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   July 21, 2008

   VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED

   Vladimir Reznik, Owner

   RangeVideo

   Re: File No. EB-08-SE-182

   Dear Mr. Reznik:

   This is an official CITATION, issued pursuant to Section 503(b)(5) of the
   Communications Act of 1934, as amended ("Act"), 47 U.S.C. S: 503(b)(5),
   for marketing unauthorized radio frequency devices in the United States in
   violation of Section 302(b) of the Act, 47 U.S.C. S: 302a(b), and Sections
   2.803 and 15.205(a) of the Commission's Rules ("Rules"), 47 C.F.R. S:
   2.803 and 15.205(a), and importing radio frequency devices without filing
   FCC Form 740 (or the electronic equivalent) with the United States Customs
   and Border Patrol, in violation of Section 1.1203 of the Rules, 47 C.F.R.
   S: 1.1203. As explained below, future violations of the Commission's Rules
   in this regard may subject your company to monetary forfeitures.

   By letter of inquiry ("LOI") dated June 2, 2008, the Spectrum Enforcement
   Division of the Commission's Enforcement Bureau initiated an investigation
   into whether RangeVideo is marketing in the United States unauthorized
   radio frequency devices, specifically, wireless video transmitters. At the
   time of that letter, we observed on your website, www.rangevideo.com, your
   marketing of the following radio frequency devices:

    1. 900MHz 100mW audio/video transmitter

    2. 900MHz 500mW audio/video transmitter

    3. 1.3GHz 300mW audio/video transmitter

    4. 2.4GHz 200mW audio/video transmitter

    5. 2.4GHz 500mW audio/video transmitter

    6. 2.4GHz 1000mW audio/video transmitter

    7. 2.4GHz 1000mW cased audio/video transmitter.

   In your response to the LOI dated June 30, 2008, you state that you do not
   manufacture these transmitter devices. You admit that you first imported
   the devices on August 2, 2006, that you continue to import the devices,
   that you have imported 2,613 units of the devices, and that you first sold
   these devices on August 22, 2006. You also admit that, although you import
   the devices, you have not filed FCC Form 740 with the United States
   Customs and Border Patrol. In addition, while you claim to "sell mostly to
   other countries," you acknowledge that you have sold 1,673 units to United
   States purchasers.

   Section 302(b) of the Act provides that "[n]o person shall manufacture,
   import, sell, offer for sale, or ship devices or home electronic equipment
   and systems, or use devices, which fail to comply with regulations
   promulgated pursuant to this section." Section 2.803(a)(1) of the
   Commission's implementing regulations provides that:

   no person shall sell or lease, or offer for sale or lease (including
   advertising for sale or lease), or import, ship, or distribute for the
   purpose of selling or leasing or offering for sale or lease, any radio
   frequency device unless ... [i]n the case of a device subject to
   certification, such device has been authorized by the Commission in
   accordance with the rules in this chapter and is properly identified and
   labeled as required by S: 2.925 and other relevant sections in this
   chapter.

   Additionally, Section 2.803(a)(1) of the Rules provides that:

   (a) Except as provided elsewhere in this section, no person shall sell or
   lease, or offer for sale or lease (including advertising for sale or
   lease), or import, ship, or distribute for the purpose of selling or
   leasing or offering for sale or lease, any radio frequency device unless:
   (1) [i]n the case of a device subject to certification, such device has
   been authorized by the Commission in accordance with the rules in this
   chapter and is properly identified and labeled as required by S: 2.925 and
   other relevant sections in this chapter[.]

   Pursuant to Section 15.201(b) of the Rules, 47 C.F.R. S: 15.201(b),
   intentional radiators must be authorized in accordance with the
   Commission's certification procedures prior to the initiation of marketing
   in the United States. It does not, however, appear that the seven
   transmitters listed above and marketed on your website have received a
   grant of authorization and, in any event, these transmitters would not be
   capable of receiving such a grant. In this regard, the marketing materials
   you provided with your LOI response indicate that these A/V transmitters
   are capable of operation on restricted frequencies listed in Section
   15.205(a) of the Commission's Rules. Specifically, the 900 MHz devices are
   capable of operation on 980 MHz, 1010 MHz and 1040 MHz; the 1.3 GHz device
   are capable of operating on 1240 MHz, 1320 MHz and 1360 MHz; and the 2.4
   GHz devices are capable of operating on 2490 MHz. Thus, these transmitter
   devices cannot comply with the FCC's technical standards and therefore
   cannot be certified or marketed.

