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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554

   In the Matter of ) File Nos.: EB-10-CG-0011

   ) EB-10-LA-0001

   )

   ReconRobotics, Inc. ) Acct. No.: 201132320004

   )

   ) FRN: 0016022279

                                     ORDER

   Adopted: July 12, 2011 Released: July 13, 2011

   By the Regional Director, Northeast Region, Enforcement Bureau:

   1. In this Order, we adopt the attached Consent Decree entered into
   between the Enforcement Bureau ("Bureau") of the Federal Communications
   Commission ("FCC" or "Commission") and ReconRobotics, Inc.
   ("ReconRobotics"). The Consent Decree terminates an investigation by the
   Bureau into whether ReconRobotics violated section 302a(b) of the
   Communications Act of 1934, as amended ("Act"), and section 2.803 of the
   Commission's rules ("Rules"), regarding the manufacturing, marketing,
   distributing, and selling of radio frequency transmitters.

   2. The Bureau and ReconRobotics have negotiated the terms of a Consent
   Decree that resolve this matter. A copy of the Consent Decree is attached
   hereto and incorporated herein by reference.

   3. After reviewing the terms of the Consent Decree and evaluating the
   facts before us, we find that the public interest would be served by
   adopting the Consent Decree and terminating the investigation.

   4. In the absence of material new evidence relating to this matter, we
   conclude that our investigation raises no substantial or material
   questions of fact as to whether ReconRobotics possesses the basic
   qualifications, including those related to character, to hold or obtain
   any Commission license or authorization.

   5. Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the Act,
   and sections 0.111 and 0.311 of the Rules, the Consent Decree attached to
   this Order IS ADOPTED.

   6. IT IS FURTHER ORDERED that the above-captioned investigation IS
   TERMINATED.

   7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
   shall be sent by first class and certified mail, return receipt requested,
   to counsel for ReconRobotics, Inc., Mitchell Lazarus, Fletcher, Heald &
   Hildreth, P.L.C., 1300 North 17th Street 11th Floor, Arlington, VA 22209.

   FEDERAL COMMUNICATIONS COMMISSION

   G. Michael Moffitt

   Regional Director

   Northeast Region Enforcement Bureau

                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554

   In the Matter of ) File Nos. EB-10-CG-0011

   ) EB-10-LA-0001

   )

   ReconRobotics, Inc. ) Acct. No.: 201132320004

   )

   ) FRN No. 0016022279

                                 CONSENT DECREE

    1. The Enforcement Bureau and ReconRobotics, Inc., by their authorized
       representatives, hereby enter into this Consent Decree for the purpose
       of terminating the Enforcement Bureau's investigation into whether
       ReconRobotics, Inc. violated section 302a(b) of the Communications Act
       of 1934, as amended ("Act"), and section 2.803 of the Commission's
       rules, regarding the manufacturing, marketing, distributing, and
       selling of radio frequency transmitters.

   I. DEFINITIONS

    2. For the purposes of this Consent Decree, the following definitions
       shall apply:

     a. "Act" means the Communications Act of 1934, as amended 47 U.S.C. S:
        151 et seq.

     b. "Bureau" means the Enforcement Bureau of the Federal Communications
        Commission.

     c. "Commission" and "FCC" mean the Federal Communications Commission and
        all of its bureaus and offices.

     d. "Effective Date" means the date on which the Bureau releases the
        Adopting Order.

     e. "Compliance Plan" means the program described in this Consent Decree
        at paragraph 9.

     f. "Investigation" means the investigation initiated by the Bureau's
        March 15, 2010 letter of inquiry regarding possible violations by
        ReconRobotics of section 302a(b) of the Act and section 2.803(a)(1)
        of the Rules.

     g. "ReconRobotics" or "the Company" means ReconRobotics, Inc. and its
        subsidiaries and their predecessors-in-interest and
        successors-in-interest.

     h. "Order" or "Adopting Order" means an Order of the Bureau adopting the
        terms of this Consent Decree without change, addition, deletion, or
        modification.

     i. "Parties" means ReconRobotics and the Bureau, and each is a "Party."

     j. "Rules" means the Commission's regulations found in Title 47 of the
        Code of Federal Regulations.

