I have a different take on this. There are a number of modes that uses
vertebrae coding which could be mis-described as spread spectrum by
some. The problem with part 97 is that it tries to be as broad as
possible where technical parameters are concerned. In this case it
causes things to be vague. There are many things that can be
described as spread spectrum that are not by definition in part 97. FM
would be one of them. Anytime information is transmitted in a wider
bandwidth than necessary it could be described as spread spectrum.
This would include some low noise modes. The problem is that we
petitioned the FCC to loosen SS rules and the more vague those rules
are made the more open to debate they are.
The worst that can happen under the rules if one would be operating
ROS in the phone segment would be an order to cease such operation if
the comish so ordered.
------------------------------------------------------------------------
*From: *KH6TY <kh...@comcast.net <kh...@comcast.net>>
*Reply-To: *<digitalradio@yahoogroups.com <digitalradio@yahoogroups.com>>
*Date: *Tue, 23 Feb 2010 19:53:53 -0500
*To: *<digitalradio@yahoogroups.com <digitalradio@yahoogroups.com>>
*Subject: *Re: [digitalradio] Consensus? Is ROS Legal in US?`
I am for whatever will succeed, but do not underestimate how difficult
it is to convincingly reverse oneself after first originally being so
convincing.
For myself, even from the beginning, I could not understand how the
spreading was accomplished by a code that everyone else automatically
had, but that was the claim, so I accepted it. Perhaps there is no
spreading code independent of the data, but if so, it must now be
proven thus, and not just claimed in what might be seen as an attempt
to have something approved that has already been disapproved.
Just because I might possess the necessary technical skills does not
mean I can individually overrule the FCC with my actions. Even
opposing technical experts are called by both parties in a legal
argument, and the "judge" to decide who is correct in this case is the
FCC, which has already issued an opinion, even if it may be wrong if
given new information, but just "saying it is so does not make it so".
I believe some concrete proof is required now, and maybe your spectrum
analyzer display can be part of such proof.
Other's opinions may vary...
73 - Skip KH6TY
W2XJ wrote:
Skip
You are over thinking this. The FCC said as they always do that
you as a licensee must possess the technical skill to evaluate
whether or not a particular mode meets the rules. On Jose's part a
better technical description and some clarification would be very
helpful to this end. I think just looking at the output on a
spectrum analyzer would also be quite revealing.
------------------------------------------------------------------------
*From: *KH6TY <kh...@comcast.net <kh...@comcast.net>>
*Reply-To: *<digitalradio@yahoogroups.com
<digitalradio@yahoogroups.com>>
*Date: *Tue, 23 Feb 2010 19:03:06 -0500
*To: *<digitalradio@yahoogroups.com <digitalradio@yahoogroups.com>>
*Subject: *Re: [digitalradio] Consensus? Is ROS Legal in US?`
Jose,
I am only trying to suggest whatever ideas I can to get ROS
declared to be legal. You have made such a strong case for FHSS
already, that only "saying" you were mistaken probably will not
convince the FCC. They will assume you are only changing the
description so ROS appears to be legal and will demand proof that
it is not FHSS to change their minds. This is only my personal,
unbiased, opinion, as I would like very much for you to succeed.
Essentially, you must PROVE that, spreading is NOT accomplished by
means of a spreading signal, often called a code signal, which is
independent of the data. How do you do that without disclosing the
code? At this point, I doubt that the FCC will believe mere words,
because there is so much pressure to allow ROS in HF in this country.
Keep in mind the mess that Toyota finds itself by previously
denying there is any substantial problem with unattended
acceleration or braking of their cars. That may still prove to be
true (i.e. not "substantial"), but the government here is now
demanding that Toyota SHOW proof that there is no problem, and not
merely saying there is not. This is currently a very hot topic
with the government and Congress and on the minds of everyone. So
I assume likewise that PROOF will have to be SHOWN that there is
no spreading signal used in ROS. Mere words will probably not be
enough, and there is probably only ONE chance to succeed, so you
need to be successful the first time. If you decide to only change
the description and nothing further, I sincerely hope I am wrong,
and I could well be. But, that is your decision, not mine.
If you need to protect your invention, then just fully document
and witness it, or do whatever is necessary in your country and
others, and be free to do whatever is required to win this battle.
Good luck!
73 - Skip KH6TY
jose alberto nieto ros wrote:
Hi, KH6.
I only i am going to describe in a technicals article how run
the mode. If FCC want the code they will have to buy it me,
that is obvious.
------------------------------------------------------------------------
*De:* KH6TY <kh...@comcast.net <kh...@comcast.net>>
*Para:* digitalradio@yahoogroups.com
<digitalradio@yahoogroups.com>
*Enviado:* mié,24 febrero, 2010 00:31
*Asunto:* Re: [digitalradio] Consensus? Is ROS Legal in US?`
Jose,
"
You will have to disclose the algorithm that determines the
spreading on ROS (independent of the data), or bandwidth
expansion, if that is actually used. You will have to convince
technical people that will show your new description to our
FCC that your original description was wrong and prove it by
revealing your code. I think this is the only way to get the
FCC opinion reversed. You now have a difficult task before
you, but I wish you success, as ROS is a really fun mode.
73 - Skip KH6TY
jose alberto nieto ros wrote:
Is legal because ROS is a FSK modulation.
------------------------------------------------------------------------
*De:* ocypret <n5...@arrl.net> <mailto:n5...@arrl.net
<mailto:n5...@arrl.net>>
*Para:* digitalradio@ yahoogroups. com
*Enviado:* mar,23 febrero, 2010 21:26
*Asunto:* [digitalradio] Consensus? Is ROS Legal in US?`
So what's the consensus, is ROS legal in the US or not?