   We note that in your response to the LOI, you state that before you ship a
   transmitter device, you switch it to operate only in the Amateur Radio
   Service ("ARS") bands. While radio transmitting equipment that transmits
   solely on ARS frequencies is not subject to the equipment authorization
   requirement prior to manufacture or marketing, it appears that the seven
   transmitter devices marketed on your website are equipped with external
   toggle switches on the unit, which if engaged would allow operation of the
   device on the restricted frequencies noted above. On May 13, 1996, the
   Commission's Office of Engineering and Technology released a Public Notice
   "to clarify the Commission's Rules regarding equipment that is intended to
   operate in various radio services in the high frequency radio spectrum,
   including `10-Meter' Amateur Radio Service equipment." The Notice stated
   that transmitters intended for operation on non-amateur frequencies must
   be approved prior to manufacture, importation or marketing. The Notice
   specifically included ARS transceivers designed "such that they can easily
   be modified by the users to extend the operating frequency range into the
   frequency bands" of other non-amateur radio services among those devices
   subject to equipment authorization procedures. The Notice also stated that
   the Commission considers these transceivers as intended to be operated on
   frequencies where the use of type accepted equipment is required "because
   of the simplicity of modifying them to extend their operating frequency
   range." Therefore, the transmitter devices listed on your website require
   a grant of equipment certification prior to the initiation of marketing in
   the United States, but, as noted above, cannot be certified because they
   operate on restricted frequencies.

   Accordingly, it appears that RangeVideo has violated Section 302(b) of the
   Act and Sections 2.803 and 2.805of the Rules by marketing in the Unites
   States the seven A/V transmitters listed above.

   Lastly, your response to the LOI indicates that you import the
   above-listed devices without filing FCC Form 740 with U.S. Customs
   declaring an import condition. Section 2.1203(a) of the Rules provides
   that "[n]o radio frequency device may be imported into the Customs
   territory of the United States unless the importer or ultimate consignee,
   or their designated customs broker, declares that the device meets one of
   the conditions for entry set out in this section." Accordingly, it appears
   that RangeVideo has violated Section 2.1203 of the Rules by importing
   radio frequency devices without filing FCC Form 740 (or the electronic
   equivalent) declaring an import condition.

   If, after receipt of this citation, you violate the Communications Act or
   the Commission's Rules in any manner described herein, the Commission may
   impose monetary forfeitures not to exceed $11,000 for each such violation
   or each day of a continuing violation.

   You may respond to this citation within 30 days from the date of this
   letter either through (1) a personal interview at the Commission's Field
   Office nearest to your place of business, or (2) a written statement. Your
   response should specify the actions that you are taking to ensure that you
   do not violate the Commission's Rules governing the marketing of radio
   frequency equipment in the future.

   The nearest Commission field office appears to be the Atlanta District
   Office, in Atlanta, Georgia. Please call Nissa Laughner at 202-418-1358 if
   you wish to schedule a personal interview. You should schedule any
   interview to take place within 30 days of the date of this letter. You
   should send any written statement within 30 days of the date of this
   letter to:

   Kathryn Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   Federal Communications Commission

   445-12th Street, S.W., Rm. 3-C366

   Washington, D.C. 20554

   Under the Privacy Act of 1974, 5 U.S.C. S: 552(a)(e)(3), we are informing
   you that the Commission's staff will use all relevant material information
   before it, including information that you disclose in your interview or
   written statement, to determine what, if any, enforcement action is
   required to ensure your compliance with the Communications Act and the
   Commission's Rules.

   The knowing and willful making of any false statement, or the concealment
   of any material fact, in reply to this citation is punishable by fine or
   imprisonment under 18 U.S.C. S: 1001.

   Thank you in advance for your anticipated cooperation.

   Sincerely,

   Kathryn Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   Federal Communications Commission

   Your response included as an attachment a grant of equipment certification
   for only one device, a 2.4 GHz 10 mW A/V transmitter, issued under FCC ID
   No. QV8TD2400. This transmitter, however, is not a subject of this
   Citation.

   Section 15.3(o) of the Rules defines an "intentional radiator" as a
   "device that intentionally generates and emits radio frequency energy by
   radiation or induction." 47 C.F.R. S: 15.3(o).

   Section 2.803(e)(4) of the Rules defines "marketing" as the "sale or
   lease, or offering to sale or lease, including advertising for sale or
   lease, or importation, shipment or distribution for the purpose of selling
   or leasing or offering for sale or lease." 47 C.F.R. S: 2.803(e)(4).

   Section 15.205(a) allows intentional radiators to transmit only spurious
   emissions in the restricted frequency bands. 47 C.F.R. S: 2.1 defines
   spurious emissions as "[e]missions on a frequency or frequencies which are
   outside the necessary bandwidth and the level of which may be reduced
   without affecting the corresponding transmission of information. Spurious
   emissions include harmonic emissions, parasitic emissions, intermodulation
   products and frequency conversion products, but exclude out-of-band
   emissions."

   Your response indicates that the 1.3 GHz device is shipped with a default
   setup of 1240 MHz. This frequency is, however, a restricted frequency
   under Section 15.205(a) of the Rules.

   Extended Coverage High Frequency Transceivers, Public Notice 62882, 1996
   WL 242469, available at
   <>
   (OET, rel. May 13, 1996) ("Notice").

   Id.

   See 47 C.F.R. S: 2.1205. Under Section 2.1205, the required declaration
   may be filed electronically. In addition, the specific import conditions
   are set forth in Section 2.1204 of the Rules, 47 C.F.R. S: 2.1204.

   See 47 C.F.R. S: 1.80(b)(3).

   Federal Communications Commission DA 08-1685

   1

   2

   Federal Communications Commission DA 08-1685

                       FEDERAL COMMUNICATIONS COMMISSION

                            WASHINGTON, D.C.  20554