Welcome Back To The Wireless Messaging News

I have three friends that I go to for technical advice about paging systems. Each of them are experts that I trust—although each of them have different skill sets. FYI, they are:

• Ron Mercer
• Allan Angus
• Ira Wiesenfeld

There are lots of others who are equally talented, but I don't bother them so much with my questions. To name just a few:

• Jim Nelson
• Vaughan Bowden
• Barry Kanne
• Vic Jackson
• Jay Moskowitz

In the last issue I expressed my opinion that Google was eliminating Instant Search, the smart feature that gives users search results while they are still typing, because (I thought) someone finally figured out how much extra traffic this feature added to the overall total Internet traffic, and how much it was costing the ISP's (Internet Service Providers) to provide the additional capacity.

“The way of a fool is right in his own eyes, But a wise man is he who listens to counsel.” — Proverbs 12:15 NASB

So I asked Allan Angus to grade my paper. Here is his response:

[I]n general, I might offer that one can make a distinction between channel capacity, say in bits/s, and signal bandwidth, also in bits/s. Shannon's great contribution was to propose that a channel with a given capacity could transmit a signal a with a bandwidth less than that capacity in an error free manner with the right coding. 

To your observation about Google's predictive search, I'm not sure that it would constitute a wide bandwidth signal. If I think about what is transmitted back and forth, it doesn't seem to be so much. For each character that the browser sends, the Google server responds with an updated short list of search responses that are just a sequence of characters, albeit longer than the single character from the browser. Still, the information content of the entire page would be less than a modest JPG encoded image and certainly less than a small video of the sort that constantly pops up as you scroll through Facebook now. 

I can only imagine that the computing horsepower that Google would churn through at its end to execute any predictive search must be significant. My guess is that the rendering of the browser screen would be done with a local PHP script that would consume a modest amount of computer power too. 

However I don't think that the back and forth character streams would represent a huge proportion of the available Internet capacity. If I had to venture a guess, that would be video of all sorts, Netflix, YouTube, porn, Amazon Prime video. 

New GPS receivers installed after 911 outage

by CBS21 WEB STAFF
Tuesday, August 1st 2017

YORK, Pa — New GPS receivers have been installed at seven tower sites after a 9-1-1 paging outage in York County.

Officials say this will allow them to synchronize and get closer to the level of performance they're trying to get back to.

They say it is still unknown when they'll get the rest of the order. The Strinestown Fire Chief says the outage has taken a toll on the staff.

They are all volunteers and some of them have had to stay on duty much longer than normal.

[source]

Honolulu to impose fines on those who use phones [or pagers] while walking.

Now on to more news and views.

Wayne County, Illinois

Emergency Radio Communications Wireless Messaging Critical Messaging Two-way Radio Technology Telemetry Science Paging Wi-Fi

Wireless Messaging

This doesn't mean that nothing is ever published here that mentions a US political party—it just means that the editorial policy of this newsletter is to remain neutral on all political issues. We don't take sides.

A new issue of the Wireless Messaging Newsletter is posted on the web each week. A notification goes out by e-mail to subscribers on most Fridays around noon central US time. The notification message has a link to the actual newsletter on the web. That way it doesn’t fill up your incoming e-mail account.

There is no charge for subscription and there are no membership restrictions. Readers are a very select group of wireless industry professionals, and include the senior managers of many of the world’s major Paging and Wireless Messaging companies. There is an even mix of operations managers, marketing people, and engineers — so I try to include items of interest to all three groups. It’s all about staying up-to-date with business trends and technology.

I regularly get readers’ comments, so this newsletter has become a community forum for the Paging, and Wireless Messaging communities. You are welcome to contribute your ideas and opinions. Unless otherwise requested, all correspondence addressed to me is subject to publication in the newsletter and on my web site. I am very careful to protect the anonymity of those who request it.

I spend the whole week searching the Internet for news that I think may be of interest to you — so you won’t have to. This newsletter is an aggregator — a service that aggregates news from other news sources. You can help our community by sharing any interesting news that you find.

Editorial Opinion pieces present only the opinions of the author. They do not necessarily reflect the views of any of advertisers or supporters. This newsletter is independent of any trade association. I don't intend to hurt anyone's feelings, but I do freely express my opinions.

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Modern Alerting Solutions in the Era of LTE

Published on Jul 28, 2017

Zacks Investment Research Upgrades SK Telecom Co., Ltd. (NYSE:SKM) to Strong-Buy

Posted by Casey Walker on Aug 3rd, 2017

SK Telecom Co., Ltd. (NYSE:SKM) was upgraded by Zacks Investment Research from a “hold” rating to a “strong-buy” rating in a research note issued to investors on Tuesday. The brokerage presently has a $32.00 target price on the Wireless communications provider’s stock. Zacks Investment Research‘s price objective suggests a potential upside of 14.78% from the stock’s current price.

According to Zacks, “SK Telecom Co. is the world’s first commercial CDMA digital cellular service. As of September 30, 1997, they have provided the highest quality service for more than 4 million cellular customers which includes 2.3 million digital cellular customers, and 7.1 million paging customers.

Other equities analysts have also recently issued reports about the stock. Citigroup Inc. reaffirmed a “neutral” rating on shares of SK Telecom Co. in a research note on Monday, April 24th. Credit Suisse Group cut shares of SK Telecom Co. from an “outperform” rating to a “neutral” rating in a research note on Tuesday, May 30th. BidaskClub cut shares of SK Telecom Co. from a “buy” rating to a “hold” rating in a research note on Wednesday, July 12th. Finally, Goldman Sachs Group, Inc. (The) raised shares of SK Telecom Co. from a “neutral” rating to a “buy” rating in a research note on Friday, July 21st. Three investment analysts have rated the stock with a hold rating, two have issued a buy rating and one has assigned a strong buy rating to the stock. The company presently has a consensus rating of “Buy” and an average price target of $32.00.

Shares of SK Telecom Co. (NYSE SKM) opened at 27.88 on Tuesday. The company has a market capitalization of $17.73 billion, a P/E ratio of 11.87 and a beta of 0.34. The firm’s 50 day moving average is $25.71 and its 200-day moving average is $24.09. SK Telecom Co. has a 52-week low of $20.44 and a 52-week high of $28.13.

Several institutional investors have recently modified their holdings of the company. Bessemer Group Inc. boosted its position in shares of SK Telecom Co. by 68.6% in the second quarter. Bessemer Group Inc. now owns 4,536 shares of the Wireless communications provider’s stock valued at $116,000 after buying an additional 1,845 shares in the last quarter. Rational Advisors LLC acquired a new position in shares of SK Telecom Co. during the second quarter valued at $139,000. Cypress Capital Management LLC WY acquired a new position in shares of SK Telecom Co. during the second quarter valued at $145,000. Mirador Capital Partners LP acquired a new position in shares of SK Telecom Co. during the first quarter valued at $203,000. Finally, Paloma Partners Management Co acquired a new position in shares of SK Telecom Co. during the first quarter valued at $203,000. 11.74% of the stock is owned by institutional investors.

About SK Telecom Co.

SK Telecom Co, Ltd. provides wireless telecommunications in Korea. The Company is engaged in the commercial development and implementation of wireless and fixed-line technologies and services, as well as develop its platforms, including Internet of things (IoT) solutions, lifestyle enhancement and advanced media.

Enhancing Mobile Alert Response

sales@wirelessmessaging.com
800-373-1466
2630 National Dr., Garland, TX 75041

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MARS (Mobile Alert Response System)

• Paging Protocol Monitoring and Wireless Sensor Monitoring (Inovonics and Bluetooth LE)
• Improves Mobile Response Team Productivity using Smartphone App
• Low-Latency Alerts using Pagers, Smartphones, Browsers, and Digital Displays
• Automated E-mail Based Alert Response and System Status Reports
• Linux Based Embedded System with Ethernet and USB Ports
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• Mobile Resident Call and Wandering Resident Tracking with Bluetooth Beacons
• SMTP and SIP Inputs and XMPP Output in Development

STG (SIP to TAP Gateway)

• Monitors Rauland Nurse Call SIP Protocol
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• Linux Based Embedded System
  
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Easy Solutions provides cost effective computer and wireless solutions at affordable prices. We can help in most any situation with your communications systems. We have many years of experience and a vast network of resources to support the industry, your system and an ever changing completive landscape.

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FCC Continues Path to Eventual 6.25 kHz Narrowbanding

By Greg Kunkle
Tuesday, August 01, 2017

One question clients frequently ask me is “When is the FCC going to require VHF and UHF land mobile users to transition to 6.25-kilohertz technology?” When and how the transition to 6.25 kilohertz will happen is anyone’s guess. But the FCC does continue to remind licensees that the transition is still in the commission’s future plans. The most recent example came just a few weeks ago in the FCC’s June 30 order denying a request for waiver filed by the International Municipal Signal Association (IMSA). IMSA had sought a waiver of the FCC’s prohibition against certification of VHF and UHF (150.80 – 162.0125, 173.20 – 173.40 and 421 – 512 MHz) LMR equipment that is not capable of operating on 6.25-kilohertz channels or with equivalent efficiency. IMSA requested the certification requirement deadline be extended until at least January 2020.

