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Wireless News Aggregation

Friday — March 29, 2019 — Issue No. 849

Welcome Back To The Wireless Messaging News

Forget everything you remember about BlackBerry

By Paul R. La Monica, CNN Business
Updated 10:28 AM ET, Fri March 29, 2019

New York (CNN Business) — BlackBerry is no longer a smartphone company. That's great news for BlackBerry investors.

BlackBerry (BB) shares surged more than 10% Friday morning after the company reported earnings and sales that topped forecasts. The company also raised its outlook for its current fiscal year. BlackBerry's stock has now surged more than 40% so far in 2019.

The key to BlackBerry's success: a transition from the cutthroat business of selling hardware to the far more lucrative world of software — particularly cybersecurity and the so-called Internet of Things for connected devices like cars.

"Everyone remembers BlackBerry as a cell phone company," said BlackBerry CEO John Chen in an interview with CNN Business Friday morning. "But a big part of our business now is security."

Since Chen took over BlackBerry in late 2013, he has revamped the company to focus more on software. The company stopped making its own branded phones in 2016 and now relies on partners to do so.

The company now generates a majority of its sales from software and services to big businesses as well as licensing.

BlackBerry also recently acquired Cylance, a leader in using artificial intelligence and machine learning for cybersecurity. Cylance sells a lot of its products to banks.

Chen told CNN Business that BlackBerry may do some other small acquisitions to complement the Cylance business as well as its QNX software that powers infotainment systems in cars.

But the message to Wall Street is clear. BlackBerry, whose corporate survival was in doubt shortly before Chen took charge as the company was losing money and hemorrhaging cash, is no longer on death's door. It's thriving.

"We're done rebuilding. We're looking to invest." Chen said.

Source: CNN Business

We need your help. This is probably the only remaining news source about paging and wireless messaging.

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Two contributions were received last week. Thank you very much.


Wireless Messaging News

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

About Us

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.

We are having a cold spell in Southern, Illinois

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.


Let's get together and share ideas. Our competitors are not other paging companies, they are other technologies.

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 Policy

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 own opinions.

Prism-IPX Systems is growing and they are looking for more good software developers with communications experience. Additional information is available on their web site. Click here.

Service Monitors and Frequency Standards for Sale

Motorola Service Monitor

IFR Service Monitor

Efratom Rubidium Standard

(Images are typical units, not actual photos of items offered for sale here.)

Qty Item Notes
2 Late IFR 500As with new batteries
1 Motorola R 2001D  
4 Motorola R 2400 and 2410A  
5 Motorola R 2600 and R 2660 late S/Ns  
4 Motorola R 1200  
2 Motorola R 2200  
2 Stand-alone Efratom Rubidium Frequency Standards 10 MHz output
1 Telawave model 44 wattmeter Recently calibrated
1 IFR 1000S  
All sold with 7 day ROR (Right of Refusal), recent calibration, operation manual and accessories  
Factory carrying cases for each with calibration certificate  
Many parts and accessories  


Frank Moorman animated left arrow

(254) 596-1124

E-mail address has been corrected.


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Advertiser Index

Easy Solutions  (Vaughan Bowden)
IWA Technical Services, Inc.  (Ira Wiesenfeld)
Leavitt Communications  (Phil Leavitt)
Prism Paging  (Jim Nelson & John Bishop)
Paging & Wireless Network Planners LLC  (Ron Mercer)
Wex International Limited

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Leavitt Communications

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Specialists in sales and service of equipment from these leading manufacturers, as well as other two-way radio and paging products:

bendix king COM

motorola blue Motorola SOLUTIONS



Contact us for price and availability please

Philip C. Leavitt
Leavitt Communications
7508 N. Red Ledge Drive
Paradise Valley, AZ 85253
Web Site:
Mobile phone: 847-494-0000
Telephone: 847-955-0511
Fax: 270-447-1909
Skype ID: pcleavitt

My Other Job

Making Passive Smartphone Amplifiers That Don't Require Electricity.

Brass Horn — Wood Base

When I first saw these acoustic amplifiers for Smartphones I thought they were really cool, so I decided to make some of them for sale. I have been pleasantly surprised that people are buying them.

E-mail me for pricing.


The most popular model — so far — has been one made from a Horn of Plenty hammered-brass planter that came from India — like this:

In stock at the The Owl’s Nest, 2006 Kelty Road, Franktown, Colorado 80116.


Hong Kong


W8001 (4 Line/8 Line IP67 Alphanumeric Pager)

W8008 Thinnest IP67 Rated Alphanumeric Pager 4 Line/8 Line, OLED Display

W2028 (2 Line/4 Line Alphanumeric Pager)

For Trade inquiries contact:
Eric Dilip Kumar

  • Available in VHF, UHF & 900 MHz Full Range Frequency Bands
  • We are OEM for Major Brand names in USA and Europe
  • We also Design and Manufacture POCSAG Decoder Boards
  • We can Design and Manufacture to customer specifications
  • Factory located in Shenzhen, China
  • Pagers have FCC, RoHs, C-Tick, CE-EMC, IC Approvals

Visit our websites for more details

For ESPAÑOL, PORTUGUÊS AND DEUTSCH versions, please go to:

Spok Holdings Inc (NASDAQ:SPOK) Stock Is Shorted More

Posted by Winifred Garcia on March 27, 2019 at 12:23 pm

Spok Holdings, Inc. (NASDAQ:SPOK) Logo The stock of Spok Holdings Inc (NASDAQ:SPOK) registered an increase of 22.19% in short interest. SPOK’s total short interest was 344,200 shares in March as published by FINRA. Its up 22.19% from 281,700 shares, reported previously. With 58,800 shares average volume, it will take short sellers 6 days to cover their SPOK’s short positions. The short interest to Spok Holdings Inc’s float is 2.09%.

The stock increased 0.96% or $0.13 during the last trading session, reaching $13.71. About 203,030 shares traded or 109.26% up from the average. Spok Holdings, Inc. (NASDAQ:SPOK) has declined 13.38% since March 27, 2018 and is downtrending. It has underperformed by 17.75% the S&P500.

