Renewal Exhibit

0174-EX-RR-2009 Text Documents

LOJACK CORPORATION

2009-07-09ELS_99776

FCC Form 405 Exhibit 1

REQUEST FOR RENEWAL OF LICENSE (CALL SIGN KS2XBH)

LoJack Corporation (“LoJack”) herein supplements its application for renewal
of its experimental license KS2XBH. 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 thirty
(30) 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.

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

1

Understanding that the LoJack SVRS network would continue to be
expanded throughout the United States, LoJack has viewed a permanent nationwide
authorization as more representative of the true need it has 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.

At the same time, however, 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, are eligible to use
the 173.075 MHz frequency requested herein. 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.

2

Document Created: 2009-07-09 11:17:30
Document Modified: 2009-07-09 11:17:30

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