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Friday — March 6, 2020 — Issue No. 898

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These are the first passwords hackers will try when attacking your device

Haven't changed those default passwords yet? You really should.

By Steve Ranger | March 4, 2020 — 14:07 GMT (06:07 PST) | Topic: Security

More evidence that using weak or default passwords is a bad idea: they really are the first thing hackers try out when attempting to take over a device.

Security company F-Secure has a set of 'honeypot' or decoy servers set up in countries around the world to detect patterns in cyberattacks. The vast majority of traffic to these servers is a result of their discovery during scans of the Internet by hackers looking for devices to access.

The company said it has seen a significant increase in the traffic to these honeypots in the second half of last year. It said the rise in 'attack traffic' reflects the increasing number of threats to Internet of Things (IoT) devices.

"Honeypot traffic was driven by action aimed at the SMB and Telnet protocols, indicating continued attacker interest in the Eternal Blue vulnerability as well as plenty of infected IoT devices," the company said.

According to its data, SMB port 445 was the most-targeted port over the period, indicating that attackers are still keen to use SMB worms and exploits such as Eternal Blue, like Trickbot. Telnet was also commonly targeted, likely as part of attacks on IoT devices. The same is the case with probes of SSH on port 22, which enables secure remote access and is commonly associated with full administrative access.

Once a potentially vulnerable device is discovered, the next thing that attackers want to do is try to gain access to it.

According to F-Secure, the "ever-present" top choice of passwords for hackers to try was 'admin' — a password which really should not used for any device, and especially not one connected to the Internet. Other bad passwords on the list include '12345', 'default', 'password' and 'root'. Last year the UK's National Cyber Security Centre (NCSC) noted that the only slightly more complicated '123456' has been found 23 million times in the breaches.

The passwords that hackers try also reflect the sorts of devices they are currently targeting, F-Secure said: included on the list of the most commonly-tried passwords were the factory defaults for digital video recorders and embedded devices such as routers.

"Brute forcing factory default usernames and passwords of IoT devices continues to be an effective method for recruiting these devices into botnets that can be used in DDoS attacks," F-Secure warned.

The UK recently set out guidelines recommending that all consumer internet-connected device passwords must be unique and not resettable to any universal factory setting. [source]

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.

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 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.

We need your help. This is the only remaining news source dedicated to information about Paging and Wireless Messaging.

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Advertiser Index

IWA Technical Services, Inc.  (Ira Wiesenfeld)
Leavitt Communications  (Phil Leavitt)
Media 1
Prism-IPX Systems  (Jim Nelson & John Bishop)
Paging & Wireless Network Planners LLC  (Ron Mercer)
Wex International Limited

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

Leavitt Communications


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

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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


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:

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:

  • LIVE response possible to any program with Media 1 Live app from Android or Apple stores, summed up immediately for producer on web site
  • Propose LIVE broadcast on Internet. with live response to reach youth with low cost quality education, seeking persons interested.
  • Contact:


“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.

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.


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Ph: +64 (0)3 379 2298
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Amateur Radio Club President is among Two Killed in Knife Attack


Paul McIntyre, KC5JAX

The president of the River City Amateur Radio Communications Society in California, Paul McIntyre, KC5JAX, was one of two individuals killed on February 28 in a knife attack by a client at a recovery center. McIntyre, a father of two, had been interning at the Wellness and Recovery Center in Carmichael as part of his training to become a social worker. He was 57. Two other victims survived the attack.

McIntyre’s club reported that he was a longtime mentor and volunteer, and he was passionate to help others learn and enjoy amateur radio. He served for years as a club officer, on the Board of Directors, as net coordinator, and was a regular Field Day participant.

“He’s a wonderful, brave blind man who had no defense against what happened here,” a Fox40 KTXL news story quoted his wife Barbara. She told the TV station that McIntyre interned at the wellness and recovery center 2 days a week.

The family has set up a GoFundMe page to help with funeral costs. “When the screaming started, he ran towards the danger,” Anissa Kolda said on the GoFundMe page she set up on behalf of Barbara McIntyre. “His act saved a life but cost him his own.” — Thanks to ARRL Sacramento Valley Section Manager Carol Milazzo, KP4MD

Source: ARRL  

Prism-IPX Systems

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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:

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

What Is Replacing Shortwave?

A joint effort is necessary to bring the digitization of radio to a successful end

March 5, 2020
The author is chairman of Digital Radio Mondiale.

Analog shortwave will celebrate about 100 years of existence in 2028 when many hope 5G will have been properly defined, tested and applied, though broadcasting is low on its long list of perceived advantages.

A screenshot of Dream software showing the technical evaluation of a DRM signal (BBC transmission) received from
a transmitter located in Singapore. Photo courtesy of Dr. TK Rao.

It’s true that shortwave was typically a medium of the Cold War that peaked in 1989 and that afterward its listenership dwindled. Many international broadcasters gave up on it as the post-war transmitters got rustier and the energy bills kept mounting.

After all, when budget cuts are needed, no transmitter will go on strike or write to the press, as happened when the BBC World Service tried to unsuccessfully close its Hindi shortwave transmissions in 2011. In 2020 these broadcasts stopped, when committed BBC Indian listeners, writers and thinkers who opposed it in 2011 did not protest too much.

The slow death of shortwave has been blamed on the Internet and satellite. As technology and content are inextricably linked, shortwave created its type of content that is no longer favored by the savvy FM listener, Internet user and cellphone obsessed.


First, came the great partnership of international broadcasters with local FM stations. International programs could be suddenly heard in big cities in very good sound quality. The drawback was that the programs were often very short, often scheduled at unreasonable hours.

“Radio should address each and every one in cities and far away rural communities, whether to inform, entertain or alert to emergency situations.”

Branding was also an issue for the big international broadcasters now piggybacking on a local station with its own identity. There was also the danger that the local station could object to this partnership for political or content reasons and drop the international program at very short notice.