   II. BACKGROUND

    3. Section 302a(b) of the Act and section 2.803(a)(1) of the Rules
       prohibit the marketing of radio frequency devices in the United States
       unless such devices comply with the applicable technical and
       administrative provisions of the Rules.

    4. On March 15, 2010, in response to a complaint alleging that the
       Company had unlawfully marketed the Recon Scout surveillance device
       before receiving an equipment certification from the Commission, the
       Bureau's Chicago Field Office issued a letter of inquiry ("LOI") to
       ReconRobotics. The Recon Scout is a remote-controlled, maneuverable
       surveillance robot operating in the 420-450 MHz band. The LOI directed
       ReconRobotics to respond to a series of questions regarding the
       manufacturing, marketing, distributing, and selling of the Recon Scout
       surveillance device. ReconRobotics responded to the LOI on April 23,
       2010 and ReconRobotics and the Bureau subsequently entered into
       settlement discussions.

   III. TERMS OF AGREEMENT

    5. Adopting Order. The Parties agree that the provisions of this Consent
       Decree shall be subject to final approval by the Bureau by
       incorporation of such provisions by reference in the Adopting Order
       without change, addition, modification, or deletion.

    6. Jurisdiction. ReconRobotics  agrees that the Bureau has jurisdiction
       over it and the matters contained in this Consent Decree and has the
       authority to enter into and adopt this Consent Decree.

    7. Effective Date; Violations. The Parties agree that this Consent Decree
       shall become effective on the Effective Date. Upon release, the
       Adopting Order and this Consent Decree shall have the same force and
       effect as any other Order of the Bureau. Any violation of the Adopting
       Order or of the terms of this Consent Decree shall constitute a
       separate violation of a Bureau Order, entitling the Bureau to exercise
       any rights and remedies attendant to the enforcement of a Commission
       Order.

    8. Termination of Investigation. In express reliance on the covenants and
       representations in this Consent Decree and to avoid further
       expenditure of public resources, the Bureau agrees to terminate the
       Investigation. In consideration for the termination of the
       Investigation, ReconRobotics agrees to the terms, conditions, and
       procedures contained herein. The Bureau further agrees that in the
       absence of new material evidence, the Bureau will not use the facts
       developed in this Investigation through the Effective Date of the
       Consent Decree, or the existence of this Consent Decree, to institute,
       on its own motion, any new proceeding, formal or informal, or take any
       action on its own motion against ReconRobotics, or any party engaged
       in the evaluation of ReconRobotics's products, concerning the matters
       that were the subject of the Investigation. The Bureau also agrees
       that it will not use the facts developed in this Investigation through
       the Effective Date of this Consent Decree, or the existence of this
       Consent Decree, to institute on its own motion any proceeding, formal
       or informal, or take any action on its own motion against
       ReconRobotics with respect to ReconRobotics's basic qualifications,
       including its character qualifications, to be a Commission licensee or
       to hold Commission licenses or authorizations.

    9. Compliance Plan. For purposes of settling the matters set forth
       herein, ReconRobotics agrees, within thirty (30) days of the Effective
       Date, to create and maintain a Compliance Plan related to future
       compliance with the Act and the Rules and orders concerning the
       manufacturing, marketing, distribution, and selling of radio frequency
       devices. The Compliance Plan will include, at a minimum, the following
       components:

   (a)  Training. Within sixty (60) days of the Effective Date, ReconRobotics
   will implement and conduct a training program for all of its employees
   responsible for the development, marketing, and sourcing of radio
   frequency devices by ReconRobotics in the United States. New employees, or
   reassigned employees who take on such responsibilities, will be provided
   such training within 30 days of hiring or reassignment.