This began more than 20 years ago in 1995, when the commission announced that as of Jan. 1, 2005, it would no longer certify equipment that could not operate on 6.25-kilohertz channels or with equivalent efficiency. This deadline was later pushed back several times until it finally took effect Jan. 1, 2015. The prohibition does not actually require users to operate in 6.25-kilohertz mode. Also, equipment certified prior to the deadline may still be sold, whether or not the device has 6.25-kilohertz capability. But any manufacturer seeking to obtain certification for new equipment or making changes to an existing model that requires recertification must include the capability to operate in 6.25-kilohertz mode or equivalent efficiency.

In its waiver request, IMSA argued that the commission’s certification deadline effectively required new radios to be digital because analog technology generally does not meet the 6.25-kilohertz requirement. IMSA claimed that the “6.25-kilohertz channelization requirement prevents manufacturers from improving current products” unless they also include 6.25-kilohertz capability, which customers may not want or even be able to use to the extent their current deployment is analog. IMSA stated inclusion of a 6.25-kilohertz capability would “inevitably” raise radio prices. Because customers may not be willing or able to afford the additional expense, manufacturers potentially would forgo adding new features to existing radio products that could enhance public-safety capabilities.

IMSA believed this to be an undue burden on public-safety users. The hardest hit users likely would not be large urban agencies, which may have already transitioned or are planning to transition to digital networks, but would almost certainly be smaller volunteer fire departments and other similar public-safety providers that often are forced to make the most of very limited budgets, IMSA said.

IMSA also noted that, unlike the developed standard for Phase 2 Project 25 (P25) trunked operations, the standard-setting process for Phase 2 P25 conventional 6.25-kilohertz operations has not yet been completed. IMSA questioned the wisdom of requiring manufacturers to implement a 6.25-kilohertz capability that may be incompatible with any future standard and noted the commission itself had previously remarked that, “proliferation of 6.25-kilohertz equipment that is incompatible with the P25 Phase 2 standard could undermine interoperability.”

IMSA pointed out that the commission recently eliminated the 6.25-kilohertz capability requirement for 700 MHz band public-safety equipment. If the requirement no longer made sense at 700 MHz, why continue to apply it to the bands below 512 MHz?

On June 30, the commission ultimately rejected IMSA’s arguments and issued an order denying its request for waiver, choosing instead to leave the Jan. 1, 2015, deadline in place.

Interestingly, the commission did not directly rebut IMSA’s assertion that a mandated 6.25-kilohertz capability would increase equipment costs for public-safety users. Instead, it said commenters in the proceeding had presented “conflicting assertions” regarding costs and there was no “clear evidence” to support IMSA’s position. The commission stated that some comments in the proceeding claimed market competition has kept the price of 6.25-kilohertz-capable equipment comparable to that of similar equipment without 6.25-kilohertz capability. The commission also questioned whether other cost estimates showing an increased burden on public safety were made on an apples-to-apples basis or were instead comparing low-end analog radio models to high-end expensive equipment. Although equipment costs would appear to be something that the commission could reasonably ascertain, the FCC typically does not perform that type of independent fact finding in response to waiver requests. Here, the commission found IMSA had not demonstrated that continued implementation of the 6.25-kilohertz capability requirement would be inequitable and unduly burdensome.

The FCC also rejected any similarities between the elimination of the 6.25-kilohertz requirement at 700 MHz and the continued implementation of the requirement for the bands below 512 MHz. In addition, the commission summarily dismissed the notion that an ongoing P25 standards process should alter continued implementation of the 6.25-kilohertz certification requirement.

Many will be disappointed by the decision.

Of possibly wider interest, the commission took the opportunity to again reiterate that it intends a further migration from 12.5- to 6.25-kilohertz licensing at some point in the future. Its order characterized the current 12.5-kilohertz landscape as a “transitional step in the eventual migration to 6.25-kilohertz technology” and stated that it would mandate such migration, as opposed to allowing for a voluntary transition, if necessary. Central to the FCC’s decision was the fact that removing the 6.25-kilohertz capability certification rule would increase the embedded base of equipment that is 12.5-kilohertz capable only. Such equipment would need to be replaced once the 6.25-kilohertz transition occurs.

One question the FCC did not answer is when the transition to 6.25 kilohertz will occur. Logically, if the transition is soon, it does not make sense to allow manufacturers to continue to certify new equipment that will need to be replaced within its expected lifetime. This is likely worse for cash-strapped agencies than the incremental cost of requiring 12.5-kilohertz radios to include 6.25-kilohertz capability now. However, IMSA’s request to extend the certification requirement starts to make more sense if the timeline for the 6.25-kilohertz migration is far enough away.

How long that timeline is remains to be seen.

---

Greg Kunkle is a partner in the law firm of Keller and Heckman, practicing in telecommunications with an emphasis on assisting corporate clients and trade associations with legal and regulatory matters before the FCC. He is president of the Land Mobile Communications Council (LMCC) and a member of the Federal Communications Bar Association.

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4 Practical Ways To Help In A Disaster

by John Hawthorne
Jan 17, 2017

It’s a frighteningly common occurrence. As you scroll through your social feeds or watch the news, you hear of another disaster happening in another part of world. A hurricane in the Philippines, an earthquake in Nepal, a tsunami in Thailand. It’s sad. Grievous. Heartbreaking. And tremendously frustrating.

You desperately want to do something to help. To alleviate the pain and suffering. To make an actual difference in the world. But as you watch the footage and see the pictures, you feel so helpless. You want to take action but you don’t know what to do. You feel hamstrung. Stuck. Like you’re flailing at the air.

We understand your predicament, which is why we put this post together. We’re going to give you 4 practical ways you can get involved when a disaster strikes. These ideas range from high time, high commitment ideas to less involved solutions. No matter what your age or ability, there is always some way to help.

Daryn Kagan said, “Bad things do happen in the world, like war, natural disasters, disease. But out of those situations always arise stories of ordinary people doing extraordinary things.” You can be an ordinary person doing extraordinary things. Here’s how to get started.

Volunteer Your Time

You may not be able to donate money, but you can always donate your time. Relief organizations are always desperate for volunteers, and when a disaster strikes there are often too few boots on the ground.

In terms of ways to volunteer, the possibilities are almost unlimited. Some ideas include:

• Collecting supplies that can be distributed to those who have been affected and those who are working to create a solution.
• Lobbying community leaders and businesses to support the relief effort. This can be done both in person and through other means like email and social media.
• Organizing a benefit dinner or event (think concert, comedy show, etc.).
• Rallying local religious communities to support the relief effort. Many churches, synagogues, mosques, and other religious organizations will be more than happy to donate time, money, or supplies.

When it comes to specific organizations to volunteer with, here are a few options:

Red Cross:

• 90% of the Red Cross are volunteers, meaning that when a disaster strikes, they depend heavily on volunteers to come to the aid of those in distress.
• They have a wide range of volunteer opportunities in different areas, and you can browse your location for opportunities here.
• They may have positions possibly related to your area of expertise, for example: Administrative specialist, media relations, office assistant, donor experience lead, disaster services lead, real estate transaction assistant, etc. This allows you utilize your specific skills during times of crisis.

Samaritan’s Purse:

• This Christian organization partners with churches in communities and works together to “share the love of Jesus Christ with people facing grief and uncertainty.”
• As noted on their website, Samaritan’s Purse, “…mobilizes staff and equipment and enlists thousands of volunteers to provide emergency aid to victims of tornadoes, hurricanes, wildfires, floods, and other natural disasters in the U.S.”
• They sometimes rebuild or restore houses for needy families.
• You can check for volunteer opportunities in your area or sign up to receive newsletter at https://spvolunteernetwork.samaritanspurse.org/volunteer/
• Some of their current projects include: repairing and restoring homes damaged by June 2016 flooding in West Virginia, restore and repair homes damaged by August 2016 flooding in Louisiana, helping restore StraightWay Training Center, a faith based drug and alcohol rehab center in Texas.

UNICEF:

• They respond to more than 250 emergencies-from conflicts to natural disasters, every year.
• Volunteers educate, advocate and fund-raise on behalf of UNICEF in their communities.
• You can host a fundraiser or event to raise money for UNICEF.

Salvation Army:

• This Christian, faith-based organization responds to numerous natural disasters, transportation accidents, civil unrest situations and terrorist attacks.
• They offer disaster training programs to help individuals and communities prepare for emergency events.
• They provide food service- offering meals, snacks and drinks to rescue workers and survivors.
• They provide emotional and spiritual care to those affected by a disaster.

Volunteering is a hugely important way to get involved and make a difference during times of crisis. Non-profits don’t have the finances to maintain a fully staffed disaster team, making volunteers a critical part of their mission success.

Donate Your Money

One of the fastest, most practical ways to make a difference in a time of need is simply by donating money. Financial aid allows relief organizations to quickly get people on the ground and get supplies to those who desperately need them.

Additionally, giving financially allows relief organizations to funnel the resources toward what is needed most, whether that’s food, machinery, medicine, or equipment.

One thing that’s important when giving finances to relief efforts: only give money to trusted organizations who will use the resources wisely. Unfortunately, fraudulent charities are a real thing. They take advantage of the pain of others to make a profit for themselves.

As Ryan Scott wrote in Forbes:

In the aftermath of Hurricane Katrina, the American Red Cross asked the FBI to investigate at least 15 fake websites that were designed to look like legitimate Red Cross appeals for donations. Even before Katrina hit, internet fraud experts saw scammers registering dozens of websites with Katrina in their names. After Hurricane Sandy, one charity calling itself the Hurricane Sandy Relief Effort raised $600k for storm victims, but it was all actually a ploy to help a couple of con artists with their own credit card relief.