Spok Holdings, Inc., through its subsidiary, Spok, Inc., provides various communications solutions to healthcare, government, and other enterprises in the United States, Europe, Canada, Australia, Asia, and the Middle East. The company has market cap of $265.19 million. The firm provides one-way messaging, including numeric messaging services, which enable subscribers to receive messages comprising numbers, such as phone numbers; and alphanumeric messages, including numbers and letters that enable subscribers to receive text messages. It currently has negative earnings. It also offers two-way messaging services that enable subscribers to send and receive messages to and from other wireless messaging devices, such as pagers, personal digital assistants, and personal computers; and voice mail, personalized greeting, message storage and retrieval, and equipment loss and/or maintenance protection to one-way and two-way messaging subscribers.

More notable recent Spok Holdings, Inc. (NASDAQ:SPOK) news were published by: which released: “Spok to Modernize Communications Throughout Veterans Affairs Hospitals — Business Wire” on December 06, 2018, also with their article: “Spok Holdings Inc (SPOK) Q4 2018 Earnings Conference Call Transcript — Motley Fool” published on February 28, 2019, published: “Spok Reports Fourth Quarter and Full Year 2017 Operating Results; Total Revenue Growth for Third Sequential Quarter — Business Wire” on February 28, 2018. More interesting news about Spok Holdings, Inc. (NASDAQ:SPOK) were released by: and their article: “Peninsula Regional Medical Center Improves Patient Care Coordination With Spok — Business Wire” published on October 31, 2017 as well as‘s news article titled: “Spok Unveils Two-Way Pager With Encryption Capabilities — Business Wire” with publication date: November 30, 2016.

Source: Money Making Articles  

Paging Transmitters 150/900 MHz

The RFI High Performance Paging Transmitter is designed for use in campus, city, state and country-wide paging systems. Designed for use where reliable simulcast systems where RF signal overlap coverage is critical.

  • Commercial Paging systems.
  • Healthcare Paging systems.
  • Public Safety Emergency Services Paging systems.
  • Demand Response Energy Grid Management.

Built-in custom interface for Prism-IPX ipBSC Base Controller for remote control, management and alarm reporting.

  • Use as a stand-alone unit or in wide area network.
  • Mix with other transmitter brands in an existing paging network.
  • Adjustable from 20-250 watts.
  • 110/240 VAC or 48VDC.
  • Absolute Delay Correction.
  • Remote Diagnostics.
  • Configurable alarm thresholds.
  • Integrated Isolator.
  • Superb Reliability.
  • Improved amplifier efficiency.
  • Most reliable high-powered paging transmitter available.

Prism-IPX Systems LLC.

11175 Cicero Dr., Alpharetta, GA 30022
Ph: 678-242-5290 Email:

Back To Paging


Still The Most Reliable Protocol For Wireless Messaging!

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If you are reading this, your potential customers are reading it as well. Please click here to find out about our advertising options.

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Easy Solutions

easy solutions

Providing Expert Support and Service Contracts for all Glenayre Paging Systems.

The GL3000 is the most prolific paging system in the world and Easy Solutions gladly welcomes you to join us in providing reliable support to the paging industry for many more decades in the future.

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.

  • We treat our customers like family. We don’t just fix problems . . . We recommend and implement better cost-effective solutions.
  • We are not just another vendor . . . We are a part of your team. All the advantages of high priced full-time employment without the cost.
  • We are not in the Technical Services business . . . We are in the Customer Satisfaction business.

Experts in Paging Infrastructure

  • Glenayre, Motorola, Unipage, etc.
  • Excellent Service Contracts
  • Full Service—Beyond Factory Support
  • Making systems More Reliable and MORE PROFITABLE for over 30 years.

Please see our web site for exciting solutions designed specifically for the Wireless Industry. We also maintain a diagnostic lab and provide important repair and replacement parts services for Motorola and Glenayre equipment. Call or  e-mail  us for more information.

Easy Solutions
3220 San Simeon Way
Plano, Texas 75023

Vaughan Bowden
Telephone: 972-898-1119
Telephone: 214 785-8255

Easy Solutions


“Is Paging Going Away?” by Jim Nelson

  • Click here for English.
  • Click here for German. (Berlin Revision: November 8, 2016)
  • Click here for French.

Here is an English PDF edit of this paper formatted with page breaks and suitable for printing.

Volunteers needed for translations into other languages.


I would like to recommend Easy Solutions for Support of all Glenayre Paging Equipment. This Texas company is owned and operated by Vaughan Bowden. I have known Vaughan for over 35 years. Without going into a long list of his experience and qualifications, let me just say that he was the V.P. of Engineering at PageNet which was—at that time—the largest paging company in the world. So Vaughan knows Paging.

GTES is no longer offering support contracts. GTES was the original group from Vancouver that was setup to offer support to customers that wanted to continue with the legacy Glenayre support. Many U.S. customers chose not to use this service because of the price and the original requirement to upgrade to version 8.0 software (which required expensive hardware upgrades, etc.). Most contracts ended as of February 2018.

If you are at all concerned about future support of Glenayre products, especially the “king of the hill” the GL3000 paging control terminal, I encourage you to talk to Vaughan about a service contract and please tell him about my recommendation.


Board of Advisors

The Wireless Messaging News
Board of Advisors

Frank McNeill
Founder & CEO
Communications Specialists
Jim Nelson
President & CEO
Prism Systems International
Kevin D. McFarland, MSCIS
Sr. Application Systems Analyst
Medical Center
Paul Lauttamus, President
Lauttamus Communications & Security
R.H. (Ron) Mercer
Wireless Consultant
Barry Kanne
Paging Industry Veteran
Ira Wiesenfeld, P.E.
Consulting Engineer
Allan Angus
Consulting Engineer

The Board of Advisor members are people with whom I have developed a special rapport, and have met personally. They are not obligated to support the newsletter in any way, except with advice, and maybe an occasional letter to the editor.


Can You Help The Newsletter?

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You can help support The Wireless Messaging News by clicking on the PayPal Donate button above. It is not necessary to be a member of PayPal to use this service.

Reader Support

Newspapers generally cost 75¢ $1.50 a copy and they hardly ever mention paging or wireless messaging, unless in a negative way. If you receive some benefit from this publication maybe you would like to help support it financially?

A donation of $50.00 would certainly help cover a one-year period. If you are wiling and able, please click on the PayPal Donate button above.

EXCLUSIVE: Patient data exposed at 2 Toronto hospitals, privacy commissioner investigating


The University Health Network (UHN) has changed the way it uses pagers to communicate after an investigation by 680 NEWS revealed more than 200 patients’ private information was easily accessible to the public.

