Re: [digitalradio] Consensus? Is ROS Legal in US?`
I see you have not idea waht is the meaning of Spread spectrum. Spread spectrum reduce energy density. De: John B. Stephensen kd6...@comcast.net Para: digitalradio@yahoogroups.com Enviado: mié,24 febrero, 2010 03:55 Asunto: Re: [digitalradio] Consensus? Is ROS Legal in US?` Convolutional coding and Viterbi decoding may increase the occupied bandwidth but they also decrease the amount of power required to communicate. In some cases, like trellis-coded modulation, the bandwidth stays the same even though the power required decreases by a factor of 2-4. Spread spectrum increases the occupied bandwidth without the decrease in power. 73, John KD6OZH - Original Message - From: W2XJ To: digitalradio@ yahoogroups. com Sent: Wednesday, February 24, 2010 01:24 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` 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. 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 Reply-To: digitalradio@ yahoogroups. com Date: Tue, 23 Feb 2010 19:03:06 -0500 To: 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 Para: 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
Re: [digitalradio] Consensus? Is ROS Legal in US?`
Not true according to Shannon. Using an independent code is a means to an end in the digital domain but is not an absolute as far a the theory goes. This is an example why we need to keep lawyers and government as far away from the hobby as possible. From: KH6TY kh...@comcast.net Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 21:00:49 -0500 To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` The distinguishing characteristic of spread spectrum is spreading by a code INDEPENDENT of the data. FM for example, creates carriers depending upon the audio frequency and amplitude. SSB creates carriers at a frequency dependent upon the tone frequency, and RTTY at a pair of set frequencirs depending upon the shift or the tones used to generate shift. In spread spectrum, as Jose has written, an independent code is used for the spreading, one of the requirements to classify it as spread spectrum. 73 - Skip KH6TY W2XJ wrote: 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 Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:53:53 -0500 To: 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 Jose¹s 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 Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:03:06 -0500 To: 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
Re: [digitalradio] Consensus? Is ROS Legal in US?`
SS reduces the power spectral density but not the total power per bit for a given error rate. 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 10:03 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` I see you have not idea waht is the meaning of Spread spectrum. Spread spectrum reduce energy density. -- De: John B. Stephensen kd6...@comcast.net Para: digitalradio@yahoogroups.com Enviado: mié,24 febrero, 2010 03:55 Asunto: Re: [digitalradio] Consensus? Is ROS Legal in US?` Convolutional coding and Viterbi decoding may increase the occupied bandwidth but they also decrease the amount of power required to communicate. In some cases, like trellis-coded modulation, the bandwidth stays the same even though the power required decreases by a factor of 2-4. Spread spectrum increases the occupied bandwidth without the decrease in power. 73, John KD6OZH - Original Message - From: W2XJ To: digitalradio@ yahoogroups. com Sent: Wednesday, February 24, 2010 01:24 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` 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 Reply-To: digitalradio@ yahoogroups. com Date: Tue, 23 Feb 2010 19:53:53 -0500 To: 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 Reply-To: digitalradio@ yahoogroups. com Date: Tue, 23 Feb 2010 19:03:06 -0500 To: 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
Re: [digitalradio] Consensus? Is ROS Legal in US?`
Asking a lawyer is the last person you would ask for technical advice. Try asking an engineer not a lawyer. Bob, AA8X - Original Message - From: Rik van Riel To: digitalradio@yahoogroups.com Sent: Tuesday, February 23, 2010 4:38 PM Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` On 02/23/2010 03:26 PM, ocypret wrote: So what's the consensus, is ROS legal in the US or not? There's a few things we all agree on: 1) The legality of a mode depends on the technical details of that mode, not on what the author calls the mode. 2) The FCC's lawyers are the definite authority. K3UK has sent a letter to the FCC to ask for clarification. Once the FCC responds, we'll know for sure :) -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
A lawyer with an engineering degree would be the best person to interpret FCC regulations. The ARRL has engineers and lawyers and deals with the FCC so they are the best source of free advice in the U.S. 73, John KD6OZH - Original Message - From: Bob John To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 19:17 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` Asking a lawyer is the last person you would ask for technical advice. Try asking an engineer not a lawyer. Bob, AA8X - Original Message - From: Rik van Riel To: digitalradio@yahoogroups.com Sent: Tuesday, February 23, 2010 4:38 PM Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` On 02/23/2010 03:26 PM, ocypret wrote: So what's the consensus, is ROS legal in the US or not? There's a few things we all agree on: 1) The legality of a mode depends on the technical details of that mode, not on what the author calls the mode. 2) The FCC's lawyers are the definite authority. K3UK has sent a letter to the FCC to ask for clarification. Once the FCC responds, we'll know for sure :) -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