These kinds of people give disaster relief a bad name and take resources away from those who legitimately need them.

In light of this, only give to organizations who are reputable.

• The Red Cross accepts donations on their website, as well as by text, email, and a host of other methods. You can also give blood at the Red Cross.
• You can become a monthly donor to UNICEF and provide children with lifesaving vaccines and insecticide-treated bed nets, emergency relief after natural disasters, educational opportunities, and more.
• The Salvation Army accepts donations of goods and supplies and money. They ask that you check with your local Salvation Army to confirm the need after the disaster. Rarely are clothing, cars and furniture needed for disaster relief, but those donations help support the day-to-day of the Salvation Army.
• We also offer a variety of ways to donate and bring relief to those who desperately need it.

Giving a small portion of your income to those in need can have an exponential effect. Lifesaving supplies can be given to those affected by tragedy, allowing you to play a key role in lessening the pain and suffering.

Advocate and Raise Awareness

When disaster strikes, a simple way to get involved is to advocate for change and raise awareness. For example, through the UNICEF website, you can support legislative advocacy for children’s rights. You can also sign various petitions on the website Change.org, like this one to intervene on behalf of children in Aleppo.

Another simple way to make a difference is to raise awareness. Most people are simply in the dark in terms of how they can help when disaster strikes. You can inform and educate people through social media, community involvement, and charity events, similar to how the “March For Life” raises funds and awareness regarding premature birth.

Get Paid To Help

FEMA (Federal Emergency Management Agency) is a federal agency that provides “financial assistance and, if necessary, direct services to eligible individuals and households who, as a direct result of a major disaster, have necessary expenses and serious needs and are unable to meet such expenses or needs through other means.”

If you want to make disaster relief a bigger part of your life, you can actually become a reservist for FEMA. Reservists assist disaster survivors and have the opportunity to travel, receive training, and build a professional network. They are appointed for a 2-year period and are the main FEMA workforce during an emergency or disaster that assists the agency in accomplishing its mission.

This probably can’t be your full time job due to the intermittent nature of disasters, but it does provide a way for you to get closely integrated into aid work. You can learn more about becoming a reservist here.

A Few Things To Consider

When choosing how to help in times of disaster, here are a few things to consider.

How much time do you have? Obviously, the more time you have the more involved your relief efforts can be. If you are strapped for time, you can donate money, sign petitions, and raise awareness. If you have the bandwidth to be more involved, you can become a reservist or volunteer.

How much stamina do you have? Disaster relief work is both emotionally and physically taxing. Those who volunteer need more stamina and energy than those who donate or raise awareness. If you are chronically ill or have a low emotional tolerance, you may want to consider raising awareness and donating.

Are you physically prepared? If you’re going to volunteer on location at a disaster, you need to be physically ready. Traveling is exhausting, disease and sickness are prevalent, and you may need to update your immunizations. Physical preparedness is crucial when volunteering on location, and a lack of it can actually be harmful to you.

To be clear, all types of relief are helpful, whether it’s volunteering or donating cash. You simply need to choose the one that is the best fit for who you are.

Conclusion

Marsha Blackburn said, “In this dangerous world that we live in, where hatred and violence and natural disasters sometimes collide to almost overwhelm us, we each can help in some way.”

Yes, we all truly can help each other in some way, and when disaster strikes, it’s crucial that all of us work together.

Don’t think that you have no power to make a difference. By simply getting involved, you can transform lives and relieve suffering.

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Disaster-Proven Paging for Public Safety

Paging system designs in the United States typically use a voice radio-style infrastructure. These systems are primarily designed for outdoor mobile coverage with modest indoor coverage. Before Narrowbanding, coverage wasn’t good, but what they have now is not acceptable! The high power, high tower approach also makes the system vulnerable. If one base station fails, a large area loses their paging service immediately!

Almost every technology went from analog to digital except fire paging. So it’s time to think about digital paging! The Disaster-Proven Paging Solution (DiCal) from Swissphone offers improved coverage, higher reliability and flexibility beyond anything that traditional analog or digital paging systems can provide. 

Swissphone is the No. 1 supplier for digital paging solutions worldwide. The Swiss company has built paging networks for public safety organizations all over the world. Swissphone has more than 1 million pagers in the field running for years and years due to their renowned high quality.

DiCal is the digital paging system developed and manufactured by Swissphone. It is designed to meet the specific needs of public safety organizations. Fire and EMS rely on these types of networks to improve incident response time. DiCal systems are designed and engineered to provide maximum indoor paging coverage across an entire county. In a disaster situation, when one or several connections in a simulcast solution are disrupted or interrupted, the radio network automatically switches to fall back operating mode. Full functionality is preserved at all times. This new system is the next level of what we know as “Simulcast Paging” here in the U.S.

Swissphone offers high-quality pagers, very robust and waterproof. Swissphone offers the best sensitivity in the industry, and battery autonomy of up to three months. First responder may choose between a smart s.QUAD pager, which is able to connect with a smartphone and the Hurricane DUO pager, the only digital pager who offers text-to-voice functionality.

Bluetooth technology makes it possible to connect the s.QUAD with a compatible smartphone, and ultimately with various s.ONE software solutions from Swissphone. Thanks to Bluetooth pairing, the s.QUAD combines the reliability of an independent paging system with the benefits of commercial cellular network. Dispatched team members can respond back to the call, directly from the pager. The alert message is sent to the pager via paging and cellular at the same time. This hybrid solution makes the alert faster and more secure. Paging ensures alerting even if the commercial network fails or is overloaded.

Swissphone sets new standards in paging:

Paging Network

• It’s much faster to send individual and stacked pages digitally than with analog voice.
• If you want better indoor coverage, you put sites closer together at lower heights.
• A self-healing system that also remains reliable in various disaster situations.
• Place base station where you need them, without the usage of an expensive backhaul network.
• Protect victim confidentiality and prevent unauthorized use of public safety communications, with integrated encryption service.

Pager

• Reliable message reception, thanks to the best sensitivity in the industry.
• Ruggedized and waterproof, IP67 and 6 1/2-feet drop test-certified products.
• Battery autonomy of up to three months, with a standard AA battery.
• Bluetooth enables the new s.QUAD pager to respond back to the dispatch center or fire chief.

Dispatching:

• Two-way CAD interfaces will make dispatching much easier.
• The new s.ONE solution enables the dispatcher or fire chiefs to view the availability of relief forces.
• A graphical screen shows how many of the dispatched team members have responded to the call.

Swissphone provides a proven solution at an affordable cost. Do you want to learn more?
Visit: www.swissphone.com or call 800-596-1914.

Wireless Communication Solutions

USB Paging Encoder

• Single channel up to eight zones
• Connects to Linux computer via USB
• Programmable timeouts and batch sizes
• Supports 2-tone, 5/6-tone, POCSAG 512/1200/2400, GOLAY
• Supports Tone Only, Voice, Numeric, and Alphanumeric
• PURC or direct connect
• Pictured version mounts in 5.25" drive bay
• Other mounting options available
• Available as a daughter board for our embedded Internet Paging Terminal (IPT)

Paging Data Receiver (PDR)

• Frequency agile—only one receiver to stock
• USB or RS-232 interface
• Two contact closures
• End-user programmable w/o requiring special hardware
• 16 capcodes
• POCSAG
• Eight contact closure version also available
• Product customization available

Other products

Please see our web site for other products including Internet Messaging Gateways, Unified Messaging Servers, test equipment, and Paging Terminals.

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A Problem

The Motorola Nucleus II Paging Base Station is a great paging transmitter. The Nucleus I, however, had some problems.

One of the best features of this product was its modular construction. Most of the Nucleus' component parts were in plug-in modules that were field replaceable making maintenance much easier.

One issue was (and still is) that two of the modules had to always be kept together. They are called the “matched pair.”

Motorola used some tricks to keep people in the field from trying to match unmatched pairs, and force them to send SCM and Exciter modules back to the factory for calibrating them with precision laboratory equipment.

The serial numbers have to match in the Nucleus programing software or you can't transmit [in simulcast mode] . Specifically the 4-level alignment ID parameter contained in the SCM has to match the Exciter ID parameter.

Even if someone could modify the programing software to “fudge” these parameters, that would not let them use unmatched modules effectively without recalibrating them to exact factory specifications.

So now that there is no longer a Motorola factory laboratory to send them to, what do we do?

I hope someone can help us resolve this serious problem for users of the Nucleus paging transmitter.

Please let me know if you can help. [click here]

[Thanks to Tom Harger Chief Engineer at Contact Wireless for the correction above in red.]

Selected portions [sometimes more — sometimes less] of the BloostonLaw Telecom Update and/or the BloostonLaw Private Users Update — newsletters from the Law Offices of Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP — are reproduced in this section of The Wireless Messaging News with the firm’s permission. Contact information is included at the end of the newsletter.

REMINDER – 911 Reliability Certifications Due October 16

We want to remind our firm’s RLEC and other telco clients that are “Covered 911 Service Providers” that 911 Reliability Certifications will be due this year by Monday, October 16. Under the Commission’s Rules, by October 15 each year, entities that “[p]rovide[] 911, E911, or NG911 capabilities such as call routing, automatic location information (ALI), automatic number identification (ANI), or the functional equivalent of those capabilities, directly to a public safety answering point (PSAP), statewide default answering point, or appropriate local emergency authority,” or that “[o]perate[] one or more central offices that directly serve a PSAP,” are required certify that they have taken reasonable measures to provide reliable 911 service with respect to three substantive requirements: (i) 911 circuit diversity; (ii) central office backup power; and (iii) diverse network monitoring. October 15 falls on a Sunday this year so the filing deadline is extended to Monday the 16th. Please contact the firm if you would like assistance with filing this certification. Such entities must also retain records supporting the responses in a certification for two years from the date of such certification, and shall make such records available to the Commission upon request.

