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   January 31, 2007

   VIA CERTIFIED MAIL

   RETURN RECEIPT REQUESTED

   AND FACSIMILE

   Ms. Doris J. Conway

   Global Trade Group, Inc.

   P.O. Box 783

   Rogue River, Oregon 97537

   cc: Global Trade Group, Inc.

   1333 W. Evans's Greek Road

   Rogue River, Oregon 97537

   Re: File No. EB-05-SE-270

   Dear Ms. Conway:

   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 in the United States certain police radar jamming devices
   manufactured by Rocky Mountain Radar ("RMR"), specifically, the RMR-S201
   and RMR-C450 devices, in violation of Section 302(b) of the Act, 47 U.S.C.
   S 302a(b), and Sections 2.803, 15.205 and 15.209 of the Commission's Rules
   ("Rules"), 47 C.F.R. SS 2.803, 15.205 and 15.209. As explained below,
   future violations of the Commission's rules in this regard may subject
   your company to monetary forfeitures.

   The Spectrum Enforcement Division ("Division") of the Enforcement Bureau
   obtained information through several informal complaints alleging that
   various entities, including Global Trade Group, Inc., were marketing
   police radar jamming devices in the United States. On June 8, 2005 and
   June 10, 2005, Division staff visited Global Trade Group, Inc.'s internet
   web site, www.ceipro.com, and observed that Global Trade Group, Inc. was
   marketing the RMR-S201 (also known as the Phazer II) and the RMR-C450
   devices. On September 1, 2005, the Division issued a letter of inquiry
   ("LOI") to Global Trade Group, Inc. requesting certain information
   concerning its marketing of these devices. In its September 15, 2005
   response to the LOI, Global Trade Group, Inc. acknowledged that it
   marketed the RMR-S201 and RMR-C450 devices and claimed that due to poor
   sales it had already made a corporate decision to remove these devices
   from its sales merchandise. Global Trade Group, Inc. further stated that
   it had contacted the manufacturer, RMR, which claimed that the RMR-S201
   and the RMR-C450 devices are not intentional radiators and "have been
   tested and certified by the FCC."

   The Commission's Office of Engineering and Technology ("OET") Laboratory
   subsequently obtained samples of the RMR-S201 and RMR-C450 devices
   directly from RMR for testing. Testing of the samples indicated that both
   units are designed to emit a signal that intentionally interferes with a
   licensed radio service (police radar), and are indeed capable of
   interfering with police radar. Therefore, the OET Laboratory concluded
   that the devices are intentional radiators, as described in Section
   15.3(o) of the Rules, 47 C.F.R. S 15.3(o). In addition, the OET
   Laboratory's tests indicated that the RMR-C450 device produced a radiated
   emission at 11.23 GHz, a restricted frequency band listed in Section
   15.205 of the Rules, 47 C.F.R. S 15.205, and that this radiated emission
   substantially exceeds the radiated emission limits for intentional
   radiators specified in Section 15.209 of the Rules, 47 C.F.R. S 15.209.
   The OET Laboratory also concluded that the RMR-C450 device was improperly
   certified. In this regard, the OET Laboratory noted that the grant of
   certification issued for the RMR-C450 device indicates that the device was
   tested as an "unintentional radiator." As explained above, however, the
   OET Laboratory found that the device is an intentional radiator.

   On January 23, 2007, the Division staff again visited Global Trade Group,
   Inc.'s internet web site and observed that Global Trade Group, Inc. was
   continuing to market the RMR-S201 and RMR-C450 devices.

   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 to this section." Section 2.803(a)(1) of the Rules, 47 C.F.R.
   S 2.803(a)(1), 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.

   Pursuant to Section 15.201 of the Rules, 47 C.F.R. S 15.201, intentional
   radiators must ordinarily be authorized in accordance with the
   certification procedure prior to marketing. Section 2.803(g) of the Rules,
   47 C.F.R. S 2.803(g), however, provides in pertinent part that:

   [R]adio frequency devices that could not be authorized or legally operated
   under the current rules ... shall not be operated, advertised, displayed,
   offered for sale or lease, sold or leased, or otherwise marketed absent a
   license issued under part 5 of this chapter or a special temporary
   authorization issued by the Commission.

   Further, Section 333 of the Act, 47 U.S.C. S 333, prohibits any person
   from willfully or maliciously interfering with or causing interference to
   any radio communications of any station licensed or authorized by the
   Commission. Moreover, Section 15.205 of the Rules, 47 C.F.R. S 15.205,
   prohibits radiated emissions, other than spurious emissions, in any of the
   restricted frequency bands listed in that section. Thus, intentional
   radiators that cannot legally be operated - because, for example, they
   interfere with or jam licensed police radio facilities or operate in
   restricted frequency bands - are not eligible for a grant of equipment
   certification. Finally, Section 15.209 of the Rules sets forth the
   radiated emission limits applicable to intentional radiators.