On 02/23/2010 03:26 PM, ocypret wrote: So what's the consensus, is ROS legal in the US or not? There's a few things we all agree on: 1) The legality of a mode depends on the technical details of that mode, not on what the author calls the mode. 2) The FCC's lawyers are the definite authority. K3UK has sent a letter to the FCC to ask for clarification. Once the FCC responds, we'll know for sure :) -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
And the creator of the mode, in this case myselft, is who has to explain the technical details. ROS is not a SS modulation definitively, is a FSK of 144 tones. I have to explain better in a technical informer De: Rik van Riel r...@surriel.com Para: digitalradio@yahoogroups.com Enviado: mar,23 febrero, 2010 23:38 Asunto: Re: [digitalradio] Consensus? Is ROS Legal in US?` On 02/23/2010 03:26 PM, ocypret wrote: So what's the consensus, is ROS legal in the US or not? There's a few things we all agree on: 1) The legality of a mode depends on the technical details of that mode, not on what the author calls the mode. 2) The FCC's lawyers are the definite authority. K3UK has sent a letter to the FCC to ask for clarification. Once the FCC responds, we'll know for sure :) -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
Is legal because ROS is a FSK modulation. De: ocypret 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?
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 *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?
Re: [digitalradio] Consensus? Is ROS Legal in US?`
Commercial and military SS systems also use FSK so that not likely alleviate the problem. The pseudorandom movement of the center frequency is the issue. Since the object is to prevent intersymbol interference due to multipath spread, one way around the legal issue is to transmit even symbols on one set of frequencies and odd symbols on another set of frequencies. 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@yahoogroups.com Sent: Tuesday, February 23, 2010 23:00 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` Is legal because ROS is a FSK modulation. -- De: ocypret 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?
Re: [digitalradio] Consensus? Is ROS Legal in US?`
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 Para: 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 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?
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 *Para:* 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 *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?
Re: [digitalradio] Consensus? Is ROS Legal in US?`
Jose If I am to understand you correctly, the coding algorithms are being held privately. If that is the case, I will have to switch sides and question the legality of it¹s use not only in the US but in many other parts of the world as well. There is a general prohibition of the use of encryption that is not publically accessible. From: jose alberto nieto ros nietoro...@yahoo.es Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 23:39:04 + (GMT) To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` 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 Para: 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 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?
Re: [digitalradio] Consensus? Is ROS Legal in US?`
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 Jose¹s 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 Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:03:06 -0500 To: 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 Para: 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 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?
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
Re: [digitalradio] Consensus? Is ROS Legal in US?`
The FCC only requires that a technical description be published: Sec. 97.309 RTTY and data emission codes. (a) Where authorized by Sec. Sec. 97.305(c) and 97.307(f) of the part, an amateur station may transmit a RTTY or data emission using the following specified digital codes: (1) The 5-unit, start-stop, International Telegraph Alphabet No. 2, code defined in ITU-T Recommendation F.1, Division C (commonly known as ``Baudot''). (2) The 7-unit code specified in ITU-R Recommendations M.476-5 and M.625-3 (commonly known as ``AMTOR''). (3) The 7-unit, International Alphabet No. 5, code defined in IT--T Recommendation T.50 (commonly known as ``ASCII''). (4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, such as CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications. (b) Where authorized by Sec. Sec. 97.305(c) and 97.307(f) of this part, a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a District Director to assure compliance with the FCC Rules, a station must: (1) Cease the transmission using the unspecified digital code; (2) Restrict transmissions of any digital code to the extent instructed; (3) Maintain a record, convertible to the original information, of all digital communications transmitted. [54 FR 25857, June 20, 1989, as amended at 54 FR 39537, Sept. 27, 1989; 56 FR 56172, Nov. 1, 1991; 60 FR 55486, Nov. 1, 1995; 71 FR 25982, May 3, 2006; 71 FR 66465, Nov. 15, 2006] 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@yahoogroups.com Sent: Tuesday, February 23, 2010 23:39 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` 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 Para: 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 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?