BloostonLaw Contacts: Ben Dickens, Mary Sisak, and Sal Taillefer.

Headlines

AIRWAVES Act May Bring Additional Funding for Rural Broadband Wireless Infrastructure

Bipartisan legislation was introduced in the Senate Commerce Committee yesterday by Sens. Cory Gardner (R-CO) and Maggie Hassan (D-NH) designed to encourage the federal government to continue to free up spectrum for commercial licensed and unlicensed use and leverage the success of spectrum auctions to help close the urban-rural divide.

According to a press release from Sen. Gardner’s office, the Advancing Innovation and Reinvigorating Widespread Access to Viable Electromagnetic Spectrum (or “AIRWAVES”) Act would “establish a pipeline to open more spectrum for wireless providers to improve existing service and expand into new areas.”

“This legislation offers innovative ways to avoid a spectrum crunch, pave the way for 5G service, and provide critical resources to rural America to continue rural buildout in unserved and underserved areas throughout Colorado and the country,” said Gardner.

Text of the bill, which was introduced as S. 1682, was not yet available as the BloostonLaw Telecom Update went to press. However, a statement from FCC Commissioner Michael O’Rielly suggests that the item could set the agenda for upcoming wireless matters at the FCC.

“There’s a lot to like in this bill including firm spectrum deadlines and auctions for key bands,” wrote O’Rielly. “I look forward to working with [Sens. Gardner and Hassan] and others in Congress as the bill moves forward.

The legislation is designed to promote more efficient use of existing spectrum and freeing up additional unlicensed spectrum for wireless technologies like WiFi and Bluetooth. Recent work by Sens Gardner and Hassan adding language to an FAA reauthorization bill suggest that the 1300-1350 MHz band, which is currently used for a number of long-range radar systems, could be among the spectrum bands that are repurposed for commercial use in the near future.

A second aspect of the AIRWAVES Act, and something that should pique the interest of rural service providers, calls for 10 percent of all of the proceeds from spectrum auctions in the bill to go directly to wireless broadband infrastructure buildout in unserved and underserved areas throughout rural communities across the country.

Any opportunity to secure additional funds for rural broadband buildout should be welcomed by our firm’s clients, though, like always, the devil will be in the details. This funding could also help pave the way for greater competition in rural and underserved markets. We will keep an eye on this legislation as it makes its way through Congress.

BloostonLaw Contacts: Cary Mitchell, John Prendergast

Deadlines Established for Rural Call Completion NPRM – Comments Due August 28

On July 27, the FCC published in the Federal Register its Second Notice of Proposed Rulemaking on new proposed rural call completion requirements for covered providers and on proposals to either modify or eliminate the Commission's existing data recording, retention, and reporting requirements. Comments are due on or before August 28, 2017, and reply comments are due on or before September 25, 2017.

In the NPRM, the FCC proposes to hold covered providers responsible for monitoring rural call completion performance, and particularly maintaining the accountability of their intermediate providers in the event of poor performance. Related questions include whether the FCC should specify: performance metrics; the form and frequency of required monitoring; limit the scope of monitoring requirements; best practices; how covered providers must hold intermediate providers accountable; and others. Importantly, the FCC is seeking comment on whether smaller providers should be exempted from any new requirements applicable to covered providers. In the 2013 Rural Call Completion Order, the Commission exempted providers that made the initial long-distance call path choice for 100,000 or fewer domestic retail subscriber lines, counting the total of all business and residential fixed subscriber lines and mobile phones and aggregated over all of the provider’s affiliates, from the recording, retention, and reporting requirements. The FCC is explicitly seeking comment on whether that exemption should apply to the new rules.

The FCC also proposes to modify or eliminate existing recording, retention, and reporting requirements. One such method of doing so on which comment is sought involves retaining but modifying existing recording, retention, and reporting requirements; a second involves retaining the recording and retention requirement but eliminate the reporting requirement. The FCC also seeks comment on how the existing Safe Harbor regime should be structured going forward.

Carries interested in participating in this proceeding should contact the firm for more information.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and Mary Sisak.

FCC Adopts DVB-CID Requirement Waiver Ahead of Open Meeting

On July 28, the FCC adopted the Memorandum Opinion and Order that waives the Digital Video Broadcasting- Carrier Identification (DVB-CID) standard for certain earth stations that was scheduled to be considered at tomorrow’s Open Meeting. Specifically, the MO&O waives section 25.281(b) of the FCC’s rules for digitally transmitting satellite news gathering vehicles, and other temporary-fixed earth stations, that use existing modulators that cannot be made compliant with the DVB-CID standard by a software upgrade. To mitigate the potential for harmful interference into satellite operations, the FCC also required earth stations with new modulators, or with existing modulators that can be made compliant through a software upgrade, to meet the DVB-CID standard by the current effective date of September 3, 2017.

This waiver does not apply to analog video transmissions. Section 25.281(a) requires these transmissions to be identified either by a 7.1 megahertz sub-carrier signal or by a DVB-CID signal required for digital transmissions. Any analog video transmitters that cannot comply with the DVB-CID standard must transmit a 7.1 megahertz signal, and are unaffected by the waiver granted here.

BloostonLaw Contacts: John Prendergast and Richard Rubino.

Law & Regulation

Legislation to End Lifeline Support for Wireless Service Introduced in House

On July 28, U.S. Representative Austin Scott (GA-08) introduced the End Taxpayer Funded Cell Phones Act (H.R. 3546), which would end the Lifeline Program’s taxpayer subsidization of cellular service while allowing landline service to continue for eligible participants.

Rep. Scott’s press release cites to the June 29, 2017 Government Accountability Office report which detailed “numerous instances of misuse and oversight gaps of the Lifeline Program, in particular the program’s free cell phone plan.” Specifically, Representative Scott cites the report’s finding that $1.2 million in cell phone subsidies “went to fake or deceased individuals, and more than 36% of cell phone program subscribers—1.2 million of 3.5 million—could not be verified.”

“Hardworking American taxpayers are already overburdened and should not be forced to pay for a program that has vastly expanded beyond its intended scope and is riddled with waste, fraud, and abuse,” said Rep. Scott. “My bill will reform the Lifeline Program and restore it to its original purpose of providing landline services and prohibit Universal Service support for mobile services. In order to promote government accountability, cut government fraud and waste, and protect consumers from further increases to their phone bills, the Lifeline Program’s free cell phone plans should end.”

Original co-sponsors of the End Taxpayer Funded Cell Phones Act include Representatives Rick Allen (GA-12), Brian Babin (TX-36), Dave Brat (VA-07), Bradley Byrne (AL-01), Steve Chabot (OH-01), Paul Cook (CA-08), Neal Dunn (FL-2), Drew Ferguson (GA-03), Bill Flores (TX-17), Jody Hice (GA-10), Lynn Jenkins (KS-02), Doug LaMalfa (CA-01), Tom McClintock (CA-04), Ralph Norman (SC-05), Bill Posey (FL-08), Tom Rice (SC-07), Brad Wenstrup (OH-02), and Rick Crawford (AR-01).

BloostonLaw Comments: John Prendergast and Richard Rubino.

Industry

Watchdog Group Files Suit Against FCC Over Net Neutrality

On July 26, a watchdog group called American Oversight filed a lawsuit in the U.S. District Court for the District of Columbia asking a judge to order the FCC to release records of its contacts with internet companies regarding its recent proposal to revert Internet access to Title I regulation and effectively roll back Net Neutrality, “so that the public can better understand how this policy decision was made.”

Austin Evers, Executive Director of American Oversight, said, “The FCC has made it clear that they’re ignoring feedback from the general public, so we’re going to court to find out who they’re actually listening to about Net Neutrality. If the Trump administration is going to let industry lobbyists rewrite the rules of the Internet for millions of Americans, we’re going to make them do it in full view of the public.”

According to a press release by American Oversight, the group filed two Freedom of Information Act requests in April seeking information “about meetings and correspondence between the incoming FCC chair Ajit Pai, his senior staff, Congress, and companies in the telecommunications industry.” After initially agreeing to process American Oversight’s requests quickly, the FCC “repeatedly delayed releasing the records even as the Trump administration continued its work to roll back the open internet rules.”

Technological Advisory Council Meeting Scheduled for September

On July 27, the FCC published notice in the Federal Register of an upcoming meeting of the Technological Advisory Council, as required by the Federal Advisory Committee Act. The meeting will be held Tuesday, September 19 from 12:30 p.m. to 4 p.m.

At the meeting, the Technological Advisory Council will discuss progress on and issues involving its work program agreed to at its initial meeting on June 8, 2017. Written comments may be filed at any time before the meeting by email to Walter Johnston, the FCC’s Designated Federal Officer for Technological Advisory Council.

The meeting will be broadcast live with open captioning over the Internet from the FCC Live Web page at http://www.fcc.gov/live/.

FCC To Hold 911 Outage Situational Awareness Workshop

On July 27, the FCC’s Public Safety and Homeland Security Bureau announced that will host a public workshop on September 11 to discuss best practices for improving situational awareness during 911 outages. Topics addressed in the workshop will include how to strengthen Public Safety Answering Point 911 service outage notifications and how to best communicate with consumers about alternative methods of accessing emergency services.