A computer programmer came across the information of 223 Toronto General Hospital and Toronto Western Hospital patients in late January. He was able to access the information, contained in hospital pager messages, from his home more than 10 km away.

“I started to see the names of patients, their date of birth, blood test results, even requests to transport patients who had died to the hospital morgue,” said the computer programmer speaking on the condition of anonymity.

Pagers can send signals strong enough to travel across the GTA instantly but the messages from most have no protection. UHN confirmed it has used this unencrypted system for decades. The Information and Privacy Commissioner of Ontario is now investigating.

Almost anyone can get their hands on the pager data with $20 worth of hardware and two free software programs, the programmer said.

“You don’t need to be an expert. You just need to be able to follow instructions that tell you what to click on and just apply some very basic sense,” he said.

After 680 NEWS asked the UHN about the exposed data last week, the hospital network changed its system to stop transmitting private patient information through pagers.

“We turned off any communication of personal health information over the paging systems,” said David Jaffray, executive vice president of technology and innovation at UHN. “We reached out to our staff and reminded them of the importance of not putting patient health information on systems without encryption, like the pagers. We also reached out the Ontario privacy commissioner.”

According to Ontario’s health ministry, hospitals are required to “take steps to ensure that personal health information in their custody or control is protected against unauthorized use or disclosure,” said ministry spokesman David Jensen in an e-mail.

UHN is in the process of contacting affected patients.

Source: CityNews  

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Prism-IPX Systems


prism-ipx systems
Critical Messaging that works
Secure . . . Dependable . . .
and Encrypted

Who We Are

Prism-IPX is a leader in providing reliable communications systems using modern designs to meet today’s demands for critical message alerting and delivery. Prism-IPX designs versatile and robust Critical Message Management systems using paging and other wireless technologies for high performance and dependable communications.

What We Make

Prism-IPX Systems products include full-featured radio paging systems with VoIP input, IP based transmitter control systems and paging message encryption. Other options include e-mail messaging, remote switch controllers, Off-The-Air paging message decoders and logging systems.

Contact Us   left arrow

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Click on the image above for more info about advertising here.

INTERNET Protocol Terminal

The IPT accepts INTERNET or serial messaging using various protocols and can easily convert them to different protocols, or send them out as paging messages.

An ideal platform for hospitals, on-site paging applications, or converting legacy systems to modern protocols.

Input Protocols: Serial and IP
Output Protocols: Serial and IP
FLEX (optional PURC control)   POCSAG (optional PURC control)

Additional/Optional Features

  • Database of up to 5000 subscribers.
  • 4 serial ports on board.
  • Up to 8 phone lines (DID or POTS).
  • Can be configured for auto-fail-over to hot swap standby.
  • 1RU rack mount unit appliance—no moving parts.
  • Easily secure legacy system messages leaving site for HIPAA compliance.
  • Only purchase the protocols/options you need.
  • Add Paging Encryption for HIPAA compliance on site.

Prism-IPX Systems LLC.

11175 Cicero Dr., Alpharetta, GA 30022
Ph: 678-242-5290 e-mail:

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Paging Data Receiver PDR-4

The PDR-4 is a multi-function paging data receiver that decodes paging messages and outputs them via the serial port, USB or Ethernet connectors.

Designed for use with Prism-IPX ECHO software Message Logging Software to receive messages and log the information for proof of transmission over the air, and if the data was error free.

  • Option—decode capcode list or all messages.
  • Large capcode capacity.
  • Serial, USB and Ethernet output.
  • POCSAG or FLEX page decoding, special SA protocols.
  • Receivers for paging bands in VHF, UHF, 900 MHz.
  • Message activated Alarm Output.
  • 8 programmable relay outputs.
  • Send notifications of a system problem.
  • Synthesized Receiver Tuning.
  • Selectivity better than 60 dB.
  • Frequencies 148-174, 450-470, 929-932 MHz.
  • Image Rejection better than 55 dB.
  • Spurious Rejection better than 55 dB.
  • Channel Spacing 12.5 or 25 kHz.
  • Power 5VDC.
  • Receiving Sensitivity 5µV at 1200 bps.

Prism-IPX Systems LLC.

11175 Cicero Dr., Alpharetta, GA 30022
Ph: 678-242-5290 e-mail:

Wireless Network Planners

Wireless Network Planners
Wireless Specialists

R.H. (Ron) Mercer
217 First Street
East Northport, NY 11731

ron mercer
Telephone: 631-786-9359 left arrow left arrow

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Consulting Alliance

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 left arrow 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.

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

Consulting Alliance

Remote AB Switches

ABX-1 switches are often used at remote transmitter sites to convert from old, outdated and unsupported controllers to the new modern Prism-IPX ipBSC base station controllers. Remotely switch to new controllers with GUI commands.


ABX-3 switches are widely used for enabling or disabling remote equipment and switching I/O connections between redundant messaging systems.


Common Features:

  • RJ45 for A, B and Common connectors.
  • Manual push button or use Prism IP commands to switch one or more relays.
  • Single or Dual Port Control card for IP or Serial connection.
  • Form C relay—control local connection.
  • Power Loss Indicator.
  • Rear Panel Connector for controlling the switch externally.
  • Power Source: 5VDC for ABX-1; 12VDC for ABX-3.

Prism-IPX Systems LLC.

11175 Cicero Dr., Alpharetta, GA 30022
Ph: 678-242-5290 e-mail:

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Leavitt Communications

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We can supply alphanumeric display, numeric display, and voice pagers.

We also offer NEW and refurbished Alphamate 250s, refurbished Alphamate IIs, the original Alphamate refurbished, and new and refurbished pagers, pager repairs, pager parts, and accessories. We are FULL SERVICE in Paging! Outstanding service is our goal.

E-mail Phil Leavitt ( ) for pricing and delivery information, or for a list of other available paging and two-way related equipment.

Phil Leavitt

7508 N. Red Ledge Drive
Paradise Valley, AZ 85253

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Friday, March 29, 2019

Volume 7 | Issue 62  

Raptor Breeding Season Brings Dangers for Tower Climbers

by Leslie Stimson, Inside Towers Washington Bureau Chief

Cell Tower Osprey Management

A big bird, like a raptor, can knock out a tower climber. Threats to climbers from nesting birds vary by body size and demeanor, according to Dr. Marco Restani, Senior Raptor Specialist with Cell Tower Osprey Management. “It’s unnerving to have a big bird attacking you on a tower,” said Restani. He shared safety tips and suggestions for what to do when a raptor has built a big nest on a tower that needs work during a NATE webinar Thursday titled “Climbing in The Bird-Tower Environment.”