In some European cities, international broadcasters have also become local ones as they have gone on DAB multiplexes, more of a prestige move than an audience growing measure.

Photo courtesy of Encompass Digital Media.

Most of these international broadcasters are streaming and throwing their lot with another 30,000 or more stations that listeners have to choose from but only if they have electricity, a laptop, an Internet connection and sometimes the patience to cope with buffering.

So, shortwave and its long-range advantage were replaced mainly by the one-to-one sophisticated Internet and the cheaper, clearer but very local FM or the DAB+ option in band III, in this way undermining the very essence of their wide coverage and appeal.

At first, it might seem that these are cheaper and more modern options. But, in reality, energy-hungry FM and the multiplexed DAB+ are not that cheap either. Streaming uses an expensive digital electronics setup for something that broadcasting, as one-to-many, can do more cheaply, preserving the anonymity of the user, an advantage that is becoming increasingly relevant in many societies.


The greater danger of replacing wide-range coverage with local broadcasting is a different one, though: Radio that should address each and every one in cities and far away rural communities, whether to inform, entertain or alert to emergency situations, becomes patchy and leaves those, who need it most, out of range.

Some international and powerful public and state broadcasters still opt for wide-range coverage, however. One example is China, which might be still pursuing its local digital broadcasting version but to give full coverage on the roads and in the areas between large cities, it has opted for DRM shortwave.

China National Radio broadcasts 80 hours a day from five existing and upgraded sites with seven or eight transmitters sending shortwave DRM to most areas of North China, East China, South China and Southwest China. Russia is also airing DRM in shortwave over huge areas of Siberia.

India has three DRM shortwave transmitters and is looking at increasing this number for national and international reach. There is also interest in Indonesia and renewed questions are coming from Brazil that has been using analog shortwave to cover mainly its Amazonian region.

Vanuatu, a small country in the Pacific, has recently gone for DRM shortwave to save lives in disaster situations by using its integrated emergency warning capability. And a site in the United States has recently started broadcasting in DRM the popular Radio Marti programs toward central and Latin America.

It thus appears as if a few big up and coming countries are rediscovering the value of shortwave radio, unlike much of the Western international broadcasters who dropped it 10 or 20 years ago.


DRM was the big hope for shortwave when the excellent engineers with vision first invented it. In its digital variant, DRM, shortwave becomes a new modern platform using up-to-the minute coding, which produces a very clear sound. In effect, DRM shortwave is like FM over very large areas. More than one good audio channel is available and can be accompanied by data and other digital services.

In digital shortwave the energy bill is cut drastically as compared to the analog invoice, and the new transmitters are very efficient. Even the not so old transmitters can be upgraded. Some broadcasters saw these opportunities and went this route while patiently waiting for receivers to become available and affordable.

Now together with the extra shortwave DRM transmission services we are seeing the rise of DRM receiver solutions (with shortwave support as well) from countries like China, India, Germany, the United Kingdom and France.

Some of these solutions are inexpensive and energy-efficient designed to serve a whole community by using a digital shortwave station receiver disseminating the broadcast via Wi-Fi.

Therefore, today shortwave is positioned differently. While the interest of most Western countries has waned, other parts of the world have stuck with the platform and are adapting it for their own use.

In fact, we are at a point where shortwave may just be ready to turn the corner, especially if digital shortwave can be made available in cars. Surprisingly, electric cars might be better suited to receiving the digital signal than the current cars on the road.

Questions remain though: Is it too little, too late for shortwave? Or is this a new digital platform that we should simply call “digital radio” and that we can confidently and courageously embrace and use?

Source: Radio World  

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:

Mar 4, 2020,6:15 am EST

New Microsoft Security ‘Nightmare’: Users Warned Your Passwords Are Now At Risk

Zak Doffman, Contributor
I write about security and surveillance.


Microsoft security is under fire after new research, published here for the first time, exposes the serious risk of account hijack from compromised sub-domains. Put simply, users visiting a genuine Microsoft web domain might actually be on a sub-domain controlled by an attacker. Any information those users then share will be at risk—including usernames and passwords. Users are advised to take care the links they click, but if sub domains appear genuine, they will likely be tricked.

"We are aware of such reports,” a Microsoft spokesperson told me, “and are taking appropriate action as needed to help protect services and customers." While the lack of controls on Microsoft sub domains has been exposed before, this new report from Numan Ozdemir and Ozan Agdepe of includes a proof of concept video (see below) that shows how simple this is in practice.

There are no claims that these exploits have been exploited in the wild yet. But the vulnerability is now in the public domain. It is only a matter of time before bad actors seek to exploit the issue and put users at risk. “Enterprise sprawl and a lack of internal domain controls has created a nightmare,” cyber expert Ian Thornton-Trump tells me. “I suspect in the wake of this, Microsoft will need to implement significant changes in how domains are managed.”

Exposing the risks of hijacking Microsoft sub-domains is not new—it’s a problem that dates back years. But two things are new.

First, the sheer scale of the exposure. There are many hundreds of such domains open to hijack—I have seen a list of 670 that researchers say are now at risk. “You can’t protect it if you don’t know about it,” Thornton-Trump warns.

And, second, bad actors are starting to notice. As ZDNet reported last month, “one spam group has figured out they could hijack Microsoft's sub-domains and boost their spammy content by hosting it on a reputable domain.”

As risks go, “spammy content” is fairly benign. The real risk is the combination of seemingly legitimate Microsoft domains and phishing campaigns designed to steal credentials and user data. You get a message purporting to be from Microsoft. The link takes you to a legitimate domain and an encrypted website. You are asked for your username and password. You will almost certainly fall victim.

Checking for spoofed domain names is one of the key flags you look for to check that you’re not being spoofed. Not only does a legitimate domain fail to trigger that flag, it goes further, reassuring a user who is then less likely to look for other flags.