Audio/video coverage of the meeting will be broadcast live with open captioning over the Internet from the FCC's web page at www.fcc.gov/live/.

FCC To Hold 911 Outage Situational Awareness Workshop

On July 27, the FCC’s Public Safety and Homeland Security Bureau announced that will host a public workshop on September 11 to discuss best practices for improving situational awareness during 911 outages. Topics addressed in the workshop will include how to strengthen Public Safety Answering Point 911 service outage notifications and how to best communicate with consumers about alternative methods of accessing emergency services.

Audio/video coverage of the meeting will be broadcast live with open captioning over the Internet from the FCC's web page at www.fcc.gov/live/.

Deadlines

AUGUST 3: E911 Indoor Location Accuracy - Initial Implementation Plan and First Progress Report. All CMRS service providers must prepare and submit to the FCC an Initial Implementation Plan which describes their company’s plans for meeting the FCC’s improved indoor location accuracy requirements, as well as a related First Progress Report which describes their efforts to date toward meeting the plan. The FCC has not specified a particular format for these filings, so we have prepared a template that combines both into a single report. Please contact us if you want us to help draft or submit these filings on your company’s behalf.

BloostonLaw Contact: Cary Mitchell.

AUGUST 29: COPYRIGHT STATEMENT OF ACCOUNTS. The Copyright Statement of Accounts form plus royalty payment for the first half of calendar year 2014 is due to be filed August 29 at the Library of Congress’ Copyright Office by cable TV service providers.

BloostonLaw Contact: Gerry Duffy.

SEPTEMBER 1: FCC FORM 477, LOCAL COMPETITION AND BROADBAND REPORTING FORM. Three types of entities must file this form. (1) Facilities-based Providers of Broadband Connections to End User Locations: Entities that are facilities-based providers of broadband connections — which are wired “lines” or wireless “channels” that enable the end user to receive information from and/or send information to the Internet at information transfer rates exceeding 200 kbps in at least one direction — must complete and file the applicable portions of this form for each state in which the entity provides one or more such connections to end user locations. For the purposes of Form 477, an entity is a “facilities-based” provider of broadband connections to end user locations if it owns the portion of the physical facility that terminates at the end user location, if it obtains unbundled network elements (UNEs), special access lines, or other leased facilities that terminate at the end user location and provisions/equips them as broadband, or if it provisions/equips a broadband wireless channel to the end user location over licensed or unlicensed spectrum. Such entities include incumbent and competitive local exchange carriers (LECs), cable system operators, fixed wireless service providers (including “wireless ISPs”), terrestrial and satellite mobile wireless service providers, MMDS providers, electric utilities, municipalities, and other entities. (Such entities do not include equipment suppliers unless the equipment supplier uses the equipment to provision a broadband connection that it offers to the public for sale. Such entities also do not include providers of fixed wireless services (e.g., “Wi-Fi” and other wireless ethernet, or wireless local area network, applications) that only enable local distribution and sharing of a premises broadband facility.) (2) Providers of Wired or Fixed Wireless Local Telephone Services: Incumbent and competitive LECs must complete and file the applicable portions of the form for each state in which they provide local exchange service to one or more end user customers (which may include “dial-up” ISPs). (3) Providers of Interconnected Voice over Internet Protocol (VoIP) Service: Interconnected VoIP service is a service that enables real-time, two-way voice communications; requires a broadband connection from the user’s location; requires Internet-protocol compatible customer premises equipment; and permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network. Interconnected VoIP providers must complete and file the applicable portions of the form for each state in which they provide interconnected VoIP service to one or more subscribers, with the state determined for reporting purposes by the location of the subscriber’s broadband connection or the subscriber’s “Registered Location” as of the data-collection date. “Registered Location” is the most recent information obtained by an interconnected VoIP service provider that identifies the physical location of an end user. (4) Providers of Mobile Telephony Services: Facilities-based providers of mobile telephony services must complete and file the applicable portions of this form for each state in which they serve one or more mobile telephony subscribers. A mobile telephony service is a real-time, two-way switched voice service that is interconnected with the public switched network using an in-network switching facility that enables the provider to reuse frequencies and accomplish seamless handoff of subscriber calls. A mobile telephony service provider is considered “facilities-based” if it serves a subscriber using spectrum for which the entity holds a license that it manages, or for which it has obtained the right to use via lease or other arrangement with a Band Manager.

BloostonLaw contacts: Ben Dickens and Gerry Duffy.

SEPTEMBER 30: FCC FORM 396-C, MVPD EEO PROGRAM REPORTING FORM. Each year on September 30, multi-channel video program distributors (“MVPDs”) must file with the Commission an FCC Form 396-C, Multi-Channel Video Programming Distributor EEO Program Annual Report, for employment units with six or more full-time employees. Users must access the FCC’s electronic filing system via the Internet in order to submit the form; it will not be accepted if filed on paper unless accompanied by an appropriate request for waiver of the electronic filing requirement. Certain MVPDs also will be required to complete portions of the Supplemental Investigation Sheet (“SIS”) located at the end of the Form. These MVPDs are specifically identified in a Public Notice each year by the FCC.

BloostonLaw Contacts: Gerry Duffy and Sal Taillefer.

OCTOBER 16: 911 RELIABILITY CERTIFICATION. Covered 911 Service Providers, which are defined as entities that “[p]rovide[] 911, E911, or NG911 capabilities such as call routing, automatic location information (ALI), automatic number identification (ANI), or the functional equivalent of those capabilities, directly to a public safety answering point (PSAP), statewide default answering point, or appropriate local emergency authority,” or that “[o]perate[] one or more central offices that directly serve a PSAP,” are required certify that they have taken reasonable measures to provide reliable 911 service with respect to three substantive requirements: (i) 911 circuit diversity; (ii) central office backup power; and (iii) diverse network monitoring by October 15. Certifications must be made through the FCC’s portal.

BloostonLaw Contacts: Mary Sisak and Sal Taillefer.

Calendar At-A-Glance

August
Aug. 3 – E911 Indoor Location Accuracy Initial implementation plan / first progress reports due.
Aug. 7 – Deadline to file for 3.65-3.7 GHz Grandfathered Protection Zone.
Aug. 15 – Deadline for reply comments refreshing the record on Toll Free Calling Access Charges.
Aug. 16 – Reply comments are due on Broadband Title I Reclassification NPRM.
Aug. 28 – Comments are due on Rural Call Completion NPRM.
Aug. 29 – Copyright Statement of Accounts is due.

September
Sep. 1 – FCC Form 477 due (Local Competition and Broadband Report).
Sep. 25 – Reply comments are due on Rural Call Completion NPRM.
Sep. 30 – FCC Form 396-C (MVPD EEO Program Annual Report).

October
Oct. 16 – 911 Reliability Certification

FCC To Adopt Stricter License Renew al and Discontinuance of Service Rules

At its upcoming August 3 Open Meeting, the FCC will vote on an order in WT Docket 10-112, which will create unified construction, renewal and discontinuance of operation rules for the various wireless radio services. The FCC is also expected to issue a Further Notice of Proposed Rulemaking in which it will seek comment on a range of additional possible actions to “increase access to wireless communications services” — which includes taking spectrum back from licensees deemed not to making adequate use of their license. It is important to note that the FCC’s expected action will impact both traditional commercial wireless services and wireless services used by private and public safety entities to meet internal communications needs.

The FCC has released a draft copy of the order which is being circulated among the Commissioners prior to the vote on August 3rd. As a result, there could be further changes to the order. Nonetheless, the summary below provides of the expected rules that will be relevant to your future station operations and license renewals.

License Renewal

Under the FCC’s renewal standard, private radio licensees will be required to demonstrate that over the course of the license period, the licensee operated and continues to operate to address the licensee’s private internal communications needs. Commercial licensees will be required to demonstrate they provided and continue to provide substantial service to the public.

The FCC is establishing a safe-harbor which will permit the vast majority of license renewal applications to be processed in the normal course, much like they have been up until now. The safe-harbor includes three certifications under penalty of perjury, which address the fol-lowing: (i) the licensee is engaged in ongoing operation to meet internal communications needs and/or provision of service to unaffiliated subscribers, (ii) there has been no “permanent discontinuance” of operation or service to the public and (iii) the licensee has substantially complied with all applicable FCC rules, policies and the Communications Act and is not the subject of any FCC order finding a violation of the Communications Act or any rule or policy or pending compliance proceeding.

The FCC recognizes that geographic area licenses (i.e., auction licenses) and spectrum leases are being used by licensees to meet private internal communications requirements. As a result, the FCC plans to adopt a safe harbor for this class of license, which includes the following certifications: (i) the required construction bench-marks have been met and the licensee continues to utilize the facilities to “further [its] private, internal business or public interest/public safety needs at or above the level required to meet its interim performance requirement” and (ii) has met its final performance requirement and continues to use its facilities to “further [its] private, internal business or public interest/public safety needs at or above the level required to meet its interim performance requirement.”

Those licensees that are not able to meet the safe harbor will be required to provide a showing demonstrating how it meets the FCC’s renewal standard. Even for the private land mobile services, we anticipate that these showings could be detailed and the subject of intense scrutiny by the FCC’s staff.