“Birds want to build nests someplace that’s safe, near food and protected from the elements. Basically,” they see towers as “tall trees,” said Restani. Migratory birds are protected by federal law. The Migratory Bird Treaty Act carries a fine of up to $15,000 per count and six months in prison for killing or capturing these birds, including hawks, ospreys, eagles and owls. The Bald and Golden Eagle Protection Act is even more stringent, carrying penalties up to $200,000 and up to two years in prison for disturbing the birds, their eggs or nests.

It’s possible to take down a nest at the end of the breeding season, said Restani, provided you have a permit from federal and/or state wildlife authorities. Tower owners have restricted access to a tower that has a nest on it during breeding season. That season can last several months.

Before climbing such a tower, he recommends contacting a wildlife specialist to help develop a plan to protect tower climbers and the birds. The plan takes into account the species involved, weather conditions and the nature and duration of the work to be performed. “In general, bird sensitivity to human disturbance varies by the stage of the breeding cycle,” said Restani.

Perhaps a nesting bird wouldn’t be disturbed by two people working quietly at the base of the tower, whereas they might be, by several people working closer to the top of the tower for a longer length of time. But, emergencies happen. Restani described a situation in Mamaroneck, New York last year, when his company was called in to lend its expertise.

An antenna had become detached, and was dangling at the top of the tower near an osprey nest that still contained eggs. Wildlife protection agencies issued a permit that allowed work to be completed. The crew moved the eggs, completed the work, and returned the eggs to the nest in under two hours. At the end of nesting season, workers returned to find all three eggs hatched and the fledglings had flown out of the nest.

Source: Inside Towers newsletter Courtesy of the editor of Inside Towers.

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BloostonLaw Newsletter

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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 kind permission from the firm. The firm's contact information is included at the end of this section of the newsletter.

 BloostonLaw Telecom Update Vol. 22, No. 14 March 27, 2019 

Form 499-A, Access to Advanced Services Certifications Due April 1

The Annual Telecommunications Reporting Worksheet, known as FCC Form 499-A, is due on April 1. The filing, which applies to every telecommunications carrier that provides interstate, intrastate, and international telecommunications, and certain other entities that provide interstate telecommunications for a fee, requires the reporting of revenue information from January 1 through December 31 of the prior year, along with certain other information.

Also due April 1 is the Annual Access to Advanced Services Certification. This filing, which applies to all providers of telecommunications services and telecommunications carriers subject to Section 255 of the Telecommunications Act, requires the filer to certify that it has procedures in place to meet the relevant record-keeping requirements and actually keeps the required records.

BloostonLaw has an extensive experience with both filings and has a compliance manual available for the Accessibility filing.

BloostonLaw Contacts: Gerry Duffy and Sal Taillefer.


FCC Announces Tentative Agenda for April Meeting

On March 25, FCC Chairman Ajit Pai announced that the following items are tentatively on the agenda for the April Open Commission Meeting, which is currently scheduled for April 12:

  • 5G Incentive Auction Public Notice: a Public Notice seeking comment on procedures for the incentive auction of Upper Microwave Flexible Use Licenses in the Upper 37 GHz, 39 GHz, and 47 GHz Bands (Auction 103) for Next Generation Wireless Services. (AU Docket 19-59)
  • 37 GHz & 50 GHz Spectrum Band Rules: a Report and Order that would allow Fixed-Satellite Service earth stations to be individually licensed to transmit in the 50 GHz band and would establish a process for the Department of Defense to operate on a shared basis in the Upper 37 GHz band in limited circumstances. (GN Docket No. 14-177)
  • Fixed Wireless Infrastructure Rules: a Notice of Proposed Rulemaking that proposes to modernize the Commission’s rule for over-the-air-reception devices (OTARD) to facilitate the deployment of modern fixed wireless infrastructure. (WT Docket No. 19-71)
  • Channel Lineup Requirements: a Report and Order that would eliminate the requirement that cable operators maintain a channel lineup at their local office and would eliminate the requirement that certain cable operators make their channel lineup available via their online public inspection file. (MB Docket Nos. 18-92, 17-105)
  • USTelecom Partial Forbearance: a Memorandum Opinion and Order that would grant forbearance to Bell Operating Companies and independent incumbent carriers from certain unnecessary and outdated structural and nondiscrimination requirements. (WC Docket No. 18-141)
  • Rural Phone Rates: a Report and Order that would eliminate the high-cost program’s rate floor rule and end the federal mandate that raises the telephone rates paid by many rural Americans. See the article below for more. (WC Docket No. 10-90)

Public drafts of each of these items are linked in the summaries above. One-page cover sheets are included in the public drafts to help summarize each item. Being drafts, these documents are not final and may be changed before final consideration. Open Meetings are streamed live at and can be followed on social media with #OpenMtgFCC.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and John Prendergast.

Chairman Pai Announces Vote to Eliminate Rate Floor Rule

On March 21, FCC Chairman Ajit Pai announced that at its April meeting, the FCC will vote on an item eliminating the “rate floor.” The rate floor requires rural carriers to charge above a certain rate or lose Universal Service Fund support.

As we reported in a previous edition of the BloostonLaw Telecom Update, back in May of 2017 the FCC adopted a Notice of Proposed Rulemaking and Order in which it sought comment on eliminating the local rate floor for voice service and, in the interim, froze the rate floor at $18 while the NPRM was pending. In the NPRM, the FCC sought comment on whether it should change the current rate floor methodology or eliminate the rate floor and its accompanying reporting obligation entirely. Proposals included allowing carriers to charge a rate that is one standard deviation below the average urban rate; replacing the single, national rate floor with state or regional rate floors; or eliminating the rate floor altogether.

“The FCC’s rate floor is a counterproductive regulation that hurts rural Americans,” said Chairman Pai. “For example, unless the Commission takes action, many rural consumers will be forced to pay almost 50% more out of their pockets starting this July. That’s why we’ve heard from the AARP, the National Consumer Law Center, the National Tribal Telecommunications Association, and others that the rule makes service in rural areas less affordable. I’ve spoken for years against the rate floor and am pleased that the Commission will be voting in April on eliminating it. I hope my colleagues will join me in taking this step to provide needed relief to older Americans on fixed incomes, low-income Americans, and many others.”

