RE: FCC + FCC = FCC? - Outlaw

2001-06-27 Thread Gary McInturff

Actually went through this with a commercial product in about 1984. I
received a letter (or call) from the FEDS that the police couldn't transmit
or receive when they were going past a bank and they were blaming our
equipment, turns out they were right. Jumped on a plane, found the problem
and fixed it. (Some of the equipment had to be turned off to find the signal
so no wonder I missed it during test) Wrote back to the FEDS, they called
the cops who confirmed the problem was cured and I never heard from the FEDS
again.
I suspect it would have been different if I hadn't responded
quickly.
Gary
While I had all of the equipment in the field updated - I was never
asked nor did I tell the FEDS that we fixed all occurrences of the
equipment.

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Monday, June 25, 2001 10:26 AM
To: Chris Maxwell; chris maxwell; 'emc-pstc internet forum'
Subject: Re: FCC + FCC = FCC? - Outlaw



Someone else on this thread quoted chapter and verse from Title 47 of the US
code stating that individuals who built their own ITE were not covered by
Part 15 rules.  Regardless of that, I find it hard to imagine the FCC going
after any individual other than to make him fix an interference or shut off
an interference source.  This comment specifically aimed at incidental
transmissions.  it does not apply to the case of an individual intentionally
transmitting rf energy at levels greater than allowed by law.

--
>From: Chris Maxwell 
>To: "'Ken Javor'" , Chris Maxwell
, "'EMC-PSTC Internet Forum'"

>Subject: RE: FCC + FCC = FCC? - Outlaw
>Date: Mon, Jun 25, 2001, 8:00 AM
>

>
> Ah,
>
> I see what you're saying.
>
> Point 7 was intended to say that a test should be performed if there was
any
> doubt of a safety problem.
>
> I never intended to say that someone should market a product if they know
> that it will interfere with people's reception of radio or TV.  Even "I
Love
> Lucy" re-runs.
>
> I'll restate with a more clear example.  Someone could buy a system with
an
> FCC Class B computer, an FCC class B printer, an FCC class B keyboard and
an
> FCC class B mouse only to find out that, by some freak of physics (a
> resonance condition ...) this system is now radiating at levels higher
than
> class B and it is fouling up a neighbor's TV reception.
>
> In this case, the person would be required to fix the emissions, after the
> fact.  I think we can all agree on this.
>
> The finer point of what I'm saying is:  If this person was ever brought to
> the attention of the FCC, there would probably be no punitive action
against
> him/her (other than correcting the emissions) because this person should
be
> able to connect FCC approved equipment together, without performing a
system
> level EMI test, with a reasonable assumption of conformity.
>
> But, if the person assembling this system had any knowledge beforehand
that
> the emissions could cause a personal or public safety problem;  I don't
> think the FCC would be so nice.
>
> It would have been more clear if I had never mentioned "Lucy" at all.
>
> Chris
>
>
>> -Original Message-
>> From: Ken Javor [SMTP:ken.ja...@emccompliance.com]
>> Sent: Friday, June 22, 2001 6:08 PM
>> To: Chris Maxwell; 'EMC-PSTC Internet Forum'
>> Subject: Re: FCC + FCC = FCC? - Outlaw
>>
>> I have no trouble with your checklist except #7.  Like it or not, the FCC
>> RE
>> limits protect "I Love Lucy" broadcasts.  More basically, the limits
>> protect
>> the broadcasters' market.  If excess RE from consumer appliances
interfere
>> with reception in fringe areas, the broadcaster's customer base is
>> reduced,
>> which in turn reduces the value of advertising time that he can charge.
>> You
>> are literally putting him out of business, and he has a license to
>> transmit
>> and your appliance does not.
>>
>> --
>> >From: Chris Maxwell 
>> >To: "'EMC-PSTC Internet Forum'" 
>> >Subject: FW: FCC + FCC = FCC? - Outlaw
>> >Date: Fri, Jun 22, 2001, 2:59 PM
>> >
>>
>> >
>> >> Hi Ken,
>> >>
>> >> Come on guys, these flames are burning me :-)
>> >>
>> >> I'm just advocating sound engineering judgement.  I understand that a
>> user
>> >> would have to take "adequate measures" if his/her appliance was
messing
>> up
>> >> the neighbor's "I Love Lucy" reception.   I understand that those
>> >> "adequa

Re: FCC + FCC = FCC? - Outlaw

2001-06-25 Thread Ken Javor

Someone else on this thread quoted chapter and verse from Title 47 of the US
code stating that individuals who built their own ITE were not covered by
Part 15 rules.  Regardless of that, I find it hard to imagine the FCC going
after any individual other than to make him fix an interference or shut off
an interference source.  This comment specifically aimed at incidental
transmissions.  it does not apply to the case of an individual intentionally
transmitting rf energy at levels greater than allowed by law.