   (b)  Compliance Officer. ReconRobotics shall designate a Compliance
   Officer within thirty (30) days of the Effective Date. The Compliance
   Officer shall be responsible for administering the Compliance Plan and
   shall be the individual with central responsibility for overseeing
   ReconRobotics's compliance with the Compliance Plan and with the Act and
   the Rules and orders.

   (c) Review and Monitoring. ReconRobotics shall review the Compliance
   Training Program to ensure that it continues to ensure compliance with the
   Act and the Commission's Rules and orders pertaining to the development,
   marketing and sourcing of radio frequency devices. ReconRobotics shall
   update the Compliance Training Program as necessary and appropriate, and
   in the event of changes and/or additions to the relevant Rules and orders
   shall update the Compliance Training Program within thirty (30) days after
   the effective date of any such change or addition.

   (d)  Compliance Reports. ReconRobotics shall file Compliance Reports with
   the Commission ninety (90) days after the Effective Date, twelve (12)
   months after the Effective Date, and twenty-four (24) months after the
   Effective Date. ReconRobotics also shall disclose any failure to comply
   with the terms and conditions of this Consent Decree within fifteen (15)
   business days after discovery of such failure to comply.

       1. Each Compliance Report shall include assertions by ReconRobotics
          that it:

            a. has established operating procedures intended to ensure
               compliance with the terms and conditions of this Consent
               Decree and with the relevant sections of the Rules, together
               with an accompanying statement explaining the basis for the
               assertion;

            b. has been utilizing these procedures for the entire term of the
               Compliance Plan;

            c. has disclosed any known instances of non-compliance with this
               Compliance Plan discovered during the reporting period; and

            d. has addressed any instances of non-compliance and taken steps
               to remedy the cause thereof.

       2. Each Compliance Report must be supported by the declaration of an
          officer as an agent of and on behalf of ReconRobotics with personal
          knowledge of the representations provided in the report, verifying
          the truth and accuracy of the information. The declaration must
          comply with section 1.16 and be subscribed to as true under penalty
          of perjury in substantially the same form set forth therein.

       3. Any instance of non-compliance with the Compliance Plan disclosed
          in the report shall provide:

            a. a detailed explanation of the non-compliance;

            b. the steps ReconRobotics has taken to remedy the non-compliance
               and ensure future compliance; and

            c. the schedule on which the proposed remedial actions will be
               taken.

   (e) Filing. All Compliance Reports and other disclosures required by this
   Consent Decree shall be submitted to Sharon Webber, Regional Counsel,
   Northeast Region, Enforcement Bureau, Federal Communications Commission,
   One Oxford Valley Office Building, Room 404, 2300 East Lincoln Highway,
   Langhorne, PA 19047. ReconRobotics must also transmit a copy of the
   reports via email to NER-Response@fcc.gov.

   10. Termination Date. Unless stated otherwise, the requirements of
       paragraph 9 of this Consent Decree will expire twenty-four (24) months
       after the Effective Date.

   11. Voluntary Contribution. ReconRobotics agrees that it will make a
       voluntary contribution to the United States Treasury in the amount of
       seventeen thousand five hundred dollars ($17,500). The payment will be
       made within thirty (30) calendar days after the Effective Date. The
       payment must be made by check or similar instrument, payable to the
       order of the Federal Communications Commission. The payment must
       include the Account Number and FRN referenced in the caption to the
       Adopting Order. Payment by check or money order may be mailed to
       Federal Communications Commission, P.O. Box 979088, St. Louis, MO
       63197-9000. Payment by overnight mail may be sent to U.S. Bank -
       Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
       Louis, MO 63101. Payment by wire transfer may be made to ABA Number
       021030004, receiving bank TREAS/NYC, and account number 27000001. For
       payment by credit card, an FCC Form 159 (Remittance Advice) must be
       submitted. When completing the FCC Form 159, enter the Account number
       in block number 23A (call sign/other ID), and enter the letters "FORF"
       in block number 24A (payment type code). ReconRobotics will also send
       electronic notification to NER-Response@fcc.gov on the date said
       payment is made.