In addition, each licensee will be required to certify that (1) it has substantially complied with the FCC’s Rules and policies, and the Communications Act of 1934 (the “Act”) as amended and (2) is not the subject of any FCC Order finding a violation, or subject to any pending FCC enforcement action. In the event that a licensee cannot make the compliance certification, the FCC has indicated that the license renewal application will need to include a detailed explanation of the circumstances preventing the certification and a justification as to why the license renewal application should still be granted. If the FCC determines that a license renewal applicant’s compliance certification is insufficient, the license renewal application will be denied and the spectrum will automatically return to the FCC’s inventory for reassignment to another applicant. BloostonLaw filed comments on behalf of its clients pointing out the unfairness of denying a license renewal based on a pending enforcement action, which may eventually be resolved in favor of the licensee.

The FCC has recognized that its new rules will have differing impacts on site-based licensees and geographic-area licensees. Because the FCC anticipates that license renewals for site-based licensees will be very similar to the renewal process in use today, the FCC is not planning for a transition period. Rather, the rules will become effective following approval by the Office of Management and Budget (OMB) and the release of a Public Notice by the FCC. For geographic-area licensees, the FCC is establishing a transition period which will make the new standards effective on January 1, 2023.

Permanent Discontinuance of Operation

The FCC is establishing uniform permanent discontinuance rules applicable to all services. These rules will be based on the type of license (site-based vs. geographic area) without regard to whether the license is used for private internal communications or to provide commercial wireless services to the public. For site-based licenses, the permanent discontinuance period will be 365 consecutive days (i.e., the same as the current rule for Part 90 private radio licensees). For geographic-area licenses, the permanent discontinuance period will be 180 consecutive days. While licenses used to meet private, internal communications needs must be operating, licenses used to provide commercial service to the public must have “at least one subscriber that is not affiliated with, controlled by, or related to the . . . carrier.”

Should a station permanently discontinue operation, the FCC will require an application for license modification to delete that transmitter or an application for license cancellation to be filed within 10 calendar days of the permanent discontinuance of operation.

Exempt Services

The FCC’s draft order states that these rule changes will not apply to the public safety services or the Educational Broadband Service. We expect that various parties may seek reconsideration of this exemption — especially as it relates to the Part 90 public safety services.

We expect the final version of the order that is released following the Open Meeting to be very similar to the draft order that we have summarized for you. A further write up will be forthcoming that provides more detail into the FCC’s new processes and how it will impact you.

Further Notice of Proposed Rulemaking

The FCC is also adopting a further notice in order to seek comment on additional rules which, if adopted, would impose further construction requirements for commercial licensees after the initial license term. Essentially, the FCC is proposing to require commercial licensees, who have already met their build out requirements, to continue to build out their network in increments of at least 10 percent per license renewal term following the initial term. For those licensees that don’t meet this requirement, the FCC is proposing to take back unserved areas and allowing commercial licensees to only keep those areas that are being served.

Comments to the proposals in the Further Notice will be due 30 days following publication in the Federal Register. Reply comments will be due 60 days following publication in the Federal Register.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Updates Equipment Authorization Rules for Radio Frequency Devices

The FCC has taken action to streamline and simplify its equipment authorization procedures for most radio-frequency devices such as cell phones, televisions, and other devices that are marketed, imported or operated within the United States.

Under the current regulatory scheme, the Commission has two different procedures — self approval processes such as verification and declaration of conformity and certification processes. Verification and Declaration of Conformity (DoC) are self-approval processes that are reserved for RF equipment that has an established testing methodology, low risk of causing harmful interference and a high compliance rate. The more rigorous certification process is reserved for equipment and/or devices that either employ new technologies, involve complex testing procedures, or have a high risk of causing harmful interference. Under the FCC’s newly adopted procedures, verification and DoC are being replaced with a single process— “Supplier’s Declaration of Conformity (SDoC). The Commission believes that this new process will be more efficient for RF devices that are well suited for self approval – i.e., equipment that has a strong record of compliance and for which there is minimal risk of harmful interference. Equipment tested under the SDoC process will no longer be required to display the FCC logo as is currently required for devices approved using the DoC process. Nonetheless, the FCC will maintain the requirement to display a compliance statement and the identity of the responsible party, and apply it to all self-approved devices, but permit it to be included with other information provided to the user instead of being displayed on the device itself. This compliance statement will represent a new requirement for verified devices, but should not increase the burden on equipment manufacturers, since it replaces the requirement for a label on the device itself confirming the device’s compliance.

In order to permit equipment manufacturers to transition from the current verification of DoC systems to the SDoC regime, the FCC has determined that while the new procedure will be effective immediately upon publication in the Federal Register, equipment manufacturers will be permitted to “continue to self-approve products using the existing DoC or verification procedures for up to one year from the effective date of the rules if they so choose.” Further, the FCC has clarified that any equipment authorized under the verification or DoC procedures prior to the end of the transition period will remain valid without any further action by the FCC, so long as the equipment has not been modified in a manner that would require the issuance of a new equipment authorization under the FCC’s new rules.

The FCC is also modifying its labeling rules to comply with the Enhanced Labeling, Accessing, and Branding of Electronic Licenses Act (E-LABEL Act). The E-LABEL Act applies to all RF devices that have the “capability to digitally display labeling and regulatory information”, and requires the FCC to adopt rules which would allow manufacturers of RF devices to utilize electronic labeling in place of a physical label. In this regard, labeling must be accessible within 3 steps, meaning that the end-user must be able to access the information without having to drill down more than 3 steps. Further, manufacturers will be required to provide easily accessible instructions on how to access regulatory information — either in the product packaging material, operating instruction booklet or on a product-related website. If a product-related website is used, then the packaging material must contain a statement that the information on accessing the regulatory information is available on the product-related Internet site, along with instructions on how to access the direct website. Further, RF devices that rely on another device to operate or on a wireless or remote connection and have no display must have a physical label unless the RF device can only be used in conjunction with a device that does have a screen. This is consistent with Canadian equipment authorization procedures.

The Commission has also eliminated the requirement for importers to file with U.S. Customs and Border Protection (CBP) the FCC Form 740 – the FCC’s unique import declaration for RF devices brought into the United States. Because of the exponential increase in imported RF devices, this filing requirement has become an unwieldy tool for the FCC and it has placed an increasingly substantial burden on importers. At the same time, the CBP’s revised database and the increasing availability of product information on the Internet and through other means have reduced the practical need for the form.

Finally, the FCC has updated its specific measurement procedures and clarified that certain standards may be used for demonstrating that RF equipment complies with the FCC’s rules. These changes will allow the FCC to respond more quickly to changes in technology and international standards, and will speed the approval of new RF devices.

BloostonLaw Contacts: John Prendergast and Richard Rubino

Virginia First State to Opt-In to First Net

On July 10, Gov. Terry McAuliffe (D) announced that Virginia became the first state to opt-in to FirstNet’s National Public Safety Broadband Network.

In signing the letter of intent, Gov. McAuliffe stated that “I am proud that Virginia is the first state in the nation to opt in to this program that will help our first responders communicate during times of emergency.” McAuliffe continued that “[w]hile this is only the beginning of the process, I look forward to the continued coordinated efforts amount Virginia, FirstNet, and AT&T to provide public safety officials with innovative new technologies that will help them keep Virginians safe.”

The Governor’s press release indicates that public safety subscribers on AT&T’s system will be able to take advantage of priority service on AT&T’s existing LTE nationwide network, and that by the end of 2017, public safety subscribers will have preemption capability on the network - which is aimed at ensuring capacity is available during times of emergency.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Provides Language for Wireless Microphone Consumer Disclosure

On July 24, the FCC issued an Order provide the specific language that must be used in the Consumer Disclosure required by the Wireless Microphones R&O, which is applicable to persons who manufacture, sell, lease, or offer for sale or lease, wireless microphone or video assist devices — either (a) wireless microphones or other low power auxiliary stations (“wireless microphones”) or video assist devices, authorized pursuant to Part 74, Subpart H of the Commission’s rules, or (b) unlicensed wireless microphones authorized pursuant to Section 15.236 — to the extent that these devices are capable of operating in the 600 MHz service band (617-652 MHz / 663-698 MHz).

The disclosure must read:

This particular wireless microphone device operates in portions of the 617-652 MHz or 663-698 MHz frequencies. Beginning in 2017, these frequencies are being transitioned by the Federal Communications Commission (FCC) to the 600 MHz service to meet increasing demand for wireless broadband services. Users of this device must cease operating on these frequencies no later than July 13, 2020. In addition, users of this device may be required to cease operations earlier than that date if their operations could cause harmful interference to a 600 MHz service licensee’s wireless operations on these frequencies. For more information, visit the FCC’s wireless microphone website at www.fcc.gov/wirelessmicrophones-guide or call the FCC at 1-888- CALL-FCC (TTY: 1-888-TELL-FCC).

On August 5, 2015, the Commission adopted the Wireless Microphones R&O, which established various rules applicable to wireless microphones (and other low power auxiliary stations) that operate on a licensed basis in the TV bands (which at that time included TV channels 2-51 except channel 37). Anticipating the repurposing of a portion of the TV bands for new 600 MHz wireless services after the close of the broadcast television incentive auction, the Commission took several actions to ensure that the use of wireless microphones does not cause harmful interference to new 600 MHz service licensees’ wireless operations. Among other actions, the Commission adopted the Consumer Disclosure requirement set forth in Sections 74.851(k) and 15.37(k), which is the subject of the instant order.

