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Spectrum Bridge, Inc., and Meld Technologies, Inc. Waiver Request

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Released: March 25, 2013

PUBLIC NOTICE

Federal Communications Commission
445 12th St., S.W.

News Media Information 202 / 418-0500

Internet: http://www.fcc.gov

Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-546

Released: March 25, 2013

OFFICE OF ENGINEERING AND TECHNOLOGY DECLARES THE SPECTRUM BRIDGE,

INC. AND MELD TECHNOLOGIES, INC. REQUEST FOR WAIVER OF SECTIONS

15.711(b)(2) AND 15.711(b)(3)(ii) OF THE RULES TO BE A “PERMIT-BUT-DISCLOSE”

PROCEEDING FOR EX PARTE

PURPOSES AND REQUESTS COMMENT

ET Docket No. 13-81

Comment Date: April 25, 2013
Reply Comment Date: May 10, 2013

On February 25, 2013, Spectrum Bridge, Inc. (“Spectrum Bridge”) filed a request on behalf of Meld
Technologies, Inc. (“MeldTech”) asking that the Commission waive the restriction on adjacent channel
operation for a fixed TV bands device (TVBD) manufactured by MeldTech and certified under FCC ID:
OKVMT300. The device that would operate pursuant to the requested waiver is a rack mounted unit with
a power level of 40 milliwatts that would stream video content to digital television receivers in
commercial locations such as “big box” stores. It would not be sold to consumers or through consumer
retail outlets. Spectrum Bridge specifically requests a waiver of Sections 15.711(b)(2) and
15.711(b)(3)(ii) of the rules to allow the MeldTech fixed device to be treated as a professionally installed
personal/portable device and to operate on channels that are indicated in a TV bands database as being
available for use by personal/portable TVBDs. It requests the waiver for a period of one year to permit
the marketing, manufacture and installation of the subject equipment.
TVBDs must have the capability to access a database that determines the available channels on which
they can operate. Spectrum Bridge is authorized by the Commission to operate one such database. Under
the Commission’s rules for TVBD operation, the channels that are available for fixed and
personal/portable devices generally differ at a given location because, for example, only fixed devices
may operate below channel 21 and only personal/portable devices with a power level of 40 milliwatts or
less may operate within the service contour of adjacent channel TV stations.
Spectrum Bridge states that the geographic location of the MeldTech device will be programmed into the
device as part of the professional installation procedure, and that MeldTech authorized distributors will be
responsible for ensuring that all devices are correctly installed. It further states that the device will
contact the Spectrum Bridge database once every 30 minutes to confirm channel availability, and that the
database will allow operation only on channels 21 and above, including adjacent channels, consistent with
the rules for 40 milliwatt personal/portable devices. Spectrum Bridge states that the waiver would permit
access to more channels indoors which can be utilized to provide parallel streams of content to different
signs, particularly in areas where channels available for fixed devices are extremely limited. Spectrum
Bridge argues that a waiver is necessary because the MeldTech devices will be used inside buildings
where GPS is not a practical or reliable way to determine location, so including GPS in the device would

not provide for reliable operation. It also argues that adding GPS capabilities would require additional
engineering and integration that would delay the device from getting to market. Spectrum Bridge
requests a waiver for a period of one year to provide time for MeldTech to develop more reliable
geolocation solutions for the environments where the devices will operate. Spectrum Bridge states that
the requested waiver would serve the public interest by increasing the potential opportunities for
innovative use of the TV white spaces while satisfying the requirement to provide protection for
incumbent operations.
The FCC’s Office of Engineering and Technology (OET) is reviewing the waiver request. OET has
concluded that in order to develop a complete record on the complex issues presented by this request, this
proceeding will be treated, for ex parte purposes, as "permit-but-disclose" in accordance with Section
1.1200(a) of the Commission's rules, subject to the requirements under Section 1.1206(b).
Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419, interested
parties may file comments and reply comments on or before the dates indicated on the first page of this
document. Comments may be filed: (1) using the Commission’s Electronic Comment Filing System
(ECFS), (2) through the Federal Government’s eRulemaking Portal, or (3) by submitting paper copies.
See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).

Electronic Filers: Comments may be filed electronically using the Internet by accessing the
ECFS: http://fjallfoss.fcc.gov/ecfs2/ or the Federal eRulemaking Portal:
http://www.regulations.gov.

Paper Filers: Parties that choose to file by paper must file an original and one copy of each filing.
If more than one docket or rulemaking number appears in the caption of this proceeding, filers
must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s
Secretary, Office of the Secretary, Federal Communications Commission.

All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries
must be held together with rubber bands or fasteners. Any envelopes must be disposed of
before entering the building.

Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.

U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities (braille,
large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer &
Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
All filings must be addressed to the Commission’s Secretary, Marlene H. Dortch, Office of the Secretary,
Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554. Parties should also
send a copy of their filings to Hugh L. Van Tuyl, Office of Engineering and Technology, Federal
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Communications Commission, Room 7-A162, 445 12th Street, SW, Washington, DC 20554, or by e-mail
to Hugh.VanTuyl@fcc.gov. Parties must also serve one copy with the Commission’s copy contractor,
Best Copy and Printing, Inc. (BCPI), Portals II, 445 12th Street, SW, Room CY-B402, Washington, DC
20554, (202) 488-5300, or via e-mail to fcc@bcpiweb.com.
Documents are available for public inspection and copying during business hours at the FCC Reference
Information Center, Portals II, 445 12th Street, SW, Room CY-A257, Washington, DC 20554. The
documents may also be purchased from BCPI, telephone (202) 488-5300, facsimile (202) 488-5563, TTY
(202) 488-5562, e-mail fcc@bcpiweb.com.
Office of Engineering and Technology contact: Hugh L. Van Tuyl at (202) 418-7506.
By the Chief, Office of Engineering and Technology
-FCC-
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