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Thread: No need to re-certify for Firmware updates. Interoperable Devices

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  1. #1
    hartleib1 is offline
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    No need to re-certify for Firmware updates. Interoperable Devices

    2.1 FCC SDR Rules
    On March 11, 2005, the FCC released a set of rules outlining an alternative method for certification of devices whose radio frequency and power characteristics can be modified by software (such devices are designated Software Defined Radio devices).1 The rules allow manufacturers who have certified under the new process to update the software on the devices without re-certifying the devices with the FCC.

    The rules require any manufacturer certifying a device under the new process to take steps to prevent “unauthorized” changes to the software on the device that might alter its radio frequency and power parameters in a way that takes it out of compliance with the regulations known as FCC Part 15 regulations.2 The specific technology implemented to accomplish this task is left to the manufacturers seeking certification, although the FCC suggests several possible mechanisms that can serve as such “security measures.”3

    In response to a petition from Cisco Systems, Inc., the FCC issued a Memorandum Opinion and Order on April 25, 2007, making two clarifications to the rules.4 First, the FCC clarified the scope of the rules to require certification under the new process of any device that uses software to comply with the Part 15 regulations if such software is “designed or expected to be modified by a party other than the manufacturer.”5 Second, the FCC stated a position regarding the use of Free and Open Source Software (FOSS) on SDR devices. The FCC acknowledged the use of FOSS by device manufacturers and noted some of the advantages of FOSS for the industry. However, citing concerns regarding publishing information relating to security measures, the FCC stated that a SDR device which uses FOSS to build the “security measures” protecting the software against modification would face a “high burden” during the certification process “to demonstrate that it is sufficiently secure

  2. #2
    hartleib1 is offline
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    Brandon I agree with your view on the ford updates. Demo for Tate!

  3. #3
    voogru is offline
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    If both companies are merging and are going to make new radios that are capable of receiving both streams, isn't the interoperability issue a moot point?

    All your doing is making yourself look like an ass or NAB henchmen.

  4. #4
    zcurzan is offline
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    I guess going forward, it wouldn't be an issue to a shareholder at this point. However, Hartleib's argument (correct me if I'm wrong) is that back in the day, the failure of Sirius to disclose and release the alleged interoperability feature of some radios would have changed the dynamics of the industry. He feels that Sirius would have been able to put XMSR out of business simply by acquiring their listener base.

    But I think as people have pointed out, an interoperable Sirius receiver is already a Sirius customer. All it would have done is allow a Sirius customer to defect to XMSR. Only through interoperable XMSR receivers would this argument hold any water.

    Furthermore, Sirius is purchasing the spectrum, OEM deals, etc. not only the XM subscriber base. So in essence it is what you claim: "a spectrum grab". However, I don't see how the two issues are inter-related. I don't see how releasing an interoperable receiver would have benefitted the Sirius business model, and your shareholder value, more-so than attempting to consolidate the industry. Convince me.

  5. #5
    hartleib1 is offline
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    Why then did Sirius not cry foul, and force the FCC to take action against Xm . Also why would Sirius allow Xm to violate the term of their settlement stipulation and joint development agreement?

  6. #6
    zcurzan is offline
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    If the agreement was to develop and bring an interoperable radio to market, wouldn't just the one on Sirius's side satisfy the requirement? Or was there language in the agreement to force each of the companies to produce a radio that was interoperable?

    And just so we're clear your belief is that Sirius developed this technology into their radios? But XMSR never did it with any of their radios?

    I guess what you are arguing is that it was the fiduciary responsibility of management to pursue whether XMSR was also developing a interoperable device on their end? In that case, they have no reason to cry foul if neither of the radios was made public. It's not like by not acting they were somehow harming Sirius by not enforcing the ability of XMSR subscribers to jump ship. The alleged ability for Sirus radio owners to jump to XMSR was never made public to them either. It's a zero sum game, sure they can't take XMSR's subscribers, but XM can't take theirs either. No advantage to either company.
    Last edited by zcurzan; 07-25-2008 at 02:37 PM.

  7. #7
    homer985 is offline
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    Quote Originally Posted by hartleib1 View Post
    Why then did Sirius not cry foul, and force the FCC to take action against Xm . Also why would Sirius allow Xm to violate the term of their settlement stipulation and joint development agreement?
    Because none of it is true. None of us have dual-capable receivers.

    Good luck proving otherwise Hartleib.

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