Security researcher Numan Ozdemir shared his findings with me, which I validated with independent researchers. He says all findings were shared with Microsoft. According to Ozdemir, he and fellow researcher Ozan Agdepe have an automated tool to identify exposed Microsoft sub-domains Once those are identified, the researchers claim they can hijack them, stealing cookies and credentials and bypassing open redirection protection: “ redirects to all and all Microsoft sub-domains seem to be whitelisted.”

“Subdomain takeover attacks generally doesn't require any technical expertise,” Ozdemir told me. “The attacker reviews DNS records and HTTP responses, then claims that sub-domain with a hosting provider. Users will not know if a sub-domain is hijacked by attackers or managed by a system admin. It means you may be surfing an attacker’s network while you think you are on an official website.”

Ozdemir warns that the vulnerability can be exploited in multiple ways, tailoring relevant sub-domains for the purpose: Tricking users into installing browser extensions and updates; spear-phishing to ask users to upload information onto a seemingly legitimate project work-share; pushing out malware to target devices. For obvious reasons, that list of 670 vulnerable domains is not being published here.

But what about systems to protect users from such attacks? Hijacked domains, security expert Sean Wright tells me, “will also likely impact on spam detection which rely on things such as domains.” We are talking about sub-domains sitting underneath and, and, and And some of the sub-domains themselves hint at identity assurance and security. This isn’t rocket science.

“Subdomain takeovers are bad news—how do users distinguish good from bad?” Wright warns. “They greatly increase the ability to perform phishing.” As this video from Ozdemir and Agdepe shows, an exploit can be crafted to steal credentials and cookies using a hijacked Microsoft sub-domain and an encrypted website:

For security researcher Mike Thompson, “the open redirect is the worst of the two [vulnerabilities]. This needs a response from Microsoft on how they’re securing, or not securing their sub-domains Open redirect is pretty much a schoolboy error.”

Microsoft’s advice is for users to look for crafted links in emails and messages as an initial red flag that it is an attack. “Specifically crafted links?” Thompson says, “like pretty much every phishing attack. It's so easy to dupe a user. Many attackers try clever things like changing unicode characters in domain names and so on. No need to do that here, when you're using a perfectly legit domain.”

“Sub-domain takeovers are not a good look for an organization,” Wright says, “especially larger organizations that should know better.” Looking at the video of this exploit, he adds “this POC helps put that into perspective. An ability to steal credentials and session related cookies should certainly be a cause for concern. I hope Microsoft pays more attention to this issue with these POCs.

Source: Forbes

Leavitt Communications

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

Friday, March 6, 2020 Volume 8 | Issue 45

Senate Passes Secure 5G and Beyond Act

The Senate passed and sent to the House a bill requiring the administration to identify 5G network security threats as well as potential hardware and software remedies, reported The Wall Street Journal.

“As our telecommunications technology advances, we must have plans in place to keep it secure from foreign interference,” said bill sponsor Sen. John Cornyn (R-TX) in a statement. Senate Select Committee on Intelligence Chairman Richard Burr (R-NC), and Vice Chairman Mark Warner (D-VA) are co-sponsors.

“5G promises to usher in a new wave of innovations, products, and services. At the same time, the greater complexity, density, and speed of 5G networks relative to traditional communications networks will make securing these networks harder and more complex. It’s why we need a coherent, national strategy to harness the advantages of 5G in a way that addresses those risks,” said Warner.

The Secure 5G and Beyond Act of 2019 calls for the administration to work with officials from the FCC, Commerce Department, Department of Homeland Security, Department of Defense, Justice Department and intelligence officials to develop policies to close security gaps. It also calls for the protection of U.S. companies that lead innovation in mobile-network technology.

The legislation sets a 180-day deadline for U.S. officials to give those policies to Congress. They must also submit a list of trusted suppliers from the U.S. and abroad.

Source: Inside Towers newsletter Courtesy of the editor of Inside Towers Jim Fryer.
Inside Towers is a daily newsletter by subscription.

BloostonLaw Newsletter

Selected portions [sometimes more — sometimes less — sometimes the whole updates] 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. 23, No. 10 March 4, 2020 

New E911 Location Accuracy Benchmark for VoLTE Providers Effective April 3

April 3rd is the deadline for all CMRS providers that offer commercial VoLTE service to provide: (1) dispatchable location; or (2) x/y location (i.e. Horizontal Location) within 50 meters for 70% of all wireless 911 calls. A related compliance certification tied to this benchmark must be filed with the FCC by June 2, 2020. To the extent a client has not yet deployed VoLTE but plans to do so in the future, they will be required to meet this “50 meters for 70% of wireless 911 calls” benchmark within six months of deploying commercial VoLTE service.

BloostonLaw Contact: Cary Mitchell.


FCC Finalizes Procedures for 3.5 GHz CBRS PAL Auction; Short-Form Applications Due April 9

At the FCC’s Open Meeting last Friday, the Commission adopted application and bidding procedures for its long-awaited auction of Citizens Broadband Radio Service (CBRS) Priority Access Licenses (PALs) in the 3550-3650 MHz band. Bidding in Auction 105 is scheduled to commence on June 25, 2020, and short-form applications will be due by Thursday, April 9th. We urge all clients who may be interested in bidding to let us know immediately so we can get to work on your company’s short-form application. To facilitate this process, we have prepared a short-form application questionnaire that is available upon request.