   As noted above, contrary to the claims of RMR, the RMR-S201 and RMR-C450
   devices are intentional radiators. These devices are not, however,
   eligible for a grant of certification because their intended purpose is to
   interfere with Commission authorized radio facilities, specifically,
   licensed police radar, in violation of Section 333 of the Act, and the OET
   Laboratory has determined that these devices in fact are capable of
   interfering with police radar. Moreover, there are two additional grounds
   for finding the marketing of the RMR-C450 device to be unlawful. The
   RMR-C450 device is not eligible for a grant of certification because it
   produces a radiated emission in the restricted frequency band at 11.23 GHz
   in violation of Section 15.205 of the Rules. This radiated emission also
   substantially exceeds the radiated emission limits for intentional
   radiators specified in Section 15.209 of the Rules. We note that on
   January 31, 2007, concurrently with the issuance of this Citation, the
   Division issued a Notice of Apparent Liability for Forfeiture proposing a
   $25,000 forfeiture against RMR for marketing the RMR-S201 and RMR-C450
   devices in apparent willful and repeated violation of Section 302(b) of
   the Act and Sections 2.803, 15.205 and 15.209 of the Rules.

   The record before us indicates that Global Trade Group, Inc. has marketed
   and continues to market the RMR-S201 and the RMR-C450 devices.
   Accordingly, it appears that Global Trade Group, Inc. has violated Section
   302(b) of the Act and Section 2.803 of the Rules by marketing the RMR-S201
   and RMR-C450 devices, which are not eligible for a grant of equipment
   certification because they are intended to interfere with licensed police
   radar, in violation of Section 333 of the Act. Global Trade Group, Inc.
   has also apparently violated Section 302(a) of the Act and Sections 2.803,
   15.205 and 15.209 of the Rules by marketing the RMR-C450 device, which is
   not eligible for a grant of equipment certification because it produces a
   radiated emission in the restricted frequency band at 11.23 GHz, and which
   produces emissions that substantially exceed the radiated emission limits
   for intentional radiators.

   If, after receipt of this citation, Global Trade Group, Inc. violates 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.

   If you choose to do so, 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 Global
   Trade Group, Inc.-Detectors is taking to ensure that it does not violate
   the Commission's rules governing the marketing of intentional radiating
   jamming devices in the future.

   The nearest Commission field office is the Portland Resident Agent Office
   in Vancouver, WA. Please call Jacqueline Johnson at 202-418-2871 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 S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   Federal Communications Commission

   445-12^th 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 S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   "Marketing" is defined as "sale or lease, or offering for 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).

   See Letter from Kathryn Berthot, Deputy Chief, Spectrum Enforcement
   Division, Enforcement Bureau, Federal Communications Commission to Global
   Trade Group, Inc. (September 1, 2005).

   See Letter from Doris J. Conway, Global Trade Group, Inc., to Susan
   Magnotti, Spectrum Enforcement Division, Enforcement Bureau, Federal
   Communications Commission (September 15, 2005).

   Id.

   An intentional radiator is defined by Section 15.3(o) of the Rules, 47
   C.F.R. S 15.3(o), as "[a] device that intentionally generates and emits
   radio frequency energy by radiation or induction."

   RMR obtained certification for the RMR-C450 under FCC ID No. QKK-C03 by
   representing to a Telecommunications Certification Body that the device
   was a radar detector. We note, however, that RMR marketed the device as a
   radar detector and a radar "scrambler."

   An "unintentional radiator" is defined by Section 15.3(z) of the Rules, 47
   C.F.R. S 15.3(z), as:

   [a] device that intentionally generates radio frequency energy for use
   within the device, or that sends radio frequency signals by conduction to
   associated equipment via connecting wiring, but which is not intended to
   emit RF energy by radiation or induction.

   Section 2.1(c) of the Rules, 47 C.F.R. S 2.1(c), defines a spurious
   emission as "Emission 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."

   Rocky Mountain Radar, Notice of Apparent Liability for Forfeiture, DA
   07-299 (Enf. Bur., Spectrum Enf. Div., rel. January 31, 2007).

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

   Federal Communications Commission DA 07-309

   2

   Federal Communications Commission DA 07-309

                       FEDERAL COMMUNICATIONS COMMISSION

                            WASHINGTON, D.C.  20554