   12. Waivers. ReconRobotics waives any and all rights it may have to seek
       administrative or judicial reconsideration, review, appeal, or stay,
       or to otherwise challenge or contest the validity of this Consent
       Decree and the Adopting Order, provided the Bureau issues an Adopting
       Order adopting the Consent Decree without change, addition,
       modification, or deletion. ReconRobotics shall retain the right to
       challenge Commission interpretation of the Consent Decree or any terms
       contained herein. If either Party (or the United States on behalf of
       the Commission) brings a judicial action to enforce the terms of the
       Adopting Order, neither ReconRobotics nor the Commission shall contest
       the validity of the Consent Decree or the Adopting Order, and
       ReconRobotics shall waive any statutory right to a trial de novo.
       ReconRobotics hereby agrees to waive any claims it may otherwise have
       under the Equal Access to Justice Act, 5 U.S.C. S: 504 and 47 C.F.R.
       S: 1.1501 et seq., relating to the matters addressed in this Consent
       Decree.

   13. Invalidity. In the event that this Consent Decree is rendered invalid
       by a court of competent jurisdiction, it shall become null and void
       and may not be used in any manner in any legal proceeding.

   14. Subsequent Rule or Order. The Parties agree that if any provision of
       the Consent Decree conflicts with any subsequent Rule or order adopted
       by the Commission (except an order specifically intended to revise the
       terms of this Consent Decree to which ReconRobotics does not expressly
       consent) that provision will be superseded by such Rule or order.

   15. Successors and Assigns. ReconRobotics agrees that the provisions of
       this Consent Decree shall be binding on its successors, assigns, and
       transferees.

   16. Final Settlement. The Parties agree and acknowledge that this Consent
       Decree shall constitute a final settlement between the Parties. The
       Parties further agree that this Consent Decree does not constitute
       either an adjudication on the merits or a factual or legal finding or
       determination regarding any compliance or noncompliance with the
       requirements of the Act or the Commission's Rules and Orders.

   17. Modifications. This Consent Decree cannot be modified without the
       advance written consent of both Parties.

   18. Paragraph Headings. The headings of the paragraphs in this Consent
       Decree are inserted for convenience only and are not intended to
       affect the meaning or interpretation of this Consent Decree.

   19. Authorized Representative. Each party represents and warrants to the
       other that it has full power and authority to enter into this Consent
       Decree.

   20. Counterparts. This Consent Decree may be signed in any number of
       counterparts (including by facsimile), each of which, when executed
       and delivered, shall be an original, and all of which counterparts
       together shall constitute one and the same fully executed instrument.


     _______________________________    
                                        
     G. Michael Moffitt                 
                                        
     Regional Director                  
                                        
     Northeast Region                   
                                        
     Enforcement Bureau                 
                                        
     ________________________________   
                                        
     Date                               
                                        
     ________________________________   
                                        
     Alan Bignall                       
                                        
     President and CEO                  
                                        
     ReconRobotics, Inc.                
                                        
     ________________________________   
                                        
     Date                               


   47 U. S. C. S: 302a(b).

   47 C.F.R. S:S: 2.803(a)(1).

   47 U. S. C. S:154(i).

   47 C.F.R. S:S: 0.111, 0.311.

   47 U. S. C. S: 302a(b).

   47 C.F.R. S:S: 2.803(a)(1).

   Letter from Mr. James M. Roop, District Director, Chicago Office,
   Northeast Region, Enforcement Bureau to Alan Bignall, President and CEO,
   ReconRobotics, Inc. (March 15, 2010).

   47 U.S.C. S: 302a(b); 47 C.F.R. S: 2.803(a)(1).

   See LOI, n.3 supra.

   Letter from Mitchell Lazarus and Christine E. Goepp, Counsel for
   ReconRobotics, Inc., to Mr. James M. Roop, District Director, Chicago
   Office, Northeast Region, Enforcement Bureau (April 23, 2010).

   Federal Communications Commission  DA 11-1188

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   Federal Communications Commission  DA 11-1188

   DRAFT Federal Communications Commission  DA 11 - XX

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