MHz/335MHZ/315MHZ/433MHz/868MHz 6/19/2013
   40W GPS L1 L2 GSM 3G Full bands Jammer GPS, GSM, CDMA, 3G 6/19/2013
   UHF VHF Jammer walkie-talkie Jammer with battery VHF, UHF, LoJack
   6/19/2013
   High Power 8 Antenna Cell Phone, 3G, WiFi, GPS, VHF, UHF Jammer CDMA, GSM,
   DCS, PCS, 3G, GPS, WiFi, VHF, UHF 6/19/2013
   Waterproof 75W High Power 3G Mobile Phone Signal Jammer CDMA, GSM, DCS,
   PHS, 3G 9/11/2013
   120W High Power Cellular Mobile Phone Jammer GSM, CDMA, PCS, DCS, 3G
   9/11/2013
   Waterproof Cell Phone Jammer (Worldwide use) AMPS, N-AMPS, NMT, TACS, GSM,
   CDMA, TDMA, IDEN, UMTS 9/11/2013
   Mini Medium Power Cellphone Jammer CDMA, GSM, DCS, PCS, 3G 9/11/2013
   70W High Power Cell Phone Jammer for 4G LTE with Omni-directional Antenna
   CDMA, GSM, DCS, PCS, 3G, 4G 9/11/2013
   Powerful Golden Portable Cell phone & Wi-Fi & GPS Jammer GPS, CDMA, DCS,
   GSM, CDMA, WiFi 9/11/2013
   Customized 5-Band Painting Cell Phone Jammer for 2G & 3G Network GSM,
   CDMA, DCS, PHS,3G 9/11/2013
   Adjustable 3G 4G Wimax Mobile Phone WiFi Signal Jammer with Bulit-in
   Directional Antenna GSM, CDMA, DCS, PCS, 3G, 4G WiMax, WiFi 9/11/2013
   Ultimate 8-Band Wireless Signal Terminator 2G, 3G, 4G, WiFi, UHF, VHF,
   GPS, LoJack 9/11/2013
   Portable GPS Jammer (GPSL1/L2) GPS 9/11/2013
   High Power 6 Antenna Cell Phone GPS WiFi VHF UHF Jammer GSM, 3G, WiFi,
   GPS, VHF, UHF 9/11/2013
   7W Powerful All GPS Signals Jammer (GPS L1,L2,L3,L4.L5) GPS 9/11/2013
   High Power Portable GPS (GPS L1/L2/L3/L4/L5) Jammer GPS 9/11/2013
   3-Band Civil GPS Tracker Preventer GPS 9/11/2013
   Vehicle Car Anti Tracker Mini GPS Jammer Blocker GPS 9/11/2013



   ^ We note, however, that there are several narrow exceptions that apply
   outside the context of U.S. consumer use. See 47 U.S.C. S 302a(c); 47
   C.F.R. S 2.807(b), (d). For example, in very limited circumstances and
   consistent with applicable procurement requirements, jamming devices may
   be marketed to the U.S. federal government for authorized, official use.
   See id.

   ^ See 47 U.S.C. SS 301, 302a, 333. As noted above, the Communications Act
   makes an exception from these prohibitions for devices to be used by the
   United States Government, and for devices manufactured solely for export.
   47 U.S.C. S 302a(c).

   ^ We note that the term "consumers," as used herein, refers to
   individuals, businesses, organizations, and state and local governments,
   among others.

   ^ See, e.g., Phonejammer.com, Notice of Apparent Liability for Forfeiture,
   25 FCC Rcd 3827 (Enf. Bur. 2010). See also 18 U.S.C. S 1362 (prohibits
   willful or malicious interference to U.S. government communications;
   subjects the operator to possible fines, imprisonment, or both); 18 U.S.C.
   S 1367(a) (prohibits intentional or malicious interference to satellite
   communications; subjects the operator to possible fines, imprisonment, or
   both).

   ^ See C.T.S. Technology website, available at
   http://www.CTStechnologys.com (last visited June 18, 2014); Aiswa website,
   available at http://www.aiswa.com (last visited June 18, 2014).

   ^ C.T.S. Technology also operates through the CTStechnologys.com website
   and markets its products on YouTube.com and Made-in-China.com.

