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Federal Communications Commission DA 16-252
1
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
R & N Manufacturing, Ltd.
Houston, Texas
)
)
)
)
)
)
)
File No.:  EB-FIELDSCR-13-00007653
NAL/Acct. No.:  201432540002
FRN:  0023432966
ORDER
Adopted:  March 22, 2016 Released:  March 22, 2016
By the Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission has 
entered into a Consent Decree to resolve its investigation into R & N Manufacturing, Ltd.’s (RNM) 
operation of a cellular phone jamming device in its manufacturing facility in Houston, Texas in 2013.  
Signal jamming devices overpower, jam, or interfere with authorized wireless communications.  In order 
to protect the public and preserve unfettered access to emergency and other communications services, the 
Communications Act and Commission regulations broadly prohibit the importation, use, marketing, 
manufacture, and sale of jamming devices. 
2. In its response to the Commission’s Notice of Apparent Liability for Forfeiture (NAL),
1
RNM provided the Bureau with detailed information about its use of the jamming device at issue.
2
Specifically, it stated that it used the jamming device for only four days, not the 10 days indicated in the 
NAL, and provided a sworn supporting statement from the company’s Chief Financial Officer. RNM also 
stressed that it had cooperated with Commission agents, surrendered the jamming device, and is a small 
company that had not previously violated any communications laws. To settle this matter, RNM admits 
that it violated the laws and regulations that prohibit the use of signal jamming devices, will comply with 
these rules in the future, and will pay $9,750 in civil penalties.  
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 resolving the NAL
against RNM regarding its use of a signal jamming device as prohibited by the Communications Act of 
1934, as amended, (Act)
3
and the Commission’s rules (Rules).
4
4. In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of RNM’s basic qualifications to hold or obtain any Commission license or authorization.
5
                                                     
1
R&N Manufacturing, Ltd., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 3332 (2014).  
2
See Letter from Raymond L. Kalmans, Esq., Counsel to RNM, to Houston Office, South Central Region, 
Enforcement Bureau, Federal Communications Commission (Apr. 24, 2014).
3
47 U.S.C. § 301, 302a(b), 333.
4
47 C.F.R. § 2.805, 15.1(c).
5
See 47 C.F.R. § 1.93(b).
Federal Communications Commission DA 16-252
2
5. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i), and 503(b) of the Act
6
and the authority delegated by Sections 0.111 and 0.311 of the Rules,
7
the attached Consent Decree IS 
ADOPTED and its terms incorporated by reference.
6. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED and 
the NAL IS CANCELED.
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 Sherry Noppe, CFO, R & N 
Manufacturing, Ltd., 6417 Cunningham Road, Houston, TX 77041, and its counsel, Raymond Kalmans, 
Esq., Schlanger Silver Barg & Paine, LLP, 109 N. Post Oak Lane, Suite 300, Houston, Texas 77024-
7755.
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief
Enforcement Bureau
                                                     
6
47 U.S.C. §§ 154(i), 503(b).
7
47 C.F.R §§ 0.111, 0.311.
Federal Communications Commission DA 16-252
3
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
R & N Manufacturing, Ltd.
Houston, Texas
)
)
)
)
)
File No.:  EB-FIELDSCR-13-00007653
NAL/Acct. No.:  201432540002
FRN:  0023432966
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and R & N 
Manufacturing, Ltd. (RNM), by their authorized representatives, hereby enter into this Consent Decree 
for the purpose of terminating the Enforcement Bureau’s investigation into whether RNM violated 
Sections 301, 302(b) and 333 of the Communications Act of 1934, as amended,
8
and Sections 2.805(a) 
and 15.1(c) of the Commission’s rules,
9
in connection with RNM’s operation of a cellular phone jamming 
device in its manufacturing facility in Houston, Texas.
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended.
10
(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) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which RNM is subject 
by virtue of its business activities.
(f) “Compliance Commitment” means the compliance obligations described in this 
Consent Decree at paragraph 11.
(g) “RNM” means R & N Manufacturing, Ltd., as well as its affiliates, subsidiaries, 
predecessors-in-interest, and successors-in-interest.
(h) “Effective Date” means the date by which both the Bureau and RNM have signed 
the Consent Decree.
(i) “Investigation” means the investigation into RNM’s apparent violations of the Act 
commenced by the Bureau’s initial Inquiry in EB-FIELDSCR-13-00007653.
(j) “Jammer Laws” means Sections 301, 302(b) and 333 of the Act, Sections 2.805(a) 
and 15.1(c) of the Rules, and other Communications Laws that prohibit the use or 
operation of a cellular phone jamming device or other signal jamming device.
                                                     
8
47 U.S.C. §§ 301, 302a(b), and 333.
9
47 C.F.R. §§ 2.805(a) and 15.1(c).
10
47 U.S.C. § 151 et seq.
Federal Communications Commission DA 16-252
4
(k) “NAL” means RNM’s Notice of Apparent Liability for Forfeiture issued on March 
26, 2014.
11
(l) “Parties” means RNM and the Bureau, each of which is a “Party.”
(m)“Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
II. BACKGROUND
3. Section 301 of the Act prohibits the use or operation of “any apparatus for the 
transmission of energy or communications or signals by radio” within the United States unless such use is 
licensed or authorized.
12
  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 
comply with regulations promulgated pursuant to this section.”
13
  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 chapter or operated by the United States 
government.”
14
  
