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Jesse Caulfield Key Bridge

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Released: November 19, 2013
Federal Communications Commission
Washington, D.C. 20554
November 19, 2013

DA 13-2210

Mr. Jesse Caulfield
Key Bridge Global, LLC.
1600 Tysons Blvd., Suite 1100
McLean, VA 22102
Dear Mr. Caulfield,
Approval is hereby granted for Key Bridge Global, LLC (Key Bridge). to operate its “TV bands database
system” to provide service to the public. This database system will provide support to unlicensed radio
devices that transmit on unused channels in the spectrum bands used by broadcast television (TV white
spaces, or TVWS).
The Commission’s Part 15 rules (47 C.F.R. § 15.701 et seq.) require that unlicensed radio transmitting
devices that operate in the broadcast television bands contact an authorized database system to obtain a
list of channels that are available for their operation (i.e., channels not occupied by authorized radio
services) at their individual locations and operate only on those channels. These devices are required to
provide their geographic location, by means of a secure Internet connection, to a TV bands database
system authorized by the Commission. The database will then return a list of the channels available for
operation by the device for its reported location.
Key Bridge, along with a number of other entities, was conditionally designated as a TV bands database
administrator under the Part 15 rules in an Order issued by the Commission on January 26, 2011, 26 FCC
Rcd 12827 (2011). Final approval for each designated database administrator’s operation of a TV bands
database system was subject to compliance with requirements that it: 1) supplement its previous filings
with sufficient information to demonstrate how it will comply with the rule changes adopted in the
Second Memorandum Opinion and Order (ET Docket No. 04-186, 25 FCC Rcd 18661 (2010)); 2) agree
that it will not use its capacity as a database manager to engage in any discriminatory or anti-competitive
practices or any practices that may compromise the privacy of users; 3) coordinate closely with the
agency to ensure competency, consistency, and compliance with the rules; 4) participate in a series of
mandatory workshops conducted by the Commission’s Office of Engineering and Technology (OET) to
address implementation issues and to ensure consistency and compliance with the rules; and 5) subject its
database to real-world testing for a period of not less than 45 days. This public trial is intended to allow
interested parties an opportunity to check that the database provides accurate results before being made
available for actual use by TV bands devices.
Key Bridge has provided the required submissions and has participated in the workshops in compliance
with conditions 1 through 4. In addition, it conducted a public trial of its database system as required by
condition 5 from March 11, 2013 to April 24, 2013. In this trial, Key Bridge made its channel availability
calculator, as well as its procedures for registering protected facilities, including low power auxiliary
services (principally licensed and unlicensed wireless microphones), MVPD receive sites, and temporary
broadcast auxiliary links that are not in the FCC databases available for testing by the public. Key
Bridge’s final report on its 45-day public trial was placed in the record of the TV white spaces
proceeding, ET Docket No. 04-186, and comments were requested in a Public Notice (Public Notice)
released May 29, 2013, DA 13-1220. In this report, Key Bridge indicated that it had satisfactorily
resolved all of the issues concerning its system that were reported during the trial.

No comments were received by the Commission concerning the Key Bridge database system’s channel
availability calculator or other aspects of the trial. Given that many parties that examined the Key Bridge
database system during its public trial, we find the absence of comments on the data base content, channel
availability calculator and registration features to be indicative that the system is satisfactory in those
Based on our own examination and testing of the Key Bridge database system, the results of the public
trial, including comments submitted to Key Bridge during the trial and Key Bridge’s responses to those
comments, and the fact that no comments expressing concerns were submitted in response to the Public
Notice, we find that Key Bridge has demonstrated that its channel availability calculator is able to
properly determine the unused channels at a location that may be used by the different types of unlicensed
TV bands devices. We also find that its registration procedures properly record, store and retrieve
protected facilities that are not in the FCC databases. In addition, we find that the Key Bridge database
system properly synchronizes registration records with the TV bands databases of Spectrum Bridge, Inc.,
iconectiv (formerly Telcordia Technologies, Inc.), and Google, Inc. using the White Space Database
Administrator Group’s Database-to-Database Synchronization Interoperability Specification, Version
1.01 September 12, 2011. We therefore find that Key Bridge’s TV bands database system is compliant
with the Commission’s rules for TV bands database systems and ready for operation. We have not yet
tested this database system with an actual TV bands device. When an application for a TV bands device
that accesses Key Bridge’s database system is processed, we will verify that the database’s provisions for
securing communications between a device and the database are functioning in accordance with the rules
in conjunction with our testing of the device itself.
As the implementation of the Commission’s plan for operation of TV bands devices proceeds, we
anticipate that there may be additional changes, generally minor, in various aspects of the plan. There
may also be elements of Key Bridge’s database system that will need to be adjusted as experience is
gained with TV white spaces operations by the Commission, the database administrators, device
manufacturers, and device users. We will provide instructions to Key Bridge and the other database
administrators to incorporate and test refinements at such time as they may be developed. We do not
generally expect that such refinements will necessitate additional testing through a public trial. We
anticipate that operation of these features will be verified by the OET staff. Nonetheless, we are reserving
the option to request that Key Bridge undertake additional public trial testing if we determine that such
testing is necessary to ensure that the database systems properly determine available channels and protect
authorized services.
Accordingly, we are granting approval for Key Bridge Global, LLC to operate its database system to
provide service to certified unlicensed devices that operate in the broadcast television bands as described
above. Authority for this action is provided in Section 0.241(h) and Sections 15.701-.715 of the
Commission’s rules, 47 C.F.R. § 0.241(h) and §§ 15.701-.715 and Sections 4, 5, 303, 304, 307, 336, and
554a of the Communications Act of 1934 as amended, 47 U.S.C. Secs. 154, 155, 302a, 303, 304, 307,
336, and 624a.
Julius P. Knapp
Chief, Office of Engineering and Technology

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