   ^ C.T.S. Technology has maintained jammer advertisements targeted at U.S.
   consumers for more than two years and has continually increased the number
   of jammer offerings. A sample of the 285 signal jammers illegally offered
   for sale to U.S. consumers by C.T.S. Technology is provided in Appendix A
   to this NAL. See also Aiswa website, available at
   http://www.aiswa.com/category-18-b0-RF+signal+jammers.html (last visited
   June 18, 2014).

   ^ C.T.S. Technology lists in its specifications for a number of its signal
   jammers that they are "Approved: CE/FCC". See, e.g.,  Aiswa website,
   available at http://www.aiswa.com/goods-4760-High+Power+Cellular+Signal+
   Remote+Control+Jammer+.html (last visited June 18, 2014). As detailed
   infra, the signal jammers offered by C.T.S. Technology cannot be certified
   or authorized because their primary purpose is to block or interfere with
   authorized radio communications.

   ^ The signal jammers offered for sale by C.T.S. Technology on the
   www.Aiswa.com website include models described as "6 bands 25W waterproof
   GPS L1 L2 L5 GSM 3G Jammers," "5 Antenna Cell Phone jammer + Remote
   Control (3G, GSM, CDMA, DCS)," "Super GPS Jammers 100W output up to
   500-1000M range," "15-20m Portable WiFi and 3G Cellphone Signal Jammer,"
   and "Big power 3G Cell phone jammers with Battery."

   ^ See Aiswa website, available at
   http://www.aiswa.com/goods-1466-Super+GPS+Jammers+100W+
   output+up+to+500~1000M+range.html (last visited June 18, 2014) ("[Jams] up
   to a distance of 500-1000M. It simply plugs into an ordinary cigarette
   lighter socket and is active immediately blocking all types of tracking
   and navigational devices.").

   ^ See  Aiswa website, available at http://www.aiswa.com (last visited June
   18, 2014).

   ^  See, e.g., Aiswa website, available at
   http://www.aiswa.com/article-75-60W+Military+Communications+
   Jammers+Backpack+Jammer+CTSVIP6.html (last visited June 18, 2014) ("C.T.S
   Technology Co., Limited is a professional Military Jammer manufacturer and
   exporter in China. We are specializing in Military Jammer, Cell Phone
   Jammers and so on. These products are been delivered to Europe, United
   States, Asia, the Middle East, Russia, Africa etc. countries.").

   ^ Section 302(a) of the Communications Act authorizes the Commission to
   "make reasonable regulations governing the interference potential of
   devices which in their operation are capable of emitting radio frequency
   energy by radiation, conduction, or other means in sufficient degree to
   cause harmful interference to radio communications." 47 U.S.C. S 302a(a).
   Section 302(b) prohibits the advertising, sale, importation, and operation
   of any communications device that does not comply with the regulations
   adopted by the Commission pursuant to Section 302. 47 U.S.C. S 302a(b).

   ^ 47 U.S.C. S 333.

   ^ Id. S 302a(b).

   ^ 47 C.F.R. SS 2.803, 2.805, 2.807, 15.1(c), 15.3(o), 15.201.

   ^ Id. S 2.803(b)(1).

   ^ An "intentional radiator" is a "device that intentionally generates and
   emits radio frequency energy by radiation or induction." Id. S 15.3(o).

   ^ See id. S 15.201(b). Section 15.1(c) of the Rules also states that "the
   operation or marketing of an intentional . . . radiator that is not in
   compliance with the administrative and technical provisions in this part,
   including prior Commission authorization or verification, as appropriate,
   is prohibited under section 302 of the Communications Act of 1934, as
   amended, and [the Rules]." Id. S 15.1(c).

   ^ Id. S 2.803(a).

   ^ See 47 U.S.C. S 333. We note that numerous other countries also restrict
   civilian use or operation of signal jammers, including Canada, the United
   Kingdom, Germany, Switzerland, and Australia.

   ^ See The Supply Room, Inc., Notice of Apparent Liability for Forfeiture
   and Order, 28 FCC Rcd 4981, 4983-84, para. 7 (2013) (Supply Room NAL);
   Taylor Oilfield Mfg., Inc., Notice of Apparent Liability for Forfeiture
   and Order, 28 FCC Rcd 4972, 4975, para. 7 (2013) (Taylor Oilfield NAL).

   ^ See supra note 1.

   ^ See 47 C.F.R. S 2.803; see also infra note 30.