FCC Adopts White Spaces Order

On March 19, the FCC adopted a Report and Order and Order on Reconsideration in its Unlicensed White Space dockets (ET 16-56, 14-165). In the Report and Order, the FCC took steps to “improve the accuracy and reliability of the fixed white space device data recorded in the white space databases and assure that the potential for these devices to cause interference to protected services is minimized.” In the Order on Reconsideration, the FCC modified the white space device antenna height rules “to allow improved broadband coverage in rural areas,” and the FCC resolved “certain outstanding white space reconsideration issues.”

Specifically, the FCC required all fixed white space devices to incorporate a geo-location capability such as GPS and eliminate the option that permitted the geographic coordinates of a fixed device to be determined by a professional installer. The FCC also adopted rules that allow the use of external geo-location sources by a fixed white space device when the device is used at a location where its internal geo-location capability does not function, such as deep inside a building. In addition, the FCC required fixed white space devices to periodically re-check their geographic coordinates at least once a day and report the coordinates to the white space database.

The FCC also addressed a number of petitions for reconsideration of the actions it took in the TV White Spaces Order. For the most part, the FCC affirmed its decisions, with the exception of increasing the maximum permissible fixed white space device antenna height above ground level in less congested areas. The FCC noted that it will address at a later time those petitions addressing push notifications and white space device operation on Channel 37, and that it has previously addressed petitions related to wireless microphones.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

Law & Regulation

On March 26, the FCC published in the Federal Register its Order establishing a comprehensive database for phone number disconnections, in an effort to address robocalling to reassigned numbers. Though effective, compliance deadlines for the requirements to maintain records regarding disconnections or ports and file associated reports have not been established.

The database is intended to enable any caller to verify whether a telephone number has been reassigned before calling that number. In order to keep the database current, each provider is required to report monthly to the database administrator the date of the most recent permanent disconnection for each number allocated to or ported to the provider. Providers required to retain and submit this information include wireless, wireline, and interconnected VoIP providers that obtain numbers — directly or indirectly — from the North American Numbering Plan Administrator (NANPA).

Carriers with questions about the reassigned number database should contact the firm for more information.

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

FCC Extends Part 15 Push Notification Requirement Waiver

On March 27, the FCC extended through September 30, 2019 a waiver of the push notification requirements for fixed and Mode II personal/portable white space devices and white space databases, which was due to expire on March 31, 2019.

To prevent interference to protected services, including licensed wireless microphones, certain white space devices are required to check a database at least once a day to obtain a list of available channels at their operating location, and the FCC adopted a requirement that database administrators push information about changes in channel availability information to white space devices in the areas where licensed wireless microphones will be used. A number of parties filed petitions for reconsideration of the push notification requirement, and since those petitions are still under consideration the FCC has chosen to extend the waiver.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

FCC Issues $2.32 Million Fine for Slamming/Cramming Violations

On March 21, the FCC issued a Press Release announcing that it has issued a $2.32 million fine against Michigan-based Long Distance Consolidated Billing Company for deceptive marketing practices: switching consumers’ carrier without authorization (“slamming”), and adding unauthorized charges to consumers’ bills (“cramming”).

The FCC began its investigation based initially on consumer complaints – largely from small businesses. The FCC reviewed more than 70 complaints received by the agency itself as well as complaints to various state regulatory agencies and the Better Business Bureau. The agency’s Enforcement Bureau further investigated through interviews with consumers, subpoenas, and reviewing documents provided by the company. The company, headquartered in Waterford, Michigan, is a non-facilities-based inter-exchange carrier providing long distance phone services.

The FCC’s investigation found that the company misrepresented its identity to consumers in order to deceive them. Telemarketers pretended to be representing small businesses’ and other consumers’ existing providers in order to trick the business or consumer into switching providers. Complaints included examples of the small businesses pushing back and pressing telemarketers as to their true identity, followed by the telemarketers repeatedly lying in response. Following this unauthorized switch, the company charged these consumers for its services.

BloostonLaw Contacts: Ben Dickens and Sal Taillefer.


Congress Introduces Communications Jobs Training Act

On March 21, Rep. Dave Loebsack (D-IA) and Rep. Markwayne Mullin (R-OK) introduced the “Communications Jobs Training Act of 2019.” Although the text of the legislation is not yet available, according to a summary it would create a competitive grant program, administered through the FCC, to establish or expand training programs for communications tower jobs. A previous version of the bill introduced but not passed in 2018 appropriated $20 million per year for three years.

FCC Commissioner Brendan Carr released the following statement:

“To ensure that America wins the race to 5G, we need to double the number of tower crews that are building this next-generation infrastructure. There is demand for up to 20,000 more tower workers. These are good-paying, 5G jobs. And as I’ve seen firsthand, America’s tower crews are unmatched in their skill, professionalism, and dedication. So I applaud Congressmen Loebsack and Mullin for their leadership and work to expand this skilled workforce. By creating a pipeline of talented tower crews, we can help extend America’s global leadership in wireless.”


APRIL 1: FCC FORM 499-A, TELECOMMUNICATIONS REPORTING WORKSHEET. This form must be filed by all contributors to the Universal Service Fund (USF) sup-port mechanisms, the Telecommunications Relay Service (TRS) Fund, the cost recovery mechanism for the North American Numbering Plan Administration (NANPA), and the shared costs of local number portability (LNP). Contributors include every telecommunications carrier that provides interstate, intrastate, and international telecommunications, and certain other entities that provide interstate telecommunications for a fee. Even common carriers that qualify for the de minimis exemption must file Form 499-A. Entities whose universal service contributions will be less than $10,000 qualify for the de minimis exemption. De minimis entities do not have to file the quarterly report (FCC Form 499-Q), which was due February 1, and will again be due May 1. Form 499-Q relates to universal and LNP mechanisms. Form 499-A relates to all of these mechanisms and, hence, applies to all providers of interstate, intrastate, and international telecommunications services. Form 499-A contains revenue information for January 1 through December 31 of the prior calendar year. And Form 499-Q contains revenue information from the prior quarter plus projections for the next quarter. (Note: the revised 499-A and 499-Q forms are now available.) Block 2-B of the Form 499-A requires each carrier to designate an agent in the District of Columbia upon whom all notices, process, orders, and decisions by the FCC may be served on behalf of that carrier in proceedings before the Commission. Carriers receiving this newsletter may specify our law firm as their D.C. agent for service of process using the information in our masthead. There is no charge for this service.

