Request for Renewal of Authority

0283-EX-RR-2013 Text Documents

LoJack Corporation

2013-08-06ELS_140030

FCC Form 405 Page 1

APPLICATION FOR RENEWAL OF EXPERIMETNAL AUTHORITY
(CALL SIGN WD2XYL)

LoJack Corporation (“LoJack”) herein submits an application for renewal
of its existing experimental authority (Call Sign WD2XYL) in order to continue
development and testing of the next generation Vehicle Location Unit (“VLU”),
the radio device 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 an advanced VLU that will be used in
foreign markets, and requests renewal of its experimental authority for ongoing
development and testing of the device at its engineering facilities in the United
States.

Under its experimental authority, LoJack has been developing and testing
a new generation of VLU, specifically intended for manufacture and export to
foreign customers for use in LoJack systems abroad. To that end, LoJack sought
and was granted Special Temporary Authority (“STA”) by the Office of
Engineering and Technology (“OET”) on May 26, 2005, to begin product
development of that VLU and, subsequently, permanent experimental
authorization on August 27, 2007. 1

LoJack has continued to have good success with the development of its
VLU and is committing additional resources to develop and manufacture a
subsequent generation of the device for export to foreign customers.
Accordingly, LoJack herein seeks extension of its permanent authority for an
additional twenty-four (24) months in order to continue its ongoing development
program. The details of the program remain essentially the same as outlined in
LoJack’s initial application for permanent authority:

(1) As stated above, LoJack has planned a program of product development
and testing of next generation Vehicle Location Unit for international
licensees working in a narrowband environment.
(2) LoJack is seeking authority for the use of the 164.175 MHz frequency. The
requested frequency is a center frequency in the band that most of the rest
of the world has carved out for Stolen Vehicle Recovery System (“SVRS”),
and LoJack requires use of the frequency for testing its devices in that
band. LoJack has no intention of migrating to the use of this frequency for
use in any active SVRS in the United States.
(3) The purpose of the temporary license is to test the product in and around
the LoJack Engineering facility in Canton, MA. In order to expedite the

1Special Temporary Authority issued under File No. 0224-EX-ST-2005; renewed by 0663-EX-ST-
2005. Permanent authority issued under File No. 0176-EX-PL-2006.

FCC Form 405 Page 2

product development process and realize the gains afforded by the new
functionality of the VLU, LoJack has need to conduct this product testing
for its international licensees in the USA, where the engineering facilities
are located.
(4) The testing consists of installing up to 10 product samples in various
vehicles, and driving them in the area. A base station is used to activate,
track, and deactivate the VLU under various conditions.
(5) The operational 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 renewal of its permanent experimental authority to continue the
development and testing of its next generation VLU device before bringing it to
market to international users. LoJack reiterates that the testing it intends to
conduct on the subject frequency is only for development and testing of
technology that will be implemented in the VLU for export. 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: 2013-08-06 14:04:25
Document Modified: 2013-08-06 14:04:25

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