Re: [digitalradio] Consensus? Is ROS Legal in US?`
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 Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:53:53 -0500 To: 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 Jose¹s 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 Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:03:06 -0500 To: 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
Re: [digitalradio] Consensus? Is ROS Legal in US?`
The distinguishing characteristic of spread spectrum is spreading by a code INDEPENDENT of the data. FM for example, creates carriers depending upon the audio frequency and amplitude. SSB creates carriers at a frequency dependent upon the tone frequency, and RTTY at a pair of set frequencirs depending upon the shift or the tones used to generate shift. In spread spectrum, as Jose has written, an independent code is used for the spreading, one of the requirements to classify it as spread spectrum. 73 - Skip KH6TY W2XJ wrote: 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
Re: [digitalradio] Consensus? Is ROS Legal in US?`
On 02/23/2010 09:00 PM, KH6TY wrote: The distinguishing characteristic of spread spectrum is spreading by a code INDEPENDENT of the data. FM for example, creates carriers depending upon the audio frequency and amplitude. SSB creates carriers at a frequency dependent upon the tone frequency, and RTTY at a pair of set frequencirs depending upon the shift or the tones used to generate shift. In spread spectrum, as Jose has written, an independent code is used for the spreading, one of the requirements to classify it as spread spectrum. One of the requirements - not the single determining characteristic by any means. From a quick look through the fldigi source code, MFSK and Olivia appear to use a pseudo-random code as well, to provide robustness against narrow band interference. From several places in src/include/jalocha/pj_mfsk.h static const uint64_t ScramblingCode = 0xE257E6D0291574ECLL; -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
Convolutional coding and Viterbi decoding may increase the occupied bandwidth but they also decrease the amount of power required to communicate. In some cases, like trellis-coded modulation, the bandwidth stays the same even though the power required decreases by a factor of 2-4. Spread spectrum increases the occupied bandwidth without the decrease in power. 73, John KD6OZH - Original Message - From: W2XJ To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 01:24 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` 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 Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:53:53 -0500 To: 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 Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:03:06 -0500 To: 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
Re: [digitalradio] Consensus? Is ROS Legal in US?`
It is a NECESSARY AND SUFFICIENT requirement (out of three). The point is that if that is not the way the spreading is done in ROS, ROS is NOT spread spectrum. PROVE, not just claim, that it is not, and the battle is won. 73 - Skip KH6TY Rik van Riel wrote: On 02/23/2010 09:00 PM, KH6TY wrote: The distinguishing characteristic of spread spectrum is spreading by a code INDEPENDENT of the data. FM for example, creates carriers depending upon the audio frequency and amplitude. SSB creates carriers at a frequency dependent upon the tone frequency, and RTTY at a pair of set frequencirs depending upon the shift or the tones used to generate shift. In spread spectrum, as Jose has written, an independent code is used for the spreading, one of the requirements to classify it as spread spectrum. One of the requirements - not the single determining characteristic by any means. From a quick look through the fldigi source code, MFSK and Olivia appear to use a pseudo-random code as well, to provide robustness against narrow band interference. From several places in src/include/jalocha/pj_mfsk.h static const uint64_t ScramblingCode = 0xE257E6D0291574ECLL; -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
