CTIA Letter (July 13, 2009)

0202-EX-PL-2009 Text Documents

Tecore Inc.

2009-07-21ELS_99976

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 The WireleM Aaaosiaion"                                                   Expsndnrg the Wreless Front&




                                     July 13.2009


Julius Knapp                                                              RECEIVED - FCC
Chief, Office of Engineering and Technology
Federal Communications Commission                                              JUL 13 2009
445 12th Street, SW                                                     FBdeMCDmmunlcafions C o r n m e
Washington, DC 20554                                                           Rureau 1 Office

RE:     Experimental License Application of Tecore, Inc.
        FCC File Number 0202-EX-PL-2009

Dear Mr. Knapp:

        CTIA - The Wireless Association@ ("CTIA) respectfully submits this letter
in support of the above-referenced experimental license application of Tecore
Networks, Inc. ("Tecore"). CTIA supports the grant of this experimental license - on
a fully coordinated basis with CTIA's affected members - to better develop a record
on the capabilities of alternative technological solutions to the unlawful use of mobile
devices within prisons. The possession and use of wireless devices by inmates in
correctional facilities is a genuine and important issue, and CTIA supports the
development and real-world testing of lawful solutions to stop the unauthorized use of
these devices by inmates. CTIA submits that the testing of Tecore's proposed
solution will enable interested stakeholders, including state and federal corrections
agencies, other interested administrative agencies, the Public Safety community, and
wireless carriers, to gather important data on the ability of non-jamming technologies
to mitigate and resolve the illicit use of wireless phones within prisons.

        CTIA recently hosted a day-long discussion among its members and several
companies that have developed potential technologies for lawfully addressing the use
of mobile devices within correctional facilities. Tecore was one of the presenters and
indicated that its proposed solution would allow for the denial of access to the
wireless network within a prison without the use of any jamming technology. To
enable this capability, Tecore would deploy base station technology that would
transmit a "preferred signal covering the grounds of the prison and thereby locking
any unauthorized communications traffic to its network's control. Tecore's
demonstration of this capability, however, requires operating authority to transmit in
the cellular (824-849/869-894 MHz) and Personal Communications Service ("PCS")
(1850-191011930-1990 MHz) bands, which Tecore seeks in its experimental license
request.

        CTIA believes there is merit to Tecore's technological proposal and supports
the grant of Tecore's experimental license request. Because Tecore must transmit in
the cellular and PCS frequency bands, CTIA asks that the Federal Communications


Commission ("Commission") condition the experimental grant with a requirement to
coordinate all operations with CTIA's affected members that hold cellular and PCS
licenses in the market area of the test. CTIA has discussed this effort with its
members and there is agreement that such coordination is feasible and that the
underlying experimental testing would be desirable.

         CTIA expects that the proposed tests can gather significant data to help
determine whether Tecore's technology could effectively manage cell phone usage in
the prison environment. This exercise will help the Commission, the Maryland
Department of Public Safety and Corrections, and other affected parties gauge the
effectiveness of this solution. CTIA believes that these cooperative efforts will assist
in the development of well-considered solutions and aid in the creation of a full
record of the capabilities of lawful technologies that can aid corrections officials'
efforts in combating cell phone usage within prisons.

       Thank you for your prompt attention to this matter. Please do not hesitate to
contact me or Brian Josef (202-736-3253, or biosef@ctia.org)with any questions.

                                             Sincerely,



                                             Christopher Gutunan-McCabe
                                             Vice President, Regulatory Affairs


cc:    Jim Schlichting
       Ira Keltz
       James Burtle
       David Hu
       Charles Mathias



Document Created: 2009-07-21 10:38:45
Document Modified: 2009-07-21 10:38:45

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