Background Information

0772-EX-ST-2013 Text Documents

Adeunis NA, Inc.

2013-08-08ELS_140132

Adeunis-NA, Inc. STA Background Information – Exhibit “A” The Company Adeunis-NA, Inc. (“Adeunis”) is the United States subsidiary of Adeunis RF (“ARF”), a French corporation engaged in the design, manufacture and marketing of wireless communications systems. Adeunis is headquartered at 65 Pondfield Rd., Suite 14, Bronxville, NY 10708. ARF headquarters is located at 283 rue Louis Néel Crolles, Rhône-Alpes, 38920, France. The Vokkero Radio System and Its Uses Among ARF’s products sold by Adeunis is the Vokkero® radio system (FCC Identifier U3Z-ARF7672). The Vokkero radio system is an all-in-one, full-duplex, hands- free communication system that enables individuals to speak to each other, using a private and portable wireless network. The Vokkero radio system can be set up in minutes and requires no base station or license, as it operates on unlicensed Part 15 spectrum as an “intentional radiator” (a “Part 15C device”). Specifically, it operates 25 500 KHz channels within the 902-928 MHz band, transmitting and receiving signals between 902.25 MHz and 927.75 MHz, at 0.233 Watts of power. Its signals have a range of approximately 800 meters in an open field environment and somewhat less in a major college football stadium. Its high-performance noise filter ensures optimal sound quality in noisy environments. In Europe and other parts of the world, ARF has sold the Vokkero radio system to many customers, especially those in competitive sports. One of the leading uses of the product is by soccer referees in major competitions such as the World Cup and the Champions League. It is also used by all of the best European-wide and nationwide leagues, as well as by many leagues and competitions in the Americas that belong to, or are affiliated with, the Confederation of North, Central American and Caribbean Association Football (“CONCACAF”). Additionally, use of the Vokkero radio system has spread to other sports, including American football, ice hockey, rugby, basketball, field hockey, and competitive sailing. Use by the SEC for the 2013 Football Season In 2012, the National Collegiate Athletic Association (“NCAA”) granted a waiver to the Southeastern Conference (“SEC”) and to the Big Ten Conference to permit the entire officiating team of referees to test the Vokkero radio system during certain football games. Existing NCAA football rules permit only the head referee to wear a microphone. The goals of the test were to “identify pre-snap reads, become more 1

efficient in enforcing penalties without huddling, and explain rulings better to coaches.”1 These improvements can result in better officiating and fewer game delays, similar to what has been found with soccer officiating. Using the NCAA waiver, two major football conferences tested the Vokkero radio system during the 2012 spring football practice season.2 One of the test goals was to determine whether the system could function without receiving interference from other RF devices.3 The radio system also was used in SEC games during the 2012 football season. Interference and Solution Among those RF devices are radio systems against which the Vokkero radio system was tested were certain radio communications systems used by the football coaches to communicate among themselves during games (“Coaches’ Systems”). These other radio systems are made by several manufacturers and also utilize 900 MHz frequencies, most often within the 902-928 MHz band. During the trials of the Vokkero radio system, referees experienced sporadic interference from the Coaches’ Systems. The interference was such that communications among the referees was interrupted on an “on-off, on-off” basis when there was transmission by the Coaches’ Systems.4 The RF interference made communication among the referees less than satisfactory, even though the Vokkero system was viewed as a positive development for football officiating. As noted, the SEC desires to use the Vokkero radio system for all of the 2013 “home” football games. ARF engineers are working to modify the Vokkero radio system to eliminate interference from other 902-928 MHz users (i.e., the Coaches’ Systems) while continuing to use the same frequencies. This work began June 1, 2013. ARF believes such modifications can be completed reasonably soon, but not necessarily immediately. ARF’s best estimate is that the modifications will take approximately six more months or by end of January 2014 to complete. 1 http://www.al.com/sports/index.ssf/2012/07/sec_will_try_wireless_communic.html (visited August 5, 2013). 2 http://espn.go.com/college-football/story/_/id/8314421/sec-officials-wear-wireless- microphones-thursday-game-south-carolina-gamecocks-vanderbilt-commodores (visited August 5, 2013). The Vokkero radio system has been used in high school football as well. “The Alabama High School Athletic Association (AHSAA) … demonstrate[ed] a new approach to officiating Friday night as top-ranked Muscle Shoals visit[ed] Cullman for the final Class 5A, Region 8 game of the season” in October 2012. The Vokkero radio system was used game officials. http://www.cullmantimes.com/local/x253554419/Cullman-game-will-feature- equipment-test-for-officiating-crew (visited August 5, 2013). 3 Id. 4 Adeunis employees have become aware that, on the occasion when both football teams’ coaches are communicating via radio headsets, one or more of the Coaches’ Systems receive interference. Needless to say, the Vokkero radio system is not a cause of this interference. 2