   ^  See infra Appendix A (sample of signal jammers marketed); Aiswa
   website, available at
   http://www.aiswa.com/category-18-b0-RF+signal+jammers.html (last visited
   June 18, 2014). In this regard, we note that C.T.S. Technology advertises
   in the English language, quotes prices in U.S. currency, accepts mailing
   addresses within the United States for the delivery of purchased goods
   through selection using a drop down menu and utilizes U.S. payment and
   delivery facilities to complete sales to individuals located in the United
   States. We also note that C.T.S. Technology consummated the sale of 10
   jamming devices to undercover Division personnel located in the United
   States.

   ^ See supra note 12.

   ^ See 47 U.S.C. S 302a(b); 47 C.F.R. SS 2.803, 15.201(b).

   ^ Section 312(f)(1) of the Act defines "willful" as "the conscious and
   deliberate commission or omission of [any] act, irrespective of any intent
   to violate" the law. 47 U.S.C. S 312(f)(1). The legislative history of
   Section 312 clarifies that this definition of willful applies to Sections
   312 and 503 of the Act, H.R. Rep. No. 97-765 (1982) (Conf. Rep.), and the
   Commission has so interpreted the term in the Section 503(b) context. See
   So. Cal. Broad. Co., Memorandum Opinion and Order, 6 FCC Rcd 4387,
   4387-88, para. 5 (1991) (Southern California), recons. denied, Memorandum
   Opinion and Order, 7 FCC Rcd 3454 (1992).

   ^ Section 312(f)(2) of the Act, which also applies to forfeitures assessed
   pursuant to Section 503(b) of the Act, defines "repeated" as "the
   commission or omission of [any] act more than once or, if such commission
   or omission is continuous, for more than one day." 47 U.S.C. S 312(f)(2);
   see also Southern California, 6 FCC Rcd at 4388, para. 5.

   ^ 47 U.S.C. S 503(b). The Act provides that parties who engage in
   activities for which an authorization is required may be subject to a
   forfeiture without a prior citation. 47 U.S.C. S 503(b)(5) (citation not
   required where "person involved is engaging in activities for which a
   license, permit, certificate, or other authorization is required."); see
   also Syntax-Brillian Corp., Forfeiture Order and Notice of Apparent
   Liability for Forfeiture, 23 FCC Rcd 6323, 6326, para. 8 (2008)
   (Syntax-Brillian FO) (noting that equipment certification is a "license,
   permit, certificate, or other authorization" for purposes of the exception
   to the citation requirement in Section 503(b)(5) of the Communications
   Act).

   ^ The Commission's Forfeiture Policy Statement and Amendment of Section
   1.80 of the Rules to Incorporate the Forfeiture Guidelines, Report and
   Order, 12 FCC Rcd 17087 (1997) (Forfeiture Policy Statement), recons.
   denied, 15 FCC Rcd 303 (1999); 47 C.F.R. S 1.80. In 2013, the Commission
   adjusted many of its base forfeiture amounts to account for inflation, but
   did not adjust the base forfeiture amount for marketing of unauthorized
   equipment. See Amendment of Section 1.80(b) of the Commission's Rules,
   Adjustment of Civil Monetary Penalties to Reflect Inflation, Order, 28 FCC
   Rcd 10785 (Enf. Bur. 2013) (2013 Amendment to Section 1.80(b) Order).

   ^ See 47 C.F.R. S 1.80(b)(8), Note ("The Commission and its staff retain
   the discretion to issue a higher or lower forfeiture than provided in the
   guidelines, to issue no forfeiture at all, or to apply alternative or
   additional sanctions as permitted by the statute.").

   ^ See Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110
   Stat. 1321 (codified as amended in scattered sections of 5, 26, 28, 31,
   and 41 U.S.C., including 28 U.S.C. S 2461 Note) (DCIA).