In adopting a Consumer Disclosure requirement, the Commission explained that consumers will need to be informed of the changes that will affect their use of wireless microphones in the portion of the TV bands that is being repurposed following the broadcast television incentive auction, the conditions associated with their continued use of the 600 MHz service band during the 39-month post-auction transition period, and their need to cease operations in the 600 MHz service band no later than the end of this transition period.

BloostonLaw Contacts: John Prendergast and Richard Rubino

Signal Jamming Produces $22K Fine

The FCC has issued a $22,000 Notice of Apparent Liability for Forfeiture against Ravi’s Import Warehouse for operating a cellular phone jammer at its commercial premises in Dallas, Texas. Signal jammers, which transmit a signal that is designed to overpower, jam, or interfere with authorized communications, are illegal in the United States.

In this case, the FCC received a complaint from AT&T that one of its base stations was receiving harmful interference in a manner that made it appear as though a signal jammer was in use. Ravi’s owner admitted that it had been using a signal jammer to prevent workers from using their wireless phones while at work and that it had previously been warned by AT&T against the use of signal jamming equipment. The owner of Ravi refused to surrender the signal jammer to the FCC, but instead, offered to sell it to the FCC’s enforcement agent.

The use of signal jammers can create risks to public safety, due to the potential for harmful interference to wireless mobile communications. In particular, signal jammers have been known to block cell phone activity, including callers’ ability to make 911 or other emergency calls. Likewise, jammers can also prevent consumers and businesses from engaging in numerous daily forms of communications, including “routine” uses with safety implications, such as mapping/GPS applications.

If you receive harmful interference that cannot otherwise be explained, please call our office for assistance.

BloostonLaw Contacts: John Prendergast and Richard Rubino

Comment Due on Aug 14 on Use of High Seas Marine Channels by First Responders and Fed Govt . During Disasters

The FCC is seeking comment on a request for waiver by Shipcom and Global HF Net to permit the use of high frequency (HF) Public Coast stations by first responders and federal agencies during a natural disaster. Comments are due by August 14, 2017 and reply comment by August 29, 2017.

In 2010, Shipcom received a waiver of Rule Section 80.123 to permit the use of HF public coast frequencies by first responders during catastrophic situations when normal communications facilities were unavailable. In granting the waiver, the FCC concluded that the limited use of HF maritime spectrum would enhance public safety during disasters by allowing service to land-based (base and mobile) public safety stations on maritime HF spectrum during a natural or man-made disaster. The waiver also permitted monthly testing and training so that personnel would be familiar with the equipment in the event of an emergency.

In February 2017, Shipcom and its affiliate, Global HF Net, requested not only that the waiver be extended to Global HF Net, but that the scope of the waiver be expanded to include federal agencies. The rationale is that federal agencies typically put boots on the ground with state and local governments in order to respond to disasters.

Please contact our office if you are interested in supporting this proposal or if you have any concerns that the use of HF Public Coast spectrum in this manner could adversely affect your operations.

Comments due on August 14, 2017; Reply Comments due on August 29, 2017.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC to Consider Expanded Use of Mid-Band Spectrum for Super-Fast Fixed Wireless Services

FCC staff is working on a Notice of Inquiry (NOI) that could lead to expanded use of certain mid-band spectrum for fixed wireless broadband services, which proponents believe could enable multiple providers to offer competitive gigabit or near-gigabit service.

FCC Commissioners are likely to vote August 3 on an NOI concerning additional uses for spectrum in the 3.7 to 4.2 GHz and 6 GHz bands, which are currently used for the Fixed Satellite Service (FSS). The item grew out of a Petition for Rulemaking filed last October by the Fixed Wireless Communications Coalition (FWCC), seeking modified coordination procedures in bands shared between terrestrial and the Fixed Satellite Service. FWCC membership consists of providers, users, and manufacturers of terrestrial Fixed Service (FS) radio communications services and equipment.

Because FCC rules permit FSS earth stations to coordinate across an entire frequency band, and over the entire geostationary arc — regardless of how little spectrum the earth stations plan to use — large amounts of spectrum shared by the FS and FSS can go needlessly unused. Earlier this year, both Google Fiber and Nokia filed comments in support of the FWCC Petition urging the Commission to consider more broadly whether rule changes can open additional opportunities for service in the 3.7 GHz to 4.2 GHz spectrum band.

“The current Part 101 regulations for these frequencies are optimized for high-power, long-haul microwave transmissions that are of diminished importance in the era of fiber-optic communications,” wrote Google. “Several relatively simple changes—such as modifying power limits, specifically authorizing point-to-multipoint connections in the band, and updating antenna requirements — would enable use of the 3.7-4.2 GHz band for short-range, superfast broadband connections, as well.” Supporting comments by Nokia describe new uses for the 3.7-4.2 GHz band that are currently being investigated. “One such fixed wireless application that Nokia is testing in real-world environments with its partners is for extreme broadband in which traditionally wired broadband access to residential and commercial buildings is, instead, provided wirelessly. Fixed wireless service can become an alternative to fiber to the home to speed up deployments for last-mile broadband delivery.”

More recently, the Broadband Access Coalition, a group of fixed wireless technology companies and non-profit advocacy groups, filed a Petition for Rulemaking urging the Commission to amend and modernize Parts 25 and 101 of the rules “to authorize and facilitate a new, licensed fixed wireless point-to-multipoint (“P2MP”) high-speed broadband service on a shared basis in the underutilized 3700 – 4200 MHz band.

A July 10 blog post by Commissioner Mike O’Rielly describes the opportunity as “A Mid-Band Spectrum Win in the Making.” O'Rielly said the proposal would free up a total of 1700 megahertz of spectrum, 500 megahertz for licensed and up to 1.2 gigahertz for unlicensed purposes. Under the coalition proposal, existing licensees would either be protected or otherwise accommodated. For example, the fixed service users in the 6 GHz band would be protected by unlicensed users and could expand their usage.

“When presented with a viable proposal that would free spectrum for licensed and unlicensed purposes while protecting or accommodating incumbent licensees, the Commission should grab it with both hands and rejoice,” wrote O’Rielly. “That exact scenario presents itself in the 3.7 to 4.2 GHz and 6 GHz bands.”

Next generation (i.e., 5G) wireless networks will require high, mid and low band spectrum. Our clients that are interested in the possible use of fixed wireless for last mile broadband access, and/or the possibility that competitors may enter the market these services, should stay apprised of the NOI and any subsequent rulemaking that may come as soon as next year.

BloostonLaw Contacts: John Prendergast, Richard Rubino and Cary Mitchell

Public Safety and Homeland Security Bureau Workshop on Improving Situational Awareness During 911 Outages

The FCC’s Public Safety and Homeland Security Bureau will host a public workshop on September 11, 2017, to discuss best practices for improving situational awareness during 911 outages. Topics addressed in the workshop will include how to strengthen Public Safety Answering Point 911 service outage notifications and how to best communicate with consumers about alternative methods of accessing emergency services. The workshop will be held in the FCC’s Commission Meeting Room at FCC Headquarters, 445 12th Street, SW Washington, DC 20554. Further details regarding the workshop participants, roundtable discussion topics, and times will be announced by a public notice that will be issued at a future date.

If you are unable to make it to Washington, DC, the FCC will also broadcast the meeting live with open captioning over the Internet from the FCC's web page at www.fcc.gov/live/. The FCC’s webcast is free to the public.

BloostonLaw Contacts: John Prendergast and Richard Rubino

“MDZhB” has been broadcasting since 1982. No one knows why.

By Zaria Gorvett
2 August 2017

In the middle of a Russian swampland, not far from the city of St Petersburg, is a rectangular iron gate. Beyond its rusted bars is a collection of radio towers, abandoned buildings and power lines bordered by a dry-stone wall. This sinister location is the focus of a mystery which stretches back to the height of the Cold War.

It is thought to be the headquarters of a radio station, “MDZhB”, that no-one has ever claimed to run. Twenty-four hours a day, seven days a week, for the last three-and-a-half decades, it’s been broadcasting a dull, monotonous tone. Every few seconds it’s joined by a second sound, like some ghostly ship sounding its foghorn. Then the drone continues.

Once or twice a week, a man or woman will read out some words in Russian, such as “dinghy” or “farming specialist”. And that’s it. Anyone, anywhere in the world can listen in, simply by tuning a radio to the frequency 4625 kHz.

It’s so enigmatic, it’s as if it was designed with conspiracy theorists in mind. Today the station has an online following numbering in the tens of thousands, who know it affectionately as “the Buzzer”. It joins two similar mystery stations, “the Pip” and the “Squeaky Wheel”. As their fans readily admit themselves, they have absolutely no idea what they are listening to.

Anyone can listen to the Buzzer, simply by tuning a radio to the frequency 4625 kHz (Credit: iStock)

In fact, no-one does. “There’s absolutely no information in the signal,” says David Stupples, an expert in signals intelligence from City University, London.

What’s going on?

The frequency is thought to belong to the Russian military, though they’ve never actually admitted this. It first began broadcasting at the close of the Cold War, when communism was in decline. Today it’s transmitted from two locations — the St Petersburg site and a location near Moscow. Bizarrely, after the collapse of the Soviet Union, rather than shutting down, the station’s activity sharply increased.

There’s no shortage of theories to explain what the Buzzer might be for — ranging from keeping in touch with submarines to communing with aliens. One such idea is that it’s acting as a “Dead Hand” signal; in the event Russia is hit by a nuclear attack, the drone will stop and automatically trigger a retaliation. No questions asked, just total nuclear obliteration on both sides.

