Particulars of Experimentation

0057-EX-ML-2014 Text Documents

LoJack Corporation

2014-03-12ELS_146830

    APPLICATION FOR MODIFICATION OF EXPERIMETNAL AUTHORITY
       IN ORDER TO ADD A NEW LOCATION (CALL SIGN WD2XYL)


      LoJack Corporation (“LoJack”) herein submits an application for
modification of its existing permanent experimental authority (Call Sign
WD2XYL) in order to add a new location proximate to the original location at
which it currently operates on an experimental basis.

        As LoJack stated in its initial application for experimental authority,1 it
relies upon such authority to continue development and testing of next
generation Vehicle Location Units (“VLU”), the radio devices both used by police
and implanted within automobiles to communicate a stolen automobile’s
location when activated. In particular, LoJack has been developing and testing
advanced VLU devices that will be used in foreign markets. LoJack herein seeks
expanded experimental authority to add one new location at which it will also
develop and test the devices, consistent with its original authorization.

        As background, LoJack has an engineering facility in Canton, MA where it
develops enhancements for the vehicle transceiver units that are deployed in its
Stolen Vehicle Recovery System (“SVRS”), which the Commission authorized in
1989. 2 As part of the LoJack SVRS, automobiles are equipped with VLU’s, which
remain dormant until police send a specific activation message based on a stolen
vehicle report. The police first verify the accuracy of the stolen vehicle
information with the NCIC database, then activate the LoJack system, which uses
the base stations to turn on the VLU transponder in the stolen vehicle.

        In addition to its engineering facility in Canton, MA, LoJack seeks to
expand testing of the device to its manufacturing facility located approximately
40 miles away in Westborough, MA. Having experimental authority at this
second location will permit LoJack to investigate and implement technical
improvements to the next generation VLU’s as manufacturing commences and
different prototypes are tested to enhance their capabilities. The next generation
VLU’s are being developed with a particular emphasis on operating in a more
efficient narrowband environment.

       As described in greater detail below, the subject VLU’s are specifically
intended to be manufactured and exported exclusively to foreign customers for
use in LoJack systems abroad. The details of the experimental program remain



1   FCC File No. 0176-EX-PL-2006.
2   4 FCC Rcd. 7558 (rel. Oct. 16, 1989).


essentially the same as outlined in LoJack’s initial request for experimental
authority:

   (1) As stated above, for over 8 years LoJack has been conducting an ongoing
       program of product development and testing of next generation Vehicle
       Location Units for international licensees operating in a narrowband
       environment.
   (2) LoJack’s authority for the use of the 164.175 MHz frequency is subject to
       its current experimental authorization. The requested frequency is a
       center frequency in the band that most of the rest of the world has carved
       out for SVRS, and LoJack requires only the single frequency for testing its
       devices in that band. As previously stated, LoJack has no intention of
       migrating to the use of this frequency for use in any domestic SVRS.
   (3) The purpose of the expanded license is to develop further and test the
       product in and around the LoJack manufacturing facility in Westborough,
       MA. In order to expedite the product development process and realize
       the gains afforded by the new functionality of the VLU’s, LoJack needs to
       conduct this product testing for its international licensees in the United
       States, near to where its engineering facilities are located.
   (4) The testing will consist of installing up to 10 product samples in various
       vehicles, and driving them in the area. The base station will be used to
       activate, track, and deactivate the VLU under various conditions.
   (5) The anticipated power output of the devices is very low and thus the
       potential for interference is minimal; however, LoJack also has monitoring
       equipment both at its facilities and in the mobile vehicles to monitor any
       potential interference to other users of the frequency.
   (6) LoJack is willing to be licensed on an intermittent, secondary, non-
       interference causing basis, as needed.

   For the foregoing reasons, LoJack respectfully requests that the OET grant its
application for modification of its permanent experimental authority to continue
the development and testing of next generation VLU devices at its
manufacturing facility before bringing them to market to international users.

    LoJack reiterates that the testing it conducts on the subject frequency is only
for development and testing of technology that is being implemented in the VLU
devices for export to other markets. Additionally, given the minimal transmit
power of the devices and the monitoring equipment that LoJack is employing, no
domestic user of the spectrum will be impacted by the operation of the devices.



Document Created: 2014-03-12 15:52:02
Document Modified: 2014-03-12 15:52:02

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