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Federal Communications Commission FCC 16-67
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
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File No.:  EB-SED-12-00005692
NAL/Acct. No.:  201432100017
FRN:  0023572043
FORFEITURE ORDER
Adopted:  May 24, 2016 Released:  May 25, 2016
By the Commission:
1. We impose a penalty of $34,912,500 against C.T.S. Technology Co., Limited, (C.T.S. 
Technology) for marketing 285 models of signal jamming devices to U.S. consumers via its Aiswa.com 
website.  These devices, which were advertised for sale to U.S. consumers, were designed to disrupt a 
variety of communications systems, including all major cellphone networks, Wi-Fi systems, and even 
Global Positioning System (GPS) channels.  Some of the more dangerous devices were advertised as 
having the capacity to jam communications for a distance of over one-half mile.  C.T.S. Technology in 
fact sold several of these high-powered jamming devices to undercover FCC personnel, who had posed as 
consumers, and shipped the equipment to the United States.
2. Signal jamming devices overpower, jam, or interfere with authorized communications.  
They can endanger life and property by preventing individuals from making 9-1-1 or other emergency 
calls, interfering with the communications of first responders such as police officers and firefighters, or 
disrupting the basic communications essential to aviation and marine safety.  Jammers also prevent 
consumers and businesses from engaging in numerous, daily lawful forms of communications, ranging 
from simple one-on-one phone conversations to the use of GPS-based map applications to social media 
use.  For these reasons, signal jammers are illegal.  They may not be marketed to the public and have no 
lawful consumer use within the United States.
1
3. On June 18, 2014, the Commission issued a Notice of Apparent Liability for Forfeiture
2
(NAL) proposing a $34,912,500 forfeiture against C.T.S. Technology for willful and repeated violation 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,
3
for marketing illegal radio frequency devices to consumers in the United States.  
Copies of the NAL in English and Simplified Chinese were transmitted to the Chinese government for 
                                                     
1
See, e.g., Cell Jammers, GPS Jammers and Other Jamming Devices, FCC Enforcement Advisory, 27 FCC Rcd 
2309 (2012) (warning both consumers and retailers that jammers may not be advertised or imported in the United 
States). In very limited circumstances and consistent with applicable procurement requirements, jamming devices 
may be marketed to and used by the U.S. federal government for authorized, official use.  See 47 U.S.C. § 302a(c).
2
The NAL includes a more complete discussion of the facts and history of this case and is incorporated herein by 
reference.  C.T.S. Technology Co., Limited, Notice of Apparent Liability for Forfeiture and Order, 29 FCC Rcd 8107 
(2014).
3
47 U.S.C. § 302a(b); 47 C.F.R. §§ 2.803, 15.201(b).
Federal Communications Commission FCC 16-67
2
service on C.T.S. Technology, at its last known address, in accordance with methods prescribed by 
international law.
4
  While C.T.S. Technology has neither filed a response to the NAL nor paid the 
proposed forfeiture, we observe that the press has reported the Chief Executive Officer of C.T.S.
Technology was aware of the issuance of the NAL when it was released,
5
and that C.T.S. Technology 
subsequently took certain actions, consistent with the requirements set forth in the NAL, to come into 
compliance with U.S. law and ensure that the company does not again make an illegal sale of signal 
jamming devices within the United States.
6
  To date, however, we have received no official confirmation 
from the International Legal Cooperation Center of China’s Ministry of Justice that the NAL was 
successfully served on C.T.S. Technology.
4. Despite the lack of official confirmation of service, The Hague Service Convention 
expressly provides that a default judgment may be entered when service of a document cannot be 
confirmed within a reasonable period of time of no less than six months, provided that “every reasonable 
effort” has been made to obtain a certificate of service through the competent authorities of the State in 
which the document is to be served.
7
  On March 6, 2015, the International Legal Cooperation Center of 
the Ministry of Justice, which China has designated as its central authority for administering foreign 
requests for service of process, received the NAL and related materials in the manner required by The 
Hague Service Convention.
8
  On four subsequent occasions—November 10, 2015, December 1, 2015, 
                                                     