This may not be as wacky as it sounds. The system was originally pioneered in the Soviet era, where it took the form of a computer system which scanned the airwaves for signs of life or nuclear fallout. Alarmingly, many experts believe it may still be in use. As Russian president Vladimir Putin pointed out himself earlier this year, “nobody would survive” a nuclear war between Russia and the United States. Could the Buzzer be warding one off?

As it happens, there are clues in the signal itself. Like all international radio, the Buzzer operates at a relatively low frequency known as “shortwave”. This means that — compared to local radio, mobile phone and television signals — fewer waves pass through a single point every second. It also means they can travel a lot further.

While you’d be hard pressed to listen to a local station such as BBC Radio London in a neighbouring county, shortwave stations like the BBC World Service are aimed at audiences from Senegal to Singapore. Both stations are broadcast from the same building.

If the "dead hand" system did not detect signs of a preserved military hierarchy it would automatically trigger a retaliation (Credit: Public Domain/ US DoD)

It’s all thanks to “skywaves”. Higher frequency radio signals can only travel in a straight line, eventually becoming lost as they bump into obstacles or reach the horizon. But shortwave frequencies have an extra trick — they can bounce off charged particles in the upper atmosphere, allowing them to zig-zag between the earth and the sky and travel thousands, rather than tens, of miles.

Which brings us back to the Dead Hand theory. As you might expect, shortwave signals have proved extremely popular. Today they’re used by ships, aircraft and the military to send messages across continents, oceans and mountain ranges. But there’s a catch.

The lofty layer isn’t so much a flat mirror, but a wave, which undulates like the surface of the ocean. During the day it moves steadily higher, while at night, it creeps down towards the Earth. If you want to absolutely guarantee that your station can be heard on the other side of the planet – and if you’re using it as a cue for nuclear war, you probably do — it’s important to change the frequency depending on the time of day, to catch up. The BBC World Service already does this. The Buzzer doesn’t.

Another idea is that the radio station exists to “sound” out how far away the layer of charged particles is. “To get good results from the radar systems the Russians use to spot missiles, you need to know this,” says Stupples. The longer the signal takes to get up into the sky and down again, the higher it must be.

Alas, that can’t be it either. To analyse the layer’s altitude the signal would usually have a certain sound, like a car alarm going off – the result of varying the waves to get them just right. “They sound nothing like the Buzzer,” says Stupples.

Intriguingly, there is a station with some striking similarities. The “Lincolnshire Poacher” ran from the mid-1970s to 2008. Just like the Buzzer, it could be heard on the other side of the planet. Just like the Buzzer, it emanated from an undisclosed location, thought to be somewhere in Cyprus. And just like the Buzzer, its transmissions were just plain creepy.

At the beginning of every hour, the station would play the first two bars of an English folk tune, the Lincolnshire Poacher.

“Oh ‘tis my delight on a shining night
In the season of the year
When I was bound apprentice in famous Lincolnshire
‘Twas well I served my master for nigh on seven years…”

After repeating this 12 times, it would move on to messages read by the disembodied voice of a woman reading groups of five numbers – “1-2-0-3-6” – in a clipped, upper-class English accent.

To get to grips with what was going on, it helps to go back to the 1920s. The All-Russian Co-operative Society (Arcos) was an important trade body, responsible for overseeing transactions between the UK and the early Soviet Union. Or at least, that’s what they said they did.

After the Arcos raid in London, the Russians realised they needed a better way to communicate with spies hiding abroad (Credit: Getty)

In May 1927, years after a British secret agent caught an employee sneaking into a communist news office in London, police officers stormed the Arcos building. The basement had been rigged with anti-intruder devices and they discovered a secret room with no door handle, in which workers were hurriedly burning documents.

It may have been dramatic, but the British didn’t discover anything that they didn’t already know. Instead the raid was a wake-up call to the Soviets, who discovered that MI5 had been listening in on them for years.

“This was a blunder of the very first order,” says Anthony Glees, who directs the Centre for Security and Intelligence Studies at the University of Buckingham. To justify the raid, the prime minister had even read out some of the deciphered telegrams in the House of Commons.

The upshot was that the Russians completely reinvented the way messages are encrypted. Almost overnight, they switched to “one-time pads”. In this system, a random key is generated by the person sending the message and shared only with the person receiving it. As long as the key really is perfectly random, the code cannot be cracked. There was no longer any need to worry about who could hear their messages.

Enter the “numbers stations” — radio stations that broadcast coded messages to spies all over the world. Soon even the British were doing it: if you can’t beat them, join ‘em, as they say. It’s quite difficult to generate a completely random number because a system for doing so will, by its very nature, be predictable — exactly what you’re trying to avoid. Instead officers in London found an ingenious solution.

They’d hang a microphone out of the window on Oxford Street and record the traffic. “There might be a bus beeping at the same time as a policeman shouting. The sound is unique, it will never happen again,” says Stupples. Then they’d convert this into a random code.

Of course, that didn’t stop people trying to break them. During World War Two, the British realised that they could, in fact, decipher the messages — but they’d have to get their hands on the one-time pad that was used to encrypt them. “We discovered that the Russians used the out-of-date sheets of one-time pads as substitute toilet paper in Russian army hospitals in East Germany,” says Glees. Needless to say, British intelligence officers soon found themselves rifling through the contents of Soviet latrines.

The new channel of communication was so useful, it didn’t take long before the numbers stations had popped up all over the world. There was the colourfully named “Nancy Adam Susan”, “Russian Counting Man” and “Cherry Ripe” — the Lincolnshire Poacher’s sister station, which also contained bars of an English folk song. In name at least, the Buzzer fits right in.

It also fits with a series of arrests across the United States back in 2010. The FBI announced that it had broken up a “long term, deep cover” network of Russian agents, who were said to have received their instructions via coded messages on shortwave radio – specifically 7887 kHz.

Messages encrypted using one time pads cannot be cracked (Credit: Getty)

Now North Korea are getting in on the act, too. On 14 April 2017, the broadcaster at Radio Pyongyang began: “I’m giving review works in elementary information technology lessons of the remote education university for No 27 expedition agents.” This ill-concealed military message was followed by a series of page numbers – No 69 on page 823, page 957 – which look a lot like code.

It may come as a surprise that numbers stations are still in use – but they hold one major advantage. Though it’s possible to guess who is broadcasting, anyone can listen to the messages – so you don’t know who they are being sent to. Mobile phones and the internet may be quicker, but open a text or email from a known intelligence agency and you could be rumbled.

It’s a compelling idea: the Buzzer has been hiding in plain sight, instructing a network of illicit Russian spies all over the world. There’s just one problem. The Buzzer never broadcasts any numbered messages.

This doesn’t strictly matter, since one-time pads can be used to translate anything — from code words to garbled speech. “If this phone call was encrypted you’d hear “…enejekdhejenw…’ but then it would come out the other side sounding like normal speech,” says Stupples. But this would leave traces in the signal.

To send information over the radio, essentially all you’re doing is varying the height or spacing of the waves being transmitted. For example, two low waves in a row means x, or three waves closer together means y. When a signal is carrying information, instead of neat, evenly spaced waves like ripples on the ocean, you’re left with a wave like the jagged silhouette of an ECG.

During the Cold War, Soviet spies were instructed via shortwave radio (Credit: Alamy)

This isn’t the Buzzer. Instead, many believe that the station is a hybrid of two things. The constant drone is just a marker, saying “this frequency is mine, this frequency is mine…” to stop people from using it.

It only becomes a numbers station in moments of crisis, such as if Russia were invaded. Then it would function as a way to instruct their worldwide spy network and military forces on standby in remote areas. After all, this is a country around 70 times the size of the UK.

It seems they’re already been practicing. “In 2013 they issued a special message, ‘COMMAND 135 ISSUED’ that was said to be test message for full combat readiness,” says Māris Goldmanis, a radio enthusiast who listens to the station from his home in the Baltic states.

The mystery of the Russian radio may have been solved. But if its fans are right, let’s just hope that drone never stops.

Brad Dye, Ron Mercer, Allan Angus, Vic Jackson, and Ira Wiesenfeld are friends and colleagues who work both together and independently, on wireline and wireless communications projects.

Click here for a summary of their qualifications and experience. Each one has unique abilities. We would be happy to help you with a project, and maybe save you some time and money.

Note: We do not like Patent Trolls, i.e. “a person or company who enforces patent rights against accused infringers in an attempt to collect licensing fees, but does not manufacture products or supply services based upon the patents in question.” We have helped some prominent law firms defend their clients against this annoyance, and would be happy to do some more of this same kind of work.

Some people use the title “consultant” when they don't have a real job. We actually do consulting work, and help others based on our many years of experience.

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“If you would know the road ahead, ask someone who has traveled it.”
— Chinese Proverb

Wireless Network Planners
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R.H. (Ron) Mercer Consultant 217 First Street East Northport, NY 11731
Telephone: 631-786-9359
www.wirelessplanners.com
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“Our prime purpose in this life is to help others. And if you can't help them, at least don't hurt them.”

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Music Always Unites Us • Playing For Change Foundation

Published on Aug 1, 2017
Each small act of kindness affects lives unknown. Kindness expands each time it is passed until a simple courtesy becomes active courage. This is the amazing story behind PFCF's 10 years of encouraging a new generation of peacemakers through the power of music. MUSIC ALWAYS UNITES US highlights our recent efforts in Nepal and Thailand offering a glimpse into the future of this groundbreaking work. What unites us, is much greater than what divides us. This is what change looks like.