BloostonLaw Contacts: Hal Mordkofsky, Ben Dickens, and Gerry Duffy.

APRIL 1: ANNUAL ACCESS TO ADVANCED SERVICES CERTIFICATION. All providers of telecommunications services and telecommunications carriers subject to Section 255 of the Telecommunications Act are required to file with the FCC an annual certification that:

  1. states the company has procedures in place to meet the record-keeping requirements of Part 14 of the Rules;
  2. states that the company has in fact kept records for the previous calendar year;
  3. contains contact information for the individual or individuals handling customer complaints under Part 14;
  4. contains contact information for the company’s designated agent; and
  5. is supported by an affidavit or declaration under penalty of perjury signed by an officer of the company.

BloostonLaw Contacts: Gerry Duffy, Mary Sisak, Sal Taillefer.

MAY 1: FCC FORM 499-Q, TELECOMMUNICATIONS REPORTING WORKSHEET. All telecommunications common carriers that expect to contribute more than $10,000 to federal Universal Service Fund (USF) support mechanisms must file this quarterly form. The FCC has modified this form in light of its recent decision to establish interim measures for USF contribution assessments. The form contains revenue information from the prior quarter plus projections for the next quarter. Form 499-Q relates only to USF contributions. It does not relate to the cost recovery mechanisms for the Telecommunications Relay Service (TRS) Fund, the North American Numbering Plan Administration (NANPA), and the shared costs of local number portability (LNP), which are covered in the annual form (Form 499-A) that was due April 1.

BloostonLaw Contacts: Ben Dickens and Gerry Duffy.

MAY 31: FCC FORM 395, EMPLOYMENT REPORT. Common carriers, including wireless carriers, with 16 or more full-time employees must file their annual Common Carrier Employment Reports (FCC Form 395) by May 31. This report tracks carrier compliance with rules requiring recruitment of minority employees. Further, the FCC requires all common carriers to report any employment discrimination complaints they received during the past year. That information is also due on May 31. The FCC encourages carriers to complete the discrimination report requirement by filling out Section V of Form 395, rather than submitting a separate report.

Calendar At-a-Glance

Mar. 31 – FCC Form 525 (Delayed Phasedown CETC Line Counts) is due.
Mar. 31 – FCC Form 508 (ICLS Projected Annual Common Line Requirement) is due.

Apr. 1 – FCC Form 499-A (Annual Telecommunications Reporting Worksheet) is due.
Apr. 1 – Annual Accessibility Certification is due.
Apr. 3 – Comments are due on Truth in Caller ID Rules.
Apr. 8 – Reply comments are due on USF Overlap Auction NPRM.
Apr. 15 – Comments are due on IP CTS Management Rules.
Apr. 16 – Reply comments are due on Satellite Services Rules NPRM.
Apr. 22 – Reply comments are due on DBS Satellite System Licensing NPRM. Apr. 29 – Comments are due on Broadcast Ownership Rules.
Apr. 29 – Reply comments are due on IP CTS Management Rules.

May 1 – FCC Form 499-Q (Quarterly Telecommunications Reporting Worksheet) is due.
May 3 – Reply comments on Truth in Caller ID Rules are due.
May 29 – Reply comments on Broadcast Ownership Rules are due.
May 31 – FCC Form 395 (Annual Employment Report) is due.

Jun. 1 – Deadline to file AM/FM License Renewals – DC, MD, VA, WV.

 BloostonLaw Private User Update Vol. 19, No. 3 March 2019 

Comment Sought on 900 MHz Band Realignment Rules

On March 14, the FCC released a Notice of Proposed Rulemaking seeking comment on proposals to reconfigure the 900 MHz band to facilitate the development of broadband technologies and services as well, including for critical infrastructure. Comments will be due 60 days after publication in the Federal Register; Reply Comments will be due 90 days after publication in the Federal Register.

Specifically, the FCC has proposed to realign the 900 MHz band to create a 6 MHz broadband segment (3 MHz paired with a 3 MHz response channel, or “3/3”) between 897.5-900.5 MHz and 936.5-939.5 MHz, leaving two separate narrowband segments: a 1.5/1.5 megahertz segment (896-897.5/935-936.5 MHz) below the broadband segment and a .5/.5 megahertz segment (900.5-901/939.5-940 MHz) above the broadband segment, and to reserve the remainder of the 900 MHz band for continued narrowband operations. This would entail replacing the Land Mobile Service allocation in the 900 MHz band with a Mobile Except Aeronautical Mobile Service allocation on a co-primary basis with the Fixed Service, consistent with the allocations in the 890-902 MHz and 928-942 MHz bands in Region 2 of the International Table of Frequency Allocations.

To accomplish this, the FCC has proposed to authorize a market-driven, voluntary exchange process that would allow existing licensees to come together and mutually agree to a plan for relocating site-based incumbents and transitioning the band for broadband use. The process would limit basic eligibility for broadband licenses to those incumbents that hold 20 geographically licensed blocks of 900 MHz SMR spectrum, which the FCC anticipates would be “best positioned to facilitate the transactions necessary to effectuate relocation.” To be eligible for a new 900 MHz broadband license in a given county, the FCC proposes that the applicant must: (1) hold licenses covering the entire county for all 20 geographically-licensed SMR blocks, (2) reach an agreement to clear from the broadband segment, or demonstrate how it will protect, all covered incumbent licensees, and (3) agree to return to the FCC all 900 MHz licenses for the relevant county, including any site-based B/ILT or SMR licenses.

As alternatives to the proposed market-driven process, the FCC has also proposed two auction processes to accomplish the relocations necessary to provide sufficient contiguous spectrum for broadband services. The first would be an auction of overlay 900 MHz broadband licenses, coupled with the right to require the mandatory relocation of narrowband incumbents in the entire band. Under this approach, the FCC would conduct, where appropriate, an auction of a single 3/3 megahertz overlay license in a geographic area (e.g., county or other area which the FCC finds most suitable for this transition method). The second alternative would be an incentive auction to reduce the number of incumbents in the 900 MHz band. Under an incentive auction approach, the FCC would create a single 3/3 megahertz broadband license in each market by offering incentive-payments to existing licensees of SMR spectrum licensed on a Major Trading Area (MTA) basis, in exchange for relinquishing spectrum usage rights, while also repacking site-based and any holdout MTA licensees.