Copies of the Auction 105 Notice and Filing Requirements Public Notice (FCC 20-18) and Attachment A spreadsheet listing county information, upfront payments and minimum opening bids are available at A list of the primary pre-auction dates and deadlines is provided below:

Auction Application Tutorial Available (via Internet) .............. No later than March 9, 2020
Short-Form Application (FCC Form 175) Filing Window Opens Eastern Time (ET) .............. March 26, 2020, 12:00 p.m.
Short-Form Application (FCC Form 175) Filing Window Deadline .............. April 9, 2020, 6:00 p.m. ET
Upfront Payments (via wire transfer) .............. May 21, 2020, 6:00 p.m. ET
Bidding Tutorial Available (via Internet) .............. No later than June 11, 2020
Mock Auction .............. June 22, 2020
Bidding Begins in Auction 105 .............. June 25, 2020

Auction 105 will assign up to seven Priority Access Licenses (PALs) in each county-based license area, for a total of 22,631 PALs nationwide. This is the greatest number of spectrum licenses ever made available for bidding in a single auction and is intended to further the deployment of fifth-generation (5G) wireless, the Internet of Things, and other advanced spectrum-based services. PALs are 10-year renewable licenses and each PAL will consist of a 10-megahertz unpaired channel. Priority Access Licensees may hold up to four 10-megahertz channel licenses (out of a total of seven) within the band in any license area at any given time. So-called “mid-band” spectrum has been identified as a focal point for the development of 5G services around the world, and Auction 105 will be the first “mid-band” opportunity for service providers in the United States. The spectrum is adjacent to the satellite C band (at 3.7–4.2 GHz), which the FCC plans to make available in Auction 107 with bidding expected to start December 9, 2020 (see related story). However, the CBRS band may be better suited for entrepreneurs and smaller service providers because it is available for use immediately (using Part 96 certified equipment) and licensed via smaller geographic areas. Priority Access Licensees also do not have any obligation to pay relocation costs of satellite operators or costly/controversial accelerated relocation payments.

Designated entity bidding credits will be available to eligible small businesses and rural service providers. Small businesses with attributed average annual gross revenues that do not exceed $55 million for the preceding three years will be eligible to receive a 15% discount on winning bids, while very small businesses with attributed average gross revenues that do not exceed $20 million for the preceding three years will be eligible for a 25% discount. Alternatively, an applicant may request a 15% discount on its winning bids using a rural service provider bidding credit. To be eligible for a rural service provider bidding credit, an applicant must: (1) be a service provider that is in the business of providing commercial communications services and, together with its controlling interests, affiliates, and the affiliates of its controlling interests, has fewer than 250,000 combined wireless, wireline, broadband, and cable subscribers; and (2) serve predominantly rural areas. The Commission adopted a $25 million cap on the total amount of bidding credit discounts that may be awarded to an eligible small business, and a $10 million cap on the total amount of bidding credit discounts that may be awarded to an eligible rural service provider.

As proposed, the auction will use “ascending clock” bidding procedures for the county-based PALs. And welcome news is that the FCC has decided NOT to adopt the proposal for CMA-level bidding. The Blooston law firm submitted comments objecting to the proposal, arguing that CMA-level bidding would be unduly harmful for small service providers and entrepreneurs. During each bidding round, the bidding system will announce a per-block price in each county, and qualified bidders will submit, for each county for which they wish to bid, the number of blocks they seek at the clock prices associated with the current round. Bidding rounds will be open for predetermined periods of time. Bidders will be subject to activity and eligibility rules that govern the pace at which they participate in the auction.

The FCC established CBRS in 2015 to expand upon the 3650-3700 MHz band service, and make available 150 megahertz of spectrum in the 3550-3700 MHz band (3.5 GHz band) for both licensed and licensed-by-rule use. Spectrum is shared between three tiers of users: Incumbent Access, Priority Access and Generally Authorized Access, and spectrum usage rights are coordinated by a cloud-based Spectrum Access System (or “SAS”), which will assign the specific channel(s) for a particular licensee on a dynamic basis. Incumbent users receive protection from Priority Access Licensees and GAA users, while Priority Access Licensees receive protection from GAA users. The three-tiered structure is designed to accommodate a variety of commercial uses on a shared basis with incumbent federal and non-federal uses of the band. The system allows GAA users to have opportunistic access to PAL spectrum at times and in areas where the spectrum is not being used.

BloostonLaw Contacts: John Prendergast, Cary Mitchell

RDOF Bidding Procedures Comments Due March 27

On March 2, the FCC released a Public Notice seeking comment on competitive bidding procedures and certain program requirements for the Rural Digital Opportunity Fund (RDOF) auction (Auction 904). Comments are due March 27, and reply comments are due April 10.

According to the Public Notice, the pre-auction and bidding procedures and processes proposed for this auction are similar to those in the CAF Phase II auction (Auction 903). However, the FCC is also proposing some new pre-auction and bidding procedures and processes that are expected materially improve upon Auction 904. Among other things, comment is sought on:

Minimum Geographic Area for Bidding: The FCC asks whether it should depart from using census block groups as it did in Auction 903 for census tracts as the minimum biddable area.

Joint Bidding Arrangements: The FCC proposes to prohibit the submission of more than one application by commonly controlled entities for Auction 904 under any circumstances (in Auction 903, commonly controlled entities could submit multiple applications as long as there was no overlap). Further, the FCC proposes to ban applicants from entering into joint bidding arrangements for Auction 904. This ban would not extend to joint ventures and bidding consortia between or among entities that are not individual applicants (or control or are controlled by an applicant). This rule change could hurt small and rural carriers, who may be in one partnership serving a particular area, but in a different partnership to serve an adjacent location. Indeed, the rural cellular settlement process set up such scenarios, with encouragement by the FCC. Such carriers may have entirely legitimate reasons to participate in different auction applicants for non-overlapping areas.

Operational Information: The FCC proposes to collect high-level operational information from each applicant to enable staff to determine whether the applicant is expected to be reasonably capable of meeting the public interest obligations (e.g., speed, usage, latency, and build-out milestones) for each performance tier and latency combination that it selected in its application.

Appropriate Spectrum: Comment is sought on whether certain individual spectrum bands provide sufficient uplink or downlink bandwidth to support the wireless technologies that a provider may use to meet the Rural Digital Opportunity Fund obligations, including 600 MHz; Lower 700 MHz; Upper 700 MHz; 800 MHz SMR; Cellular; Broadband PCS; AWS‐1; AWS (H Block); AWS‐3; AWS‐4; BRS/EBS; WCS; CBRS (3.5 GHz); UMFUS (terrestrial); 70‐80‐90 GHz unpaired & 70‐80 GHz paired (point-to-point terrestrial); TV White Spaces; 900 MHz; 2.4 GHz. Carriers considering using these bands to obtain RDOF support should contact John Prendergast ( for more information.