4. On April 10, 2012, a Commission agent determined that one or more signal jamming 
devices were in use at RNM’s manufacturing facility in Houston Texas. The agent interviewed RNM’s 
chief financial officer (CFO), who admitted to the agent that RNM was using a cellular jamming device to 
block cell phone communications, thereby preventing employees from placing wireless calls at 
work. RNM’s CFO stated that RNM would discontinue using jamming devices, and RNM subsequently 
surrendered the jamming device to Commission agents. On March 26, 2014, the Commission issued the 
NAL against RNM for these apparent violations of the Jammer Laws.
5. RNM responded to the NAL on April 24, 2014.
15
In its response, RNM admitted using 
the jamming device, but argued for a reduction of the proposed forfeiture.  It reports to have used the 
jamming device only during working hours, not on weekends, and that the device had been used four 
days, not 10 days as stated in the NAL.  As evidence, RNM provided a sworn statement from the CFO 
stating that, although she did not have a record of the exact date of installation, she believed the jammer 
was installed and activated on March 27, 2012.  RNM also highlighted that it had cooperated with the 
Commission agents and surrendered the jamming device. RNM further stressed that it is a small 
company and had not previously violated the Communications Laws. Subsequently, RNM and the 
Bureau engaged in settlement negotiations. The Bureau and RNM agree to the following terms and 
conditions of settlement and hereby enter into this Consent Decree as provided herein.   
III. TERMS OF AGREEMENT
6. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.
7. Jurisdiction.  RNM 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.
                                                     
11
R&N Manufacturing, Ltd., 29 FCC Rcd 3332 (2014).
12
47 U.S.C. § 301.
13
Id. § 302a(b).
14
Id. § 333.
15
See Letter from Raymond L. Kalmans, Esq., Counsel to RNM, to Houston Office, South Central Region, 
Enforcement Bureau, Federal Communications Commission (Apr. 24, 2014).
Federal Communications Commission DA 16-252
5
8. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.  
9. 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 the Investigation, RNM agrees to the 
terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the absence of new 
material evidence, it will not use the facts developed in the 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 RNM 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 the Investigation through the Effective Date, or the existence of this Consent 
Decree, to institute on its own motion any proceeding, formal or informal, or to set for hearing the 
question of RNM’s basic qualifications to be a Commission licensee or hold Commission licenses or 
authorizations.
16
10. Admission of Liability.  RNM admits for the purpose of this Consent Decree and for 
Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 9 herein,
that its actions that were the subject of the NAL violated the Jammer Laws.  
11. Compliance Commitment.  RNM has ceased using or operating and will not use or 
operate in the future any cellular jamming device or other illegal jamming device.  Any use or operation 
of a jamming device by RNM will violate the Jammer Laws and the terms of this Consent Decree.  RNM
shall report any noncompliance with the Jammer Laws or with the terms and conditions of this Consent 
Decree within fifteen (15) calendar days after discovery of such noncompliance to Chief, Spectrum 
Enforcement Division, Enforcement Bureau, Federal Communications Commission, 445 12th Street, SW, 
Washington, DC 20554, with a copy submitted electronically to JoAnn Lucanik at
JoAnn.Lucanink@fcc.gov and Maureen McCarthy at Maureen.McCarthy@fcc.gov.  
12. Termination Date. Unless stated otherwise, the requirements set forth in paragraph 11 
shall expire thirty-six (36) months after the Effective Date.
13. Civil Penalty.  RNM will pay a civil penalty to the United States Treasury in the amount 
of nine thousand seven hundred and fifty dollars ($9,750) within 30 calendar days after the Effective 
Date.  RNM shall send electronic notification of payment to JoAnn Lucanik at JoAnn.Lucanink@fcc.gov, 
Maureen McCarthy at Maureen.McCarthy@fcc.gov, and Samantha Peoples at Sam.Peoples@fcc.gov on 
the date said payment is made.  The payment must be made by check or similar instrument, wire transfer, 
or credit card, and must include the NAL/Account Number and FRN referenced above.  Regardless of the 
form of payment, a completed FCC Form 159 (Remittance Advice) must be submitted.
17
  When 
completing the FCC Form 159, enter the NAL/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 that should be followed based on the form of payment selected:
? 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.
                                                     
16
See 47 C.F.R. § 1.93(b).
17
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
Federal Communications Commission DA 16-252
6
? 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 (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.
Questions regarding payment procedures should be addressed to the Financial Operations Group Help 
Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
14. Waivers.  As of the Effective Date, RNM 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.  RNM 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 Consent 
Decree or the Adopting Order, neither RNM nor the Commission shall contest the validity of the Consent 
Decree or the Adopting Order, and RNM shall waive any statutory right to a trial de novo.  RNM hereby 
agrees to waive any claims it may otherwise have under the Equal Access to Justice Act
18
relating to the
matters addressed in this Consent Decree.  
15. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
16. 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.
17. 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 RNM does not expressly 
consent), that provision will be superseded by such Rule or Order.
18. Successors and Assigns.  RNM agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees.
19. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall
constitute a final settlement between the Parties with respect to the Investigation.
20. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
21. 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.
22. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
                                                     
18
See 5 U.S.C. § 504; 47 C.F.R. §§ 1.1501–1.1530.
Federal Communications Commission DA 16-252
7
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions.
23. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
______________________________ __________________________
Travis LeBlanc, Chief Sherry Noppe, CFO
Enforcement Bureau R & N Manufacturing, Ltd.
Date:  _________________________ Date:  _____________________