--
>From: Chris Maxwell 
>To: "'Ken Javor'" , Chris Maxwell
, "'EMC-PSTC Internet Forum'"

>Subject: RE: FCC + FCC = FCC? - Outlaw
>Date: Mon, Jun 25, 2001, 8:00 AM
>

>
> Ah,
>
> I see what you're saying.
>
> Point 7 was intended to say that a test should be performed if there was any
> doubt of a safety problem.
>
> I never intended to say that someone should market a product if they know
> that it will interfere with people's reception of radio or TV.  Even "I Love
> Lucy" re-runs.
>
> I'll restate with a more clear example.  Someone could buy a system with an
> FCC Class B computer, an FCC class B printer, an FCC class B keyboard and an
> FCC class B mouse only to find out that, by some freak of physics (a
> resonance condition ...) this system is now radiating at levels higher than
> class B and it is fouling up a neighbor's TV reception.
>
> In this case, the person would be required to fix the emissions, after the
> fact.  I think we can all agree on this.
>
> The finer point of what I'm saying is:  If this person was ever brought to
> the attention of the FCC, there would probably be no punitive action against
> him/her (other than correcting the emissions) because this person should be
> able to connect FCC approved equipment together, without performing a system
> level EMI test, with a reasonable assumption of conformity.
>
> But, if the person assembling this system had any knowledge beforehand that
> the emissions could cause a personal or public safety problem;  I don't
> think the FCC would be so nice.
>
> It would have been more clear if I had never mentioned "Lucy" at all.
>
> Chris
>
>
>> -Original Message-
>> From: Ken Javor [SMTP:ken.ja...@emccompliance.com]
>> Sent: Friday, June 22, 2001 6:08 PM
>> To: Chris Maxwell; 'EMC-PSTC Internet Forum'
>> Subject: Re: FCC + FCC = FCC? - Outlaw
>>
>> I have no trouble with your checklist except #7.  Like it or not, the FCC
>> RE
>> limits protect "I Love Lucy" broadcasts.  More basically, the limits
>> protect
>> the broadcasters' market.  If excess RE from consumer appliances interfere
>> with reception in fringe areas, the broadcaster's customer base is
>> reduced,
>> which in turn reduces the value of advertising time that he can charge.
>> You
>> are literally putting him out of business, and he has a license to
>> transmit
>> and your appliance does not.
>>
>> --
>> >From: Chris Maxwell 
>> >To: "'EMC-PSTC Internet Forum'" 
>> >Subject: FW: FCC + FCC = FCC? - Outlaw
>> >Date: Fri, Jun 22, 2001, 2:59 PM
>> >
>>
>> >
>> >> Hi Ken,
>> >>
>> >> Come on guys, these flames are burning me :-)
>> >>
>> >> I'm just advocating sound engineering judgement.  I understand that a
>> user
>> >> would have to take "adequate measures" if his/her appliance was messing
>> up
>> >> the neighbor's "I Love Lucy" reception.   I understand that those
>> >> "adequate measures" would include fixing the emissions or turning the
>> unit
>> >> off.
>> >>
>> >> The 120dB safety margin is there.  We can't argue whether it is right
>> or
>> >> wrong.  It's a fact.I agree that it would be wrong for anybody to
>> >> abuse the safety margin and willfully produce a non-compliant product.
>> >> One 911 that gets slammed by a non-compliant product would be too much.
>> >>
>> >> More to the point.
>> >>
>> >> I assume that you have a good enough background in EMC to make a sound
>> >> judgement. (probably more so than I)  What would you do with a product
>> >> that you evaluated using my checklist?  Would you have your company
>> write
>> >> the check for a re-test?
>> >>
>> >> Chris
>> >>
>> >> -Original Message-
>> &g

RE: FCC + FCC = FCC? - Outlaw

2001-06-25 Thread Chris Maxwell

Ah,  

I see what you're saying. 

Point 7 was intended to say that a test should be performed if there was any
doubt of a safety problem.  

I never intended to say that someone should market a product if they know
that it will interfere with people's reception of radio or TV.  Even "I Love
Lucy" re-runs. 

I'll restate with a more clear example.  Someone could buy a system with an
FCC Class B computer, an FCC class B printer, an FCC class B keyboard and an
FCC class B mouse only to find out that, by some freak of physics (a
resonance condition ...) this system is now radiating at levels higher than
class B and it is fouling up a neighbor's TV reception.

In this case, the person would be required to fix the emissions, after the
fact.  I think we can all agree on this.

The finer point of what I'm saying is:  If this person was ever brought to
the attention of the FCC, there would probably be no punitive action against
him/her (other than correcting the emissions) because this person should be
able to connect FCC approved equipment together, without performing a system
level EMI test, with a reasonable assumption of conformity.  

But, if the person assembling this system had any knowledge beforehand that
the emissions could cause a personal or public safety problem;  I don't
think the FCC would be so nice. 

It would have been more clear if I had never mentioned "Lucy" at all.

Chris


> -Original Message-
> From: Ken Javor [SMTP:ken.ja...@emccompliance.com]
> Sent: Friday, June 22, 2001 6:08 PM
> To:   Chris Maxwell; 'EMC-PSTC Internet Forum'
> Subject:  Re: FCC + FCC = FCC? - Outlaw
> 
> I have no trouble with your checklist except #7.  Like it or not, the FCC
> RE
> limits protect "I Love Lucy" broadcasts.  More basically, the limits
> protect
> the broadcasters' market.  If excess RE from consumer appliances interfere
> with reception in fringe areas, the broadcaster's customer base is
> reduced,
> which in turn reduces the value of advertising time that he can charge.
> You
> are literally putting him out of business, and he has a license to
> transmit
> and your appliance does not.
> 
> --
> >From: Chris Maxwell 
> >To: "'EMC-PSTC Internet Forum'" 
> >Subject: FW: FCC + FCC = FCC? - Outlaw
> >Date: Fri, Jun 22, 2001, 2:59 PM
> >
> 
> >
> >> Hi Ken,
> >>
> >> Come on guys, these flames are burning me :-)
> >>
> >> I'm just advocating sound engineering judgement.  I understand that a
> user
> >> would have to take "adequate measures" if his/her appliance was messing
> up
> >> the neighbor's "I Love Lucy" reception.   I understand that those
> >> "adequate measures