Finally, the FCC has proposed to designate the 900 MHz broadband service as a Miscellaneous Wireless Communications Service governed by Part 27 of the FCC’s rules. Broadband licensees in the 900 MHz broadband segment would be required to comply with licensing and operating rules that are applicable to all Part 27 services, including foreign ownership reporting, the new renewal criteria, and the 180-day permanent discontinuance of operations rule. The FCC is also seeking comment on proposed technical rules for the new broadband service.

Comments will be due 60 days after publication in the Federal Register; Reply Comments will be due 90 days after publication in the Federal Register.

BloostonLaw Contacts: John Prendergast and Richard Rubino.

FCC Begins Process of Withdrawing as Accounting Authority in Maritime Mobile and Maritime Mobile-Satellite Radio Services

The FCC has instructed its staff to begin consultations with Federal stakeholders, including the United States Coast Guard, in order to work with service providers to finalize and announce a plan to transition the functions and duties performed by the FCC as an accounting authority for those licensees in the Maritime Mobile and Maritime Mobile-Satellite radio Services who have not otherwise designated an accounting authority. The FCC expects that discussions will commence within the next 3-4 months. The FCC stated that it would provide a substantial transition period of up to one year following the announcement of a transition plan in order to ensure an orderly transition of the FCC’s accounting authority duties to private authorities.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Opens Frequencies Above 95 GHz for Experimental Use

The FCC has created a new category of experimental licenses for use of frequencies between 95 GHz and 3 terahertz (THz) to encourage the development of new communications technologies and to expedite the deployment of new services. This spectrum has long been considered the outermost horizon of the usable spectrum range, but rapid advancements in radio technology have made these bands especially ripe for new development.

Proponents believe there are substantial opportunities for innovation in these frequencies, especially for data-intensive high-bandwidth applications as well as imaging and sensing operations. Prior to this decision, the FCC had no rules for authorizing communications above 95 GHz, other than by amateur operators or through experiments of limited duration and scope.

The new “Spectrum Horizons” experimental licenses will give innovators the flexibility to conduct experiments lasting up to 10 years, and to more easily market equipment during the experimental period. The new rules also allow a total of 21.2 gigahertz of the spectrum to be used by unlicensed devices.

FCC Chairman Ajit Pai invited NYU Wireless Professor Ted Rappaport, who was instrumental in conducting ground-breaking millimeter wave research, to present his institution’s findings thus far on the opportunities afforded by the spectrum bands above 95 GHz, where “science fiction will become reality,” Rappaport told the FCC. A presentation that Rappaport delivered during the Open Meeting describes potential mmWave and THz applications involving wireless cognition (for robotic and drone fleet control), sensing (e.g., air quality detection and touchless smartphones), imaging (HD video radar and security body scanning), and what could eventually become 6G wireless services (e.g., wireless fiber for backhaul, intra-device radio communication).

The First Report and Order in ET Docket No. 18-21 provides opportunities for new experimental and unlicensed use in the frequencies above 95 GHz and the FCC believes this will help ensure that the United States stays at the forefront of wireless innovation. Moreover, study of these uses could ultimately lead to further rulemaking actions and additional licensing opportunities within the Spectrum Horizons bands.

BloostonLaw Contacts: John Prendergast, Cary Mitchell and Richard Rubino.

FCC Temporarily Freezes Non-Federal 3100-3550 MHz Band Applications

The FCC has announced a temporary freeze on the acceptance and processing of applications for new or expanded Part 90 Radiolocation Service operations in the 3100-3550 MHz frequency band. According to the FCC, the purpose of this freeze is to “preserve the current landscape of authorized operations in the 3100-3550 MHz band in light of Congress’ mandate that the Secretary of Commerce, working through the National Telecommunications and Information Administration (NTIA), and the Commission consider alternate uses of the band.”

Specifically, until further notice, the FCC will not accept or process: (1) applications for new licenses; (2) applications that seek to modify existing licenses by adding or changing frequencies or locations; (3) applications that seek to modify existing licenses by changing technical parameters in a manner that expands the station’s spectral or geographic footprint, such as, but not limited to, increases in bandwidth, power level, antenna height, or area of operation; and (4) any other application that could increase the degree to which the 3100-3550 MHz band currently is licensed. Affected applications that are now pending will not be processed further until the Commission decides how to proceed in this band.

This action does not apply to applications that would not materially increase spectral congestion in the band, including:

  1. applications to renew existing licenses without modification;
  2. applications that seek to modify existing licenses by deleting frequencies or locations;
  3. applications that seek to modify existing licenses by changing technical parameters in a manner that does not expand the station’s spectral or geographic coverage, such as decreases in bandwidth, power level, or antenna height;
  4. applications that seek to modify existing licenses by changing the number of associated mobile units or temporary fixed stations;
  5. applications that seek to modify existing licenses by adding or moving control points;
  6. applications to assign, transfer, or lease existing licenses;
  7. notices of construction or consummation;
  8. requests for extensions of time to construct or consummate previously granted applications;
  9. applications to cancel licenses; and
  10. applications for special temporary authority for short-term operations.

The FCC also noted that in the future, it may begin placing a special condition on new, renewed, and modified licenses for stations subject to this action to remind licensees that the stations may be subject to future relocation or other Commission action taken pursuant to or in connection with the MOBILE NOW Act.

BloostonLaw Contacts: John Prendergast and Richard Rubino.

Enforcement Reminder: Ensure That Radio Facilities Operate in Accordance with the Terms of Your License

The FCC’s Enforcement Bureau regularly conducts station inspections, which can either be routine or the result of an interference complaint. Recently and in response to the receipt of an interference complaint from a public safety entity, the FCC conducted an inspection of a Part 90 land mobile station in Paterson, New Jersey. The inspection revealed that while the licensee was authorized to operate its base and mobile radios on the frequency 159.8025 MHz, it was actually operating the base station on 154.8025 MHz without authority from the FCC.

This case illustrates the need to periodically compare the technical parameters on your station license to the actual operation of your radios, in order to ensure that your radio systems are being operated consistent with your license and the FCC’s Rules. As a result, in addition to making sure that your transmitters are operating on the correct frequency, you should also ensure that the base transmitter is at the correct location and that the height to tip of the antenna is correct. Likewise, you should also ensure that the radio transmitters are operating at the correct output power and effective radiated power (ERP), as well as verify that your equipment is using the emission designator(s) specified on the license. This is because the FCC does not permit licensees in the Part 90 land mobile services to make any technical changes to their radio operations without first obtaining FCC approval.