Prohibited Technology/Performance Tier Combinations: To streamline the review of short-form applications, the FCC proposes adopting prohibitions and presumptions for applicants selecting certain performance tier and latency combinations that may be inconsistent with the technologies they intend to use to meet their Rural Digital Opportunity Fund auction public interest obligations. Specifically, the FCC proposes the following:

  • Geostationary or medium earth orbit satellites may not select low latency in combination with any of the performance tiers.
  • Geostationary satellite providers may not select the Gigabit performance tier and the Above Baseline performance tier.
  • Fixed wireless or DSL technologies may not select the Gigabit tier if the applicant has not reported offering Gigabit broadband service in its FCC Form 477 data.

Financial Statements: The FCC proposes to have applicants submitting audited financial statements identify whether it has a “clean” opinion letter on its audited financial statements. The FCC will consider an opinion letter to be clean if it has an unmodified opinion without an emphasis-of-matter paragraph regarding whether there is a going concern. An unmodified opinion is one where “the auditor concludes that the [audited] financial statements are presented fairly, in all material respects, in accordance with the applicable financial reporting framework.”

Bidding Procedures: The bidding procedures the FCC proposes for the Rural Digital Opportunity Fund auction are the same as those used in the CAF Phase II auction, with several modifications. Once the budget has cleared, the bid processing procedures will prioritize bids with lower T+L weights. In line with this modification, the FCC proposes to require all areas within a package bid to be bid at the same T+L weight. The FCC also proposes to set a maximum amount of implied support for which a bidder may bid in a round, and the FCC proposes to set that limit at 100% of the Rural Digital Opportunity Fund budget. The FCC further proposes that the bidding system will consider bids submitted at the clock percentage of the previous round, if bid processing procedures in the clearing round cannot assign the full budget to bids submitted in the clearing round.

Carriers interested in submitting comments on the FCC’s proposed Auction 904 procedures should contact the firm for more information.

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

FCC Issues Proposed Rules for 3.7 GHz “C-Band” Auction; Bidding to Begin December 8, 2020

The fire hose of spectrum auctions / licensing opportunities continues as the FCC yesterday released proposed competitive bidding procedures for its auction of flexible use service licenses in the 3.7-3.98 GHz band (the “3.7 GHz Service”). The FCC cleared a path for this much-anticipated mid-band auction when the Commission voted at last week’s open meeting to approve a controversial $9.7 billion package to expedite the relocation of C-Band satellite operators by 2023 rather than 2025. The FCC expects bidding in Auction 107 will begin on December 8, 2020.

Comments on the Commission’s proposed auction rules (FCC 20-23) are due by May 1, 2020 with reply comments due by May 15th.

Under the Commission’s proposal, Auction 107 will offer 5,684 new flexible-use overlay licenses for spectrum in the 3.7– 3.98 GHz band throughout the contiguous United States, subject to incumbent user clearing requirements. The FCC is proposing that the 280 megahertz of spectrum be licensed on an unpaired basis in three blocks divided into 20-megahertz sub-blocks by partial economic area (PEA).

The Public Notice seeks comment on proposed upfront payment and minimum opening bid amounts. Small business and rural service provider bidding credits will be available in Auction 107 to reduce the cost of 3.7 GHz Service licenses by 15% to 25% for eligible applicants. In addition, the Public Notice proposes bidding credit caps of $25 million for small businesses and $10 million for rural service providers, as well as a $10 million cap on the overall amount of bidding credits that a small business bidder may apply to winning licenses in smaller markets.

The auction as proposed would use an ascending clock auction design. First, the clock phase would allow bidding on generic blocks in each geographic area in successive clock bidding rounds. Second, the assignment phase would allow clock phase winning bidders to bid for frequency-specific license assignments. The Public Notice also outlines pre-auction rules to ensure anonymous bidding and limited information procedures.

Transition of Incumbent Operations

In a companion 3.7 GHz Report and Order also released yesterday (FCC 20-22), the FCC modified licenses of incumbent Fixed Satellite Service (FSS) operators and Fixed Service (FS) licensees to repack existing satellite operations into the upper 200 megahertz of the band, to reserve a 20 megahertz guard band, and to clear the 3.7–4.0 GHz band for new flexible-use terrestrial operations. But rather than following the Emerging Technologies framework of having auction winners voluntarily negotiate the payment of FCC operators’ reasonable relocation costs (estimated to cost as much as $5.2 billion), the FCC offers satellite operators the option of accelerating their transition by two years in exchange for their actual relocation costs plus an additional $9.7 billion accelerated payment. As a result, this nearly $10 billion “premium” (which was negotiated by the FCC and which has been criticized as a “windfall”) will be a mandatory payment for winning bidders, and this will presumably reduce the amounts that bidders are willing to pay when bidding for the licenses. The FCC said Intelsat, SES, Eutelsat, Telesat and Embratel Star One, have all demonstrated they have C-band customers in the U.S., making them eligible for the accelerated clearing payments.

Setting aside the band clearing controversy, which could spur litigation and/or Congressional action, new Part 27 Rules adopted by the FCC specify that flexible use 3.7 GHz Service licenses will be issued for 15-year renewable license terms, and licensees will be required to meet coverage and service requirements to at least 45% of the population of each PEA within eight years and to at least 80% of the population within twelve years (for mobile or point-to-multipoint service). Alternatively, licensees choosing to offer IoT-type services are required to provide geographic coverage to 35% of their license area within eight years, and 65% of their license area by year twelve.

The Commission’s actions are intended to implement FCC Chairman Ajit Pai’s 5G FAST Plan, which seeks to secure American leadership in 5G as well as to boost economic growth, job creation, and America’s global competitiveness. However, Congress is already pushing back on the mandatory relocation payment plan: S. 3246, known as the “SMART Act”, proposes to limit any incentive payment to satellite incumbents to just $1 billion.