   ^ See 47 U.S.C. S 503(b); 47 C.F.R. S 1.80(b); see also 2013 Amendment of
   Section 1.80(b) Order, supra note 31. Specifically, as applicable here,
   Section of 503(b)(2)(D) of the Act initially established that "the amount
   of any forfeiture penalty determined under this subsection shall not
   exceed $10,000 for each violation or each day of a continuing violation,
   except that the amount assessed for any continuing violation shall not
   exceed a total of $75,000 for any single act or failure to act . . . . "
   47 U.S.C. S 503(b)(2)(D).  Pursuant to the DCIA, federal agencies, such as
   the FCC, are required to adjust civil monetary penalties at least once
   every four years to account for inflation.  See supra note 33. Based on
   this statutory authority, the Commission has adjusted for inflation the
   statutory maxima in Section 503(b)(2)(D) of the Act by amending Section
   1.80(b) of the Rules over the years.  Currently, under Section 1.80(b)(7),
   "the amount of any forfeiture penalty determined under [Section 1.80 of
   the Rules] shall not exceed $16,000 for each violation or each day of a
   continuing violation, except that the amount assessed for any continuing
   violation shall not exceed a total of $122,500 for any single act or
   failure to act . . . ."  See 47 C.F.R. S 1.80(b)(7). See also Section 2013
   Amendment of Section 1.80(b) Order, supra note 31.

   ^ See 47 C.F.R. S 1.80(b)(7); see also supra note 34.

   ^ 47 U.S.C. S 503; 47 C.F.R. S 1.80(b)(7). see also supra note 34. These
   amounts are subject to further adjustment for inflation and the forfeiture
   amount applicable to any violation will be determined based on the
   statutory amount designated at the time of the violation. See 47 C.F.R. S
   1.80(b)(9); see also supra note 31.

   ^ Cf. Phonejammer.com, 25 FCC Rcd 3827, supra note 4. In Phonejammer.com,
   the Bureau upwardly adjusted the base forfeiture of $7,000, which is
   applicable to typical equipment marketing violations, to $12,500 due to
   the retailer's continued marketing of signal jamming devices after its
   receipt of a Citation. Id. at 3834, para. 13. The Commission is taking
   more aggressive action in the instant case because vendors and
   manufacturers have not taken corrective action and continue to market
   signal jammers in violation of the Rules. We also note that the instant
   case is especially egregious given the lengthy duration of the violations,
   the high power level of some of the signal jammers offered for sale, and
   the number of signal jammers marketed and actually sold into the United
   States.

   ^ We assess the present forfeiture on a per model basis, as we have in
   other equipment marketing cases, to better reflect the seriousness of the
   violations and deter future misconduct. See Hauppauge Computer Works,
   Inc., Notice of Apparent Liability for Forfeiture and Order, 24 FCC Rcd
   5272, 5278-79, para. 18 (2009) ("We find that calculating forfeitures for
   violations of the DTV tuner requirement involving television receivers
   without an associated viewing screen on a per model basis will result in
   forfeiture amounts that reflect the seriousness of the violations will
   deter future misconduct."); Syntax-Brillian FO,  23 FCC Rcd 6323, supra
   note 30; Regent U.S.A., Inc., Notice of Apparent Liability for Forfeiture,
   22 FCC Rcd 10520 (2007); see also San Jose Navigation Inc., Notice of
   Apparent Liability for Forfeiture, 21 FCC Rcd 2873, 2877, para. 14 (2006)
   (finding that the marketing of each separate unauthorized model
   constitutes a separate violation); ACR Elec., Inc., Notice of Apparent
   Liability for Forfeiture, 19 FCC Rcd 22293, 22302, para. 23 (2004) (same),
   forfeiture ordered, Forfeiture Order, 21 FCC Rcd 3698 (2006) (forfeiture
   paid).

   ^ Illegal marketing was first observed on C.T.S. Technology's websites on
   October 14, 2011; was continually observed on numerous occasions
   throughout 2012 and 2013; and continues as of the release of this
   enforcement action. A sample of the 285 signal jammers illegally offered
   for sale to U.S. consumers by C.T.S. Technology is provided in Appendix A
   to this NAL. See also Aiswa website, available at
   http://www.aiswa.com/category-18-b0-RF+signal+jammers.html (last visited
   June 18, 2014).

   ^ 47 U.S.C. S 503(b)(2)(E).

   ^ See Supply Room NAL, 28 FCC Rcd at 4986-87, para. 14; Taylor Oilfield
   NAL, 28 FCC Rcd at 4977, para. 14; Gary P. Bojczak, Notice of Apparent
   Liability for Forfeiture, 28 FCC Rcd 11589, 11592-93, para. 10 (2013).
   Accord R&N Manufacturing, Ltd., Notice of Apparent Liability for
   Forfeiture, 29 FCC Rcd 3332 (2014) (R&N Manufacturing). See also 47 C.F.R.
   S 1.80(b)(8).