If there are any discrepancies, please contact our office so that we can help determine whether changes are required to your license or to your equipment.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Fines Carrier $2.32 Million for Tricking Small Businesses into Switching Carriers

The FCC recently announced that it was issuing a $2.32 million fine against Long Distance Consolidated Billing Company (LDCBC) of Waterford, Michigan for deceptive marketing practices, switching consumers’ carriers without authorization (slamming) and adding unauthorized charges to customer bills (cramming).

Like many slamming and cramming cases, the FCC’s investigation began based upon the receipt of consumer complaints – mostly from small businesses. In this regard, the FCC directly received more than 70 complaints, which was in addition to those filed through the Better Business Bureau (BBB) and various state regulatory agencies. Based upon these complaints, the FCC’s Enforcement Bureau interviewed customers, issued subpoenas and reviewed documents that were provided by LDCBC.

As a result of its investigation, the FCC determined that LDCBC had misrepresented its identity to consumers in order to deceive them. In particular, its telemarketers allegedly pretended to represent small businesses and other consumers’ existing providers in order to “trick” the business or consumer into switching providers. The FCC noted that complaints included examples of small businesses pushing back and pressing telemarketers as to their true identity and the telemarketer continuing to lie. The FCC pointed out that the deception and the unauthorized switch of carriers violated the Communications Act and that any charges by LDCBC likewise violated the Communications Act, since the charges were unauthorized.

Any office client that receives these sorts of solicitations and notices unauthorized charges on their phone bill should contact our office so that we can assist you with your complaint to the FCC.

BloostonLaw Contacts: John Prendergast, Ben Dickens and Gerry Duffy.

FCC Proposal Would Help First Responders Find 911 Callers in Multi-Story Buildings

The FCC has proposed to implement a vertical or z-axis, location accuracy metric of plus or minus 3 meters relative to the handset for each of the benchmarks and geographic requirements established by the FCC’s E911 wireless location accuracy rules in order to ensure that first responders and Public Safety Answer Points (PSAPs) can promptly find callers in a multi-story building during an emergency. The FCC believes that its proposed metric would allow first responders to more accurately identify the correct floor in a multi-story building and therefore reduce emergency response times and save lives and property. Comments are due 45 days from publication in the Federal Register and Reply Comments are due 75 days from publication in the Federal Register.

The FCC’s z-axis, location accuracy metric is nothing new. In 2015, the FCC established benchmarks and time-tables for the deployment of z-axis technology or dispatchable location (which includes a vertical location component) in the top 50 cellular market areas. A decision on the specific z-axis metric was deferred so that the FCC could receive additional testing data from the four nationwide carriers. This data was submitted by CTIA in August 2018 on behalf of the four nationwide carriers. According to the report, Stage Z testing sought to assess the accuracy of solutions that used barometric pressure sensors in the handset for determining the altitude in support of E911. The test results showed that in 80% of the NextNav test calls, vertical location accuracy was within 1.8 meters or less, while 80% of the Polaris calls were accurate to within 4.8 meters or less. In response to public comment, public safety organizations unanimously opposed CTIA’s proposed 5-meter metric as too imprecise to identify a caller’s floor.


The FCC is proposing a z-axis metric based on a 3-meter standard. The FCC stated that this will provide the final element of the FCC’s existing indoor location accuracy regime, which already included a time-table for CMRS providers to deliver vertical location information by deploying either a dispatchable location or z-axis technology in specific geographic areas. The FCC believes that its proposed z-axis metric will provide certainty to all parties and establish a focal point for future testing, development and implementation of evolving z-axis technologies.

The FCC is also proposing to amend Rule Section 20.18 in order require that by April 3, 2021, nationwide CMRS providers must deploy in each of the top 25 Cellular Market Areas either dispatchable location or z-axis technology in compliance with the 3-meter metric. In Cellular Market Areas where z-axis technology is used, nationwide CMRS carriers would be required to deploy the technology over 80% of the population in the Cellular Market Area. Two years later (April 23, 2023) these requirements would then expand to the top 50 Cellular Market Areas. Non-nationwide carriers that serve any of the top 25 or top 50 Cellular Market Areas would have an additional year to meet each of the benchmarks described above.

As a result, the FCC is seeking comment on:

  • The proposed 3-meter metric. Will it provide sufficient accuracy in most cases to get first responders to the caller’s floor? If 3 meters is not appropriate, what vertical location metric should be adopted?
  • Should the metric apply to 80% of wireless calls? If not, what would be an appropriate percentage of calls?
  • Should the z-axis metric apply only to devices equipped with barometric pressure sensors, devices manufactured after a certain date or should it apply to wireless calls from all mobile devices as proposed by the FCC?
  • Is the FCC’s conclusion that barometric sensor based solutions are likely to be scalable and therefore readily available to wireless consumers within the deployment timeframes described above accurate?

Comments are due 45 days from publication in the Federal Register and Reply Comments are due 75 days from publication in the Federal Register.

BloostonLaw Contacts: John Prendergast, Cary Mitchell and Richard Rubino


2120 L St. NW, Suite 300
Washington, D.C. 20037
(202) 659-0830
(202) 828-5568 (fax)


Harold Mordkofsky, 202-828-5520,
Benjamin H. Dickens, Jr., 202-828-5510,
Gerard J. Duffy, 202-828-5528,
John A. Prendergast, 202-828-5540,
Richard D. Rubino, 202-828-5519,
Mary J. Sisak, 202-828-5554,
D. Cary Mitchell, 202-828-5538,
Salvatore Taillefer, Jr., 202-828-5562,

This newsletter is not intended to provide legal advice. Those interested in more information should contact the firm.

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― George Gordon Byron (Lord Byron)

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Playing For Change
Published on Mar 22, 2019

As we continue celebrating Women's History Month, we are excited to share the PFC Band performing “Run,” featuring Titi Tsira and Claire Finley. Written by Claire and her friend Jason Lamson, this feel-good song was inspired by a riff that Jason wrote—I’m gonna run, as fast as I can.

“...And, I thought, so many songs that involve running play with the idea of running away from a bad thing. Instead, let's write a song that runs towards the good. Life can steer you in many different directions but if you stay true to your dreams and ideas....and really head straight for them, full steam....envisioning success, you might just find yourself in the right place, at the right time, doing exactly what you love,” says Claire.

We hope this song inspires you to never stop running towards your dreams!

Source: YouTube  

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