BloostonLaw Contacts: Cary Mitchell, John Prendergast

Law and Regulation

FCC Proposes $200 Million in Fines to Big Four Over Location Data Sharing

February 28, the FCC issued a Notice of Proposed Liability against the nation’s four largest wireless carriers for apparently selling access to their customers’ location information without taking reasonable measures to protect against unauthorized access to that information. As a result, T-Mobile faces a proposed fine of more than $91 million; AT&T faces a proposed fine of more than $57 million; Verizon faces a proposed fine of more than $48 million; and Sprint faces a proposed fine of more than $12 million. The FCC also admonished these carriers for apparently disclosing their customers’ location information, without their authorization, to a third party.

As we reported in a previous edition of the BloostonLaw Telecom Update, the controversy over location data sharing exploded when Missouri Sheriff Cory Hutcheson used a “location-finding service” operated by Securus, a provider of communications services to correctional facilities, to access the location information of the wireless carriers’ customers without their consent between 2014 and 2017. In some cases, Hutcheson provided Securus with irrelevant documents like his health insurance policy, his auto insurance policy, and pages from Sheriff training manuals as evidence of his authorization to access wireless customer location data. All four carriers sold access to their customers’ location information to “aggregators,” who then resold access to such information to third-party location-based service providers (like Securus). Although their exact practices varied, each carrier relied heavily on contract-based assurances that the location-based services providers (acting on the carriers’ behalf) would obtain consent from the wireless carrier’s customer before accessing that customer’s location information.

The NAL contains allegations that advise the parties on how they have apparently violated the law and set forth a proposed monetary penalty. Neither the allegations nor the proposed sanctions in the NALs are final Commission actions. The parties will be given an opportunity to respond and the Commission will consider the parties’ evidence and legal arguments before taking further action to resolve these matters.

BloostonLaw Contacts: Cary Mitchell and Sal Taillefer.

Senate Introduces 5G Workforce Legislation

On February 27, Senator John Thune (R-SD), along with Senators Wicker, Tester, Moran, and Peters, introduced the Telecommunications Skilled Workforce Act (S.3355). The bill would create a working group comprised of members from the FCC, Labor Department, Commerce Department, and Education Department, in addition to the private sector, to leverage federal resources to:

  • determine whether any Federal laws (including regulations), policies, or practices, or any budgetary constraints, inhibit institutions of higher education or for-profit businesses from establishing, adopting, or expanding programs intended to address the workforce needs of the telecommunications industry, including the workforce needed to build and maintain the 5G wireless infrastructure necessary to support 5G wireless technology;
  • identify potential policies and programs that could encourage and improve coordination among Federal agencies, between Federal agencies and States, and among States, on telecommunications workforce needs; • identify ways in which existing Federal programs, including programs that help facilitate the employment of veterans and military personnel transitioning into civilian life, could be leveraged to help address the workforce needs of the telecommunications industry;
  • identify ways to encourage individuals and for-profit businesses to participate in qualified industry-led workforce development programs, including the Telecommunications Industry Registered Apprenticeship Program and other industry-recognized apprenticeship programs;
  • identify ways to improve recruitment in qualified industry-led workforce development programs, including the Telecommunications Industry Registered Apprenticeship Program and other industry-recognized apprenticeship programs; and
  • identify Federal incentives that could be provided to institutions of higher education, for-profit businesses, State workforce development boards, or other relevant stakeholders to establish or adopt programs, or expand current programs, to address the workforce needs of the telecommunications industry, including such needs in rural areas.

Labor and GAO also would be required to issue guidance and reports.

“To complete America’s 5G build, we need nearly to double the number of skilled tower techs and telecom crews working in this country. U.S. leadership, jobs, next-gen services, and bridging the digital divide depend on meeting this 5G workforce challenge.” said Commissioner Brendan Carr. “The legislation that Senator Thune and his colleagues introduced would meet this challenge head on and advance a truly government-wide effort to train and connect workers to these good-paying jobs.”

BloostonLaw Contacts: Ben Dickens and Sal Taillefer.

Senate Passes Supply Chain Reimbursement Bill

On February 27, the Senate passed the Secure and Trusted Communications Networks Act (HR 4998), which prohibits USF subsidies from being used to purchase communications equipment or services posing national security risks and, importantly, provides for the establishment of a reimbursement program for the replacement of communications equipment or services posing such risks. The bill will next move on to the President for signature into law.

Originally introduced in the House of Representatives in November 2019 by Rep. Frank Pallone, Jr. (D-NJ), the bill would establish the Secure and Trusted Communications Reimbursement Program to assist communications providers with the costs of removing and replacing prohibited equipment and services from their networks. The fund limits reimbursement to carriers with fewer than 2 million customers.

Applicants for reimbursement will be required to certify that they have (i) developed a plan for the permanent removal, replacement, and disposal of any covered communications equipment or services that are in the communications network of the applicant as of the application date and (ii) developed a specific timeline for the permanent removal, replacement, and disposal of the covered communications equipment or services. Applicants must also certify that, beginning on the date of the approval of the application, they will not purchase, rent, lease, or otherwise obtain covered communications equipment or services, using reimbursement funds or any other funds (including funds derived from private sources); and will develop a risk management practice by consulting and considering the standards, guidelines, and best practices set forth in the cybersecurity framework developed by the National Institute of Standards and Technology.

The bill also requires applicants to submit to the FCC on a regular basis reports regarding how reimbursement funds have been spent, including detailed accounting of the covered communications equipment or services permanently removed and disposed of, and the replacement equipment or services purchased, rented, leased, or otherwise obtained, using reimbursement funds. The FCC is also obligated to conduct regular audits and reviews of reimbursements, as well as random field investigations, to ensure that recipients of reimbursements are performing the work such recipients are required to perform under the commitments made in their applications.

