Supplemental Information

0119-EX-RR-2005 Text Documents

LOJACK CORPORATION

2005-08-24ELS_72380

0119-EX-RR-2005
Supplement 1

                       CLARIFICATION OF NATIONWIDE REQEUST

       LoJack Corporation (“LoJack”) hereby supplements its above-referenced
request for renewal of its experimental license KS2XBH in accordance with the
OET’s request of August 2, 2005 seeking additional information. In its
application, LoJack requested renewal of its experimental license, initially
granted in 1995, to continue use of the license in the manner in which it was
originally issued. In its correspondence, the OET requests clarification whether
LoJack continues to have need to operate its devices on an experimental basis
across the continental United States.

       LoJack is the designer of specialized units that are utilized in its
nationwide network that operates under the Commission’s Stolen Vehicle
Recovery System (“SVRS”) rule. 1 The LoJack SVRS consists of radio receiver-
transmitters installed in a hidden location in motor vehicles, tracking devices
mounted in police vehicles, and a computerized network of radio transmitters.
The units are ultimately licensed, in accordance with the Commission’s rule, to
state police eligibles on a statewide basis using the WTB’s Universal Licensing
System. Presently, LoJack units are authorized on a statewide basis for use in
twenty-three jurisdictions, including the District of Columbia and Puerto Rico.

       In anticipation of the initiation of the LoJack system in new jurisdictions,
LoJack engineers work with state police authorities for an extended period of
time to demonstrate the capabilities of the system at large and the specific
functionality of the LJU’s. During this critical stage of the development of new
statewide systems, LoJack performs demonstrations of its equipment using its
experimental license. Once demonstration of the equipment is complete and the
police authorities have committed to proceeding with the installation of a
statewide system, those police eligibles file for Part 90 authority to operate the
system on a permanent basis.

      LoJack’s request for renewal of its nationwide authorization is supported
by good cause. LoJack filed its initial request for experimental authority on the
premise that a nationwide license would be more prudent and much less
resource-intensive for the OET’s staff as an alternative to filing individual STA
requests to operate in specific states in anticipation of upcoming demonstrations.
Furthermore, in many cases, the demonstration and testing of LoJack’s
equipment in a specific state exceeds the standard six-month period permitted

1   47 C.F.R. 90.20(e)(6).


for experimental Special Temporary Authority (“STA”) and LoJack would thus
further burden the staff with regular requests for extension of those STA’s.
Understanding that the LoJack SVRS network would likely be expanded
throughout much of the United States, LoJack viewed a permanent nationwide
authorization as more representative of the true need it would have for the use of
its equipment. As intentional radiators that are ultimately authorized under Part
90 of the Commission’s rules, LJU’s are not permitted to operate under the
Commission’s generic demonstration rules absent experimental authority.

       LoJack’s nationwide network and the units that are members of it operate
solely on the 173.075 MHz frequency, for which SVRS networks have the only
authority. At this point, LoJack’s network is the only SVRS network so
authorized. Accordingly, grant of LoJack’s renewal request will not interfere
with or compromise in any way other users of the radio spectrum.

       For the reasons set forth above, LoJack respectfully requests that the OET
grant its experimental renewal application on a nationwide basis. Given the
benefits of LoJack’s SVRS to the public at large and the important role that the
subject experimental license plays in the expansion of the SVRS, LoJack submits
that grants of its request would fully be in the public interest.

       Should you have any additional questions, please direct them to Ryan N.
Terry, at Goldberg, Godles, Wiener & Wright, (202) 429-4900.



Document Created: 2005-08-24 13:07:00
Document Modified: 2005-08-24 13:07:00

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