   ^ 47 U.S.C. S 503(b)(2). C.T.S. Technology has marketed a large number of
   signal jammers to U.S. consumers for well over two years. The most recent
   violations, involving 285 jammer models, have been ongoing for over eight
   months or 240 days, which yields a forfeiture calculation of $16,000 per
   day x 240 days = $3,840,000 per model (reduced to $122,500, the statutory
   cap) x 285 models = $34,912,500.

   ^ See R&N Manufacturing, 29 FCC Rcd at 3332, para. 3 ("We expect
   individuals and businesses, like RNM, to take immediate steps to ensure
   compliance and to avoid any recurrence of this type of misconduct,
   including ceasing operation of any signal jamming devices that may be in
   its possession, custody, or control."); Supply Room NAL, 28 FCC Rcd at
   4982, para. 3 (same); see also TD Spot Inc. dba Spy Spot Investigations,
   Citation and Order, 27 FCC Rcd 7642, 7642, para. 2 (Enf. Bur. 2012)
   (ordering retailer of jamming devices to "take immediate steps to come
   into compliance and to avoid any recurrence of [the] misconduct, including
   actions such as removing illegal signal jamming devices from displays and
   declining to sell signal jamming devices in the United States").

   ^ See Illegal Marketing of Signal Jamming Devices, Omnibus Citation and
   Order, 26 FCC Rcd 13565,13566, para. 2 (Enf. Bur. 2011) (Omnibus Citation)
   ("Each Online Vendor must take immediate steps to cease marketing signal
   jamming devices to consumers in the United States and its territories and
   to avoid any recurrence of this misconduct. This may include actions such
   as removing the illegal signal jamming devices from online display,
   expressly excluding consumers in the United States and its territories as
   potential customers, and declining to sell signal jamming devices or
   complete any sales transaction to consumers in the United States and its
   territories."). See also Behringer U.S.A., Inc., Notice of Apparent
   Liability for Forfeiture, 21 FCC Rcd 1820, 1829, para. 24 (2006) (ordering
   retailer to produce an affidavit within 30 days confirming compliance with
   the Act and Rules with respect to each model of unauthorized radio
   frequency devices that it was found to have been illegally importing and
   marketing in the United States, and if not, providing plans for full
   compliance); St. George Cable, Inc., Notice of Apparent Liability for
   Forfeiture and Order, 27 FCC Rcd 11447 (2012) (proposing a forfeiture
   against cable operator for failing to comply with prior order requiring
   installation of an operational Emergency Alert System equipment, that it
   operate its cable system within required signal leakage limits, and to
   immediately suspend operations until it received written authorizations
   from the Commission; further order issued requiring operator to confirm
   within 30 days that it was now in full compliance with FCC rules).

   ^ We order the production of this information pursuant to our authority
   under Sections 1, 4(i), 4(j), and 403 of the Act. 47 U.S.C. SS 151,
   154(i), 154(j), 403. See Supply Room NAL, 28 FCC Rcd at 4982, para. 3
   (seeking information concerning the source from which it purchased or
   received jamming devices); Taylor Oilfield NAL, 28 FCC Rcd at 4973, para.
   3 (same); Omnibus Citation, 26 FCC Rcd at 13566, para. 3 (seeking a report
   on the specific actions taken to correct the violations; information
   concerning signal jamming device suppliers, distribution channels, and
   sales; and information on websites that have been used to market the
   devices in the United States or its territories). See also Behringer
   U.S.A., Inc., 21 FCC Rcd at 1829, para. 24; SBC Communications, Inc.,
   Notice of Apparently Liability for Forfeiture and Order, 16 FCC Rcd 19091,
   19126, para. 27 (2001) (ordering carrier to file detailed reports
   regarding future compliance).

   ^ 47 U.S.C. SS 302a(b), 503(b); 47 C.F.R. SS 1.80, 2.803, 15.201(b).

   ^ 47 U.S.C. SS 151, 154(i)-(j), 302a(b), 403.

   ^ 47 C.F.R. SS 2.803, 15.201(b).

   ^ An FCC Form 159 and detailed instructions for completing the form may be
   obtained at http://www.fcc.gov/Forms/Form159/159.pdf.

   ^ See 47 C.F.R. S 1.1914.

   ^ 47 C.F.R. SS 1.16, 1.80(f)(3).

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   Federal Communications Commission FCC 14-92

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   Federal Communications Commission FCC 14-92