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


FCC Auction Technical Guides Available

With the announcements this week on Auctions 904 and 105, the FCC also made available guides that provide technical and mathematical details regarding the proposed bidding procedures for each. The guides provide examples and serve as supplements to the bidding and bid processing procedures for the auctions as proposed by the FCC in their respective Public Notices described above.

The guide for Auction 904, which is entitled Rural Digital Opportunity Fund Auction Technical Guide, is available in the Education section of the Commission’s Auction 904 website (, where it will remain available and accessible for reference. The Phase I auction, which is scheduled for October 22, 2020, will target over six million homes and businesses in census blocks that are entirely unserved by voice and broadband with download speeds of at least 25 Mbps. Phase II will cover locations in census blocks that are partially served, as well as locations not funded in Phase I.

The guide for Auction 105, which is entitled Auction 105 Technical Guide, is available on the Commission’s Auction 105 website ( in the Education section, where it will remain available and accessible for reference. Auction 105 will offer Priority Access Licenses in the 3550-3650 MHz band.

FCC Implements Electronic Payments for Forfeiture Penalties

On February 28, the FCC released an Order implementing mandatory electronic payments for forfeiture penalties. As a result, payments for forfeiture penalties may no longer be paid via check or money order 90 days from the date the Order is published in the Federal Register. After that date, forfeiture penalty payments must be made in accordance with the procedures set forth on the Commission’s website, For now, such payments will be made through the Fee Filer Online System (Fee Filer), accessible at

These changes were made without notice and comment because they are rules of agency organization, procedure, or practice exempt from the general notice-and-comment requirements of the Administrative Procedure Act.


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 FCC. 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: Ben Dickens, Gerry Duffy, and Sal Taillefer.

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 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 499-A that is due April 1.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and Sal Taillefer.

JUNE 1: 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. However, because the 31st is a Sunday this year, the filing will be due on June 1. 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 June 1. The FCC encourages carriers to complete the discrimination report requirement by filling out Section V of Form 395, rather than submitting a separate report.

BloostonLaw Contact: Richard Rubino.

Law Offices Of
Blooston, Mordkofsky, Dickens,
Duffy & Prendergast, LLP

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.

Calendar At-a-Glance

Mar. 9 – Comments are due on All-Digital AM Broadcasting NPRM.
Mar. 9 – Comments are due on 5.9 GHz Band Proceeding NPRM.
Mar. 9 – Reply comments are due on Reassigned Numbers Database Technical Requirements.
Mar. 13 – Reply comments are due on Truth-in-Billing for VoIP proceeding.
Mar. 20 – Reply comments are due on Vertical Location Accuracy.
Mar. 23 – Reply comments are due on Removing Radiolocation/Amateur Allocations in 3.3-3.5 GHz Band.
Mar. 27 – Comments are due on RDOF bidding procedure Public Notice.
Mar. 30 – Comments on Restoring Internet Freedom/Lifeline Reform record are due.
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 – E911 Location Accuracy Benchmark Deadline for VoLTE Providers.
Apr. 6 – Reply comments are due on All-Digital AM Broadcasting NPRM.
Apr. 6 – Reply comments are due on 5.9 GHz Band Proceeding NPRM.
Apr. 9 – Short Form for Auction 105 due.
Apr. 10 – Comments are due on RDOF bidding procedure Public Notice.
Apr. 22 – Huawei/ZTE Data Collection Responses are due.
Apr. 29 – Reply comments on Restoring Internet Freedom/Lifeline Reform record are due.

May 1 – FCC Form 499-Q (Quarterly Telecommunications Reporting Worksheet) is due.
May 21 – Upfront payments for Auction 105 due.

Jun. 1 – FCC Form 395 (Annual Employment Report) is due. Jun. 25 – Bidding begins in Auction 105.

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From: Ruschak, Andrew
Subject: Paging Coverage Modeling Engineering inquiry
Date: February 28, 2020 at 5:06:21 PM CST
To: Brad Dye


Please let me first introduce myself as a LMR / Wireless consultant in the Seattle area, and have an upcoming project where a client has asked us to perform coverage testing and predictive coverage modeling for UHF (POCSAG) and 931 MHz (FLEX) paging services. They are a healthcare provider and use both private an carrier paging. I was hoping that I might ask a moment of your time as the preeminent authority in this relatively esoteric field of wireless?

Our predictive modeling software that we use daily is highly configurable in both modulations and fading models, but is based primarily on modulation formats associated with traditional LMR (analog a digital formats) and 3GPP cellular formats. Ultimately, all of the Channel Performance Criterion (CPC) values for loss are based upon TIA TSB-88 . . . for which there is not (to my knowledge) CPC data for either the POCASG or FLEX modulation formats. No channel data, filter data, no emission mask data…nothing ! 

While there are similar 2- and 4-level FSK formats associated with digital voice modes, neither the modulation mode, data rates and channel bandwidths seem to be a “perfect match” for those found in POCSAG and FLEX. This dilemma along with the fact (at least to my knowledge) that current service monitors cannot do off-air decoding and BER% analysis of POCSAG or FLEX throws a big wrench in the gears of doing a drive test signal survey.

For example, I could use the LMR MPT1327 standard of control channel modulation (1200 bps @ 12.5 or 25 kHz channel BW) and maybe get a close approximation for 1200 bps POCSAG, but without knowing the error correction abilities of each under equivalent faded conditions, the comparison wouldn’t be very scientific. Likewise, with FLEX I could set up a LMR modulation running at 9600 bps with 2-level or GMSK but I know of no digital voice protocol in LMR using 1600 or 3200 bps… this is very frustrating to say the least.

Undoubtedly, back in the day (I’m 55 years old BTW and remember earlier times . . . first licensed as KA3AWX in 1978😊)  the likes of Motorola and Glenayre (and the paging carriers of old) had to have something to perform predictive modeling and drive testing for paging coverage, but I am at a loss at how to do this with current software tools and wireless analyzers in production.   Any guidance or suggestions. . . ?

Lastly, what an outstanding job on your website! You have immortalized in one place a great depository of information for all to use and share. Thank you !