4
See generally, The Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or 
Commercial Matters, Nov. 15, 1965, 20 U.S.T. 361, 658 U.N.T.S. 163 (treaty specifying the means by which 
documents may be transmitted for service upon litigants in signatory states) (The Hague Service Convention). 
5
On the day that the NAL was released and published on the FCC website, the company’s Chief Executive Officer 
was quoted as saying that he had not yet received a copy of the document, adding that his company “rarely sells 
jamming devices to the U.S.”  Thomas Gryta and Gautham Nagesh, FCC Levels Record Fine Against Maker of 
Cellphone Jammers, The Wall Street Journal (Tech), (June 19, 2014), http://www.wsj.com/articles/fcc-levels-
record-fine-against-chinese-maker-of-cellphone-jammers-1403205812.
6
After release of the NAL, at least one of C.T.S. Technology’s own web sites, the ctstechologys.com webpage, was 
revised to add a hyperlink directing its website visitors to an FCC jammer enforcement webpage that published the 
NAL and to expressly warn potential U.S. customers that, to comply with FCC regulations, signal jamming devices 
would only be sold to authorized government agencies.  See Attention for Jammer, 
http://ctstechologys.com/attention-jammer (follow “http://www.fcc.gov/encyclopedia/jammer-enforcement” 
hyperlink) (last visited June 18, 2015); cf. NAL, 29 FCC Rcd at 8114, para. 20 (ordering the company to implement 
all necessary measures to prevent future sales of jamming devices to U.S. consumers).  This webpage further notes 
that the company’s order processing system will automatically exclude U.S. addresses.  Id.
7
The Hague Service Convention provides, in relevant part:
Each contracting State shall be free to declare that the judge, notwithstanding the provisions of the first 
paragraph of this article, may give judgment even if no certificate of service or delivery has been 
received, if all the following conditions are fulfilled –
(a) the document was transmitted by one of the methods provided for in this Convention,
(b) a period of time of not less than six months, considered adequate by the judge in the particular 
case, has elapsed since the date of the transmission of the document,
(c) no certificate of any kind has been received, even though every reasonable effort has been made to 
obtain it through the competent authorities of the State addressed.
Hague Service Convention, 20 U.S.T. 361, art. 15, para. 2; see id. at Declarations Table (documenting that China 
and the United States have each adopted this proviso).
8
According to The Hague Service Convention website, the relevant Chinese authorities report that requests for 
service in China are generally executed within three to four months.  See China—Central Authority & practical 
information, https://www.hcch.net/en/states/authorities/details3/?aid=243.  Survey data from 2013, the most recent 
available, instead indicates that only half of the requests for service are executed within six months, and 31% of 
(continued….)
Federal Communications Commission FCC 16-67
3
January 16, 2016, and February 26, 2016—Commission personnel successfully communicated with the 
authority but were unable to obtain the certificate of service from the authority or to expedite its return.  
Accordingly, more than one year after the NAL was transmitted via the methods provided for in The 
Hague Service Convention, the Commission concludes that it has made every reasonable effort to obtain 
the certificate.
9
  Despite these efforts, the Commission has received no certificate of any kind from 
China’s designated authority for these matters.  Consequently, we find it appropriate to enter a default 
judgment against C.T.S. Technologies.  Thus, based on the information before us, we affirm the forfeiture 
proposed in the NAL.
5. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended (Act)
10
and Section 1.80 of the Commission’s rules (Rules),
11
C.T.S. Technology 
Co., Limited IS LIABLE FOR A MONETARY FORFEITURE in the amount of thirty-four million 
nine hundred and twelve thousand and five hundred dollars ($34,912,500) for willfully and repeatedly 
violating Section 302(b) of the Communications Act of 1934, as amended,
12
and Sections 2.803 and 
15.201(b) of the Commission’s rules.
13
6. Payment of the forfeiture shall be made in the manner provided for in Section 1.80 of the 
Rules within thirty (30) calendar days after the release date of this Forfeiture Order.
14
  If the forfeiture is 
not paid within the period specified, the case may be referred to the U.S. Department of Justice for 
enforcement of the forfeiture pursuant to Section 504(a) of the Act.
15
7. Payment of the forfeiture must be made by check or similar instrument or wire transfer, 
and must include the NAL/Account Number and FRN referenced in the caption above.  C.T.S. 
Technology Co., Limited shall send electronic notification of payment to the Spectrum Enforcement 
Division at jammerinfo@fcc.gov on the date said payment is made.  Regardless of the form of payment, a 
completed FCC Form 159 (Remittance Advice) must be submitted.
16
  When completing the Form 159, 
enter the Account Number in block number 23A (call sign/other ID) and enter the letters “FORF” in 
(Continued from previous page)                                                            
requests remain “pending” more than a year after submission.  See Details, https://www.hcch.net/en/publications-
and-studies/details4/?pid=6042&dtid=33 (follow “China: Mainland” hyperlink).
9
In the first of several attempts to obtain the certificate, we asked the authority whether service had been achieved 
and when the Commission should expect the certificate of service to arrive.  We expressly asked that the authority 
please contact us if we could be of any assistance in expediting the return of the certificate.  The authority responded 
that the case was registered and was being processed by the court system and that it would notify the Commission 
when service was completed.  In response to our next inquiry, the authority advised only that the court had not yet 
responded.  In response to a third inquiry, the authority advised that the court system was still processing.  However, 
we also asked:  1) whether it would be permissible or useful to contact the court directly; 2) if permissible, to which 
individual and email address should the inquiry be directed, and 3) whether the authority could offer any additional 
guidance on how to obtain the certificate of service.  The authority provided a name but stated that the individual 
speaks only Mandarin, provided a phone number in the Beijing time zone rather than an email address, and added 
that the court does not prefer direct inquiry from foreign parties.  As of this writing, the Commission has received no 
response to its fourth attempt to obtain the certificate of service.
10
47 U.S.C. § 503(b).
11
47 C.F.R. § 1.80.
12
47 U.S.C. § 302a(b).
13
47 C.F.R. §§ 2.803, 15.201(b).
14
47 C.F.R. § 1.80.
15
47 U.S.C. § 504(a).
16
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 FCC 16-67
4
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.
? 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.
8. 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, SW, Room 1-A625, Washington, DC 20554.
17
  Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by telephone, 1-877-480-3201, or by e-mail, 
ARINQUIRIES@fcc.gov.
9. IT IS FURTHER ORDERED that, in accordance with U.S. and international law, a 
copy of this Forfeiture Order SHALL BE SERVED on C.T.S. Technology Co., Limited, by transmitting 
copies of this Order (one in English and one translated into Simplified Chinese), along with any requisite 
fee and procedural paperwork, to the Ministry of Justice, International Legal Cooperation Center, No. 6 
Chaoyangmen Nandajie, Chaoyang District, Beijing 100020, People’s Republic of China, and requesting 
that these copies of the Order be served on C.T.S. Technology Co., Limited at the following addresses:
(a) 3F, OCT Building, No. 2010, Shennan Road E., Shenzhen, Guangdong, People’s Republic of China, 
518000, and (b) 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
                                                     
17
See 47 C.F.R. § 1.1914.