Renewal request

0129-EX-RR-2007 Text Documents

LOJACK CORPORATION

2007-07-18ELS_82608

FCC Form 405 Exhibit 1

REGARDING REQUEST FOR RENEWAL OF LICENSE

LoJack Corporation (“LoJack”) hereby supplements the subject request for
renewal of its experimental license KS2XBH with the following explanation. In its
application, LoJack requests renewal of its experimental license, initially granted in
1995, to continue use of the license in the manner in which it was originally issued.
For reasons set forth below, 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 SVRS rule, to police eligibles on a statewide basis
using the Wireless Telecommunications Bureau’s (WTB) Universal Licensing
System. Presently, LoJack units are authorized on a statewide basis for use in
twenty-seven 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 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

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

1

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.

Likewise, operation of the LoJack facilities in new areas for which Part 90
authority has not yet been issued will not compromise other users of the radio
spectrum as only SVRS operators, or proposed operators, would be eligible to use
the 173.075 MHz frequency requested herein.

2

Document Created: 2007-07-18 15:30:17
Document Modified: 2007-07-18 15:30:17

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