Andy Ruschak KK7TR, FCC GROL
Wireless Technology Consultant
4100-194th St. SW
Lynnwood, WA 98036-4613
Phone: (206) 224-3638
Cell: (206) 280-2662

From: Brad Dye <>
Subject: Re: Paging Coverage Modeling Engineering inquiry
Date: February 28, 2020 at 6:04:29 PM CST
To: "Ruschak, Andrew" <>
Bcc: Allan Angus <>

Hey Andy,

I was very happy to receive your message. When I worked at Weblink Wireless in Dallas we did a lot of coverage testing but that department reported into a different section – an engineering group. Fortunately I am still in contact with the former Weblink system architect – Allan Angus. We do occasional consulting projects together. Please let me check with him to see if he can help you or possibly refer you to one of his former staff engineers.

I really appreciate your comments about my web site. I have put a lot of work into it for almost twenty years. I am glad you found helpful information there.

My role in the radio communications industry has been to be “the go between” – to explain technical things to customers. Salesmen are good at telling jokes and taking customers to lunch but often don’t understand the technical issues. Engineers frequently explain things in a language that customers don’t fully understand. So, most of my work has been in sales and marketing although I did start out as a FCC-licensed First Class Commercial engineer. (At least an engineer “wannabe.”)

Since Allan has a good sense of humor, I’m sure he won’t mind if I say that if you ask an engineer what time it is, he (or she) will tell you how to build a clock.

Good to hear from another ham radio operator as well. I got my license 63 years ago.

Best Regards,

Brad Dye, K9IQY
Editor, The Wireless Messaging News
P.O. Box 266 Fairfield, IL  62837 USA
Telephone: 618-599-7869
Skype: braddye

From: <>
Subject: RE: Paging Coverage Modeling Engineering inquiry
Date: March 2, 2020 at 1:22:06 PM CST
To: "'Brad Dye'" <>, <>

Hello Mr Ruschak,

Brad has forwarded you inquiry to me, and so I’m copying him on my response.

You are correct that the major paging/NPCS companies had well-developed models for coverage prediction and network design. As you can well imagine, these models would begin with fairly well-established propagation theory at UHF with corrections for land use and land cover, with seasonal corrections.

Unfortunately (or not), most LMR models incorporate no factors for the sort of nonlinear modulations and simulcast transmission that are typical of paging and the impacts these have on BER at the paging mobile. For much more detail on these channel degradations, I’d recommend a couple of documents by myself and Selwyn Hill that are still up on Brad’s web site:

To the extent that the impacts of simulcast beat fading and simulcast delay spread are significant in typical inexpensive paging mobiles, we took significant steps to mitigate these issues in network design back at WebLink. These included much lower ERP values that would have be the norm for POCSAG systems, TCXO transmitters with GPS clock discipline and IQ modulator, nonlinear optimization (simulated annealing) for carrier frequency and time offsets, and so on. IMHO, while Selwyn’s 1997 paper is pushing 25 years old now, I think it represents a master work of analysis in the channel degradations in FLEX at 6400 bit/s. While Motorola and Glenayre did have some modeling systems (and there were other variants available), at WebLink, we wrote our own system basically from scratch. This was in no small measure because RSSI was a very poor predictor of BER were not signal to noise or signal to co-channel, but rather, signal to degradation.

Binary POCSAG is a considerably simpler beast than FLEX at 6400 bit/s. POCSAG tends to operate well back from the sorts of channel degradations that begin to crop up in FLEX at 3200 or 6400 bit/s. FLEX binary at 1600 bit/s is not too different than POCSAG at 1200. At WebLink, we discovered that our network had to undergo significant modifications in order to achieve the higher capacities that high-speed FLEX promised. I believe that Selwyn addresses some of the issues pertinent to a design that deals with the combination of outdoor coverage at ground level with Rayleigh fading versus indoor coverage at elevation with strong line of sight to sets of simulcasting transmitters. Such combinations prove to be especially pernicious.

In the situation that you’re describing; a private first responder system, perhaps the simulcast channel degradations that would come along with FLEX at 6400 bit/s would not be part of the design package. If the coverage area were small and the number of simulcasting transmitters were limited, then a good deal of Selwyn’s considerations could be rather moot.

I’m not sure if these folks would fit into any of your project plans right now, but a few folks that I think highly of started a business in the Atlanta area back in 2005 to address the growth in private first responder messaging. They are called Critical Response and they have a site at While I’d bet that they have their own modeling s/w, they also sell and install their own systems for this sort of application. You may be too far down the road for that sort of engineering.

I’m not sure what further help I might be. It is simply the truth that a good deal of technology in this wireless arena has left the field, as one of my old buddies used to say, on two feet.

-Allan Angus

From: Peter Cook
Subject: Salcom is launching a series of new products this year
Date: March 1, 2020
To: Brad Dye

Salcom is launching a series of new products this year and re-affirming its commitment to communications and paging. The company is also proud to be a Licensee and Ambassador for the New Zealand Government operated “Fernmark Program.” which helps to promote and protect New Zealand products and services on a global scale.

The new products include:

20-62 Transmitter: A configurable 5W POCSAG paging transmitter available in both VHF and UHF bands offering 2 serial ports, Ethernet and four inputs. Inputs may be used to initiate relay commands for remote control applications. Over twenty protocols are available as standard. The product can be configured remotely from a PC or allow the sending of a pager message from a remote location.

20-90 Transceiver: A low-power, configurable transmitter / repeater / receiver with Ethernet that offers tremendous versatility to any system. Remote configuration and/or messaging via Ethernet.

PageMe: A single PC installed paging General User Interface (GUI) that is designed for smaller businesses at a very competitive, entry-level price. Users may send pre-configured messages or type their own free-form message and send to any of the pager recipients on a list, or to user groups (configurable). Recommended to be used in conjunction with a 20-62 Ethernet transmitter.

Salcom invites you to visit its new website at



Peter Cook
Sales & Marketing Manager



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