These modes use interleaving and randomize data values by exclusive-ORing with a pseudorandom binary sequence. The methods are used in most commerial products and the FCC and NSA know how to monitor the signals. The FCCs problem is that the military uses FHSS and DSSS to hide the existance and content of their transmissions thus preventing the monitoring that the FCC is required to do of amateur signals. It took AMRAD a long time to get authorization for SS above 222 MHz. They first had to get experimental licenses for test transmissions and satisfy the FCC that they could monitor the signals. 73, John KD6OZH - Original Message - From: Rik van Riel To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 02:32 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` On 02/23/2010 09:00 PM, KH6TY wrote: The distinguishing characteristic of spread spectrum is spreading by a code INDEPENDENT of the data. FM for example, creates carriers depending upon the audio frequency and amplitude. SSB creates carriers at a frequency dependent upon the tone frequency, and RTTY at a pair of set frequencirs depending upon the shift or the tones used to generate shift. In spread spectrum, as Jose has written, an independent code is used for the spreading, one of the requirements to classify it as spread spectrum. One of the requirements - not the single determining characteristic by any means. From a quick look through the fldigi source code, MFSK and Olivia appear to use a pseudo-random code as well, to provide robustness against narrow band interference. From several places in src/include/jalocha/pj_mfsk.h static const uint64_t ScramblingCode = 0xE257E6D0291574ECLL; -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
On 02/23/2010 10:22 PM, John B. Stephensen wrote: These modes use interleaving and randomize data values by exclusive-ORing with a pseudorandom binary sequence. The methods are used in most commerial products and the FCC and NSA know how to monitor the signals. However, this does result in carrier placement also being somewhat randomized. Maybe not in exactly the same way as true spread spectrum, since the carrier position is still somewhat dependent on the data content. On the other hand, from the ROS documentation it appears that the carrier location in ROS is also still dependent on data content (as well as a pseudo-random sequence). Carrier location it ROS is, as far as I can tell (Jose will know for sure), dependent on both the data being transmitted and the pseudo-random sequence being used. The FCCs problem is that the military uses FHSS and DSSS to hide the existance and content of their transmissions thus preventing the monitoring that the FCC is required to do of amateur signals. That could be a problem with ROS, as long as the protocol specification is unknown. However, once the protocol has been finalized and the specification made public, monitoring ROS communications will be easy. -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
The problem is that he said that ROS uses FHSS in the documentation. If the final version doesn't use FHSS, DSSS or any other form of SS and a technical specification is published the FCC will have no objection. 73, John KD6OZH - Original Message - From: Rik van Riel To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 03:37 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` On 02/23/2010 10:22 PM, John B. Stephensen wrote: These modes use interleaving and randomize data values by exclusive-ORing with a pseudorandom binary sequence. The methods are used in most commerial products and the FCC and NSA know how to monitor the signals. However, this does result in carrier placement also being somewhat randomized. Maybe not in exactly the same way as true spread spectrum, since the carrier position is still somewhat dependent on the data content. On the other hand, from the ROS documentation it appears that the carrier location in ROS is also still dependent on data content (as well as a pseudo-random sequence). Carrier location it ROS is, as far as I can tell (Jose will know for sure), dependent on both the data being transmitted and the pseudo-random sequence being used. The FCCs problem is that the military uses FHSS and DSSS to hide the existance and content of their transmissions thus preventing the monitoring that the FCC is required to do of amateur signals. That could be a problem with ROS, as long as the protocol specification is unknown. However, once the protocol has been finalized and the specification made public, monitoring ROS communications will be easy. -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
On 02/23/2010 10:50 PM, John B. Stephensen wrote: The problem is that he said that ROS uses FHSS in the documentation. If the final version doesn't use FHSS, DSSS or any other form of SS and a technical specification is published the FCC will have no objection. Oh, agreed. For the moment I will not be using ROS because (1) I am not sure whether or not it is SS, (2) I cannot run ROS on my computer (don't have Windows) and (3) the protocol specification is not available. I expect that once the protocol specification is available, and it is clear that ROS is not spread spectrum, I will start using it once there is a free implementation in eg. fldigi. -- All rights reversed.