This timing issue presents a problem because, as noted above, Adeunis has contracted with the SEC to supply the Vokkero radio system for use by conference referees during the 2013 football season that begins August 29, 2013 and ends in late 2013 with the conference championship game at the Georgia Dome in Atlanta. In order to offer its customers a better experience with the Vokkero radio system by eliminating the possibility of interference from the Coaches’ Systems, during the 2013 SEC football season, Adeunis engineers believe the Adeunis product can be easily set, without costly and time-consuming modifications, to operate at either the 860-870 MHz band or the 900-930 MHz band. The 860-870 MHz sub-band lies within the larger 854-894 MHz band that is allocated to Fixed and Mobile services subject to Parts 22 and 90 of the FCC’s rules. The 900-930 MHz band covers the 896-901, 901-902, 902-928,5 928-929, and 929-930 MHz bands. The 896-901 MHz band is allocated to Fixed and Mobile services subject to Part 90. The 901-902 MHz band is allocated to Fixed and Mobile services subject to Part 24. The 928-929 MHz band is allocated to Fixed subject to Parts 22, 90 and 101. Finally, the 929-930 MHz band is allocated to Fixed and Land Mobile services subject to Part 90 of the FCC’s rules. After research and testing by its engineers and using input from a leading radio frequency coordinator, MRFAC, Inc., Adeunis has selected the 900-901 MHZ band for its Special Temporary Authorization (“STA”) application. An STA Is Required and Warranted under the Facts Section 309(f) of the Communications Act of 1934, as amended, 47 U.S.C. 309(f), authorizes the FCC to grant an applicant for a license to use radio spectrum on a special, temporary basis, not to exceed 180 days, whenever the FCC determines “such application is otherwise authorized by law”; “there are extraordinary circumstances requiring temporary operations in the public interest and that delay in the institution of such temporary operations would seriously prejudice the public interest.” As explained in this application, the Vokkero radio system has begun to bring benefits to college football in the form of better officiating, better communication of referee decisions and fewer game delays, each of which better serve fans, players and coaches, as well as referees. Despite the existence of some radio interference, the SEC saw sufficient value in the Vokkero radio system from the 2012 trials to agree with Adeunis to use the system for all home games and for the league championship game in 2013. It is in the public interest for the SEC to have access to the system for the entire season, even though the AFR engineers may not have the interference problem 5 Since the Vokkero radio system already operates in the 902-928 MHz band, subject to interference as described herein, Adeunis is not considering those frequencies in connection with this application. Rather, Adeunis is simply explaining the present capabilities of its radio system. 3

remedied before the end of the 2013 football season. This result can be achieved by the Commission’s grant of an STA to allow operation of the Vokkero radio system on 900-901 MHz.6 Similarly, it would not serve the public interest for the Commission to delay the SEC’s use of the Vokkero radio system beyond the opening football games that begin in late August 2013. The requirements of Section 309(f) are satisfied, such that the STA should be granted as soon as possible. 6 The Commission has granted STAs to enable the continued provision of services to customers. See, e.g., Intelsat North America, LLC Request for Extension of Special Temporary Authority, Order, 20 FCC Rcd 7955 (2005). 4


Document Created: 2013-08-08 11:13:52
Document Modified: 2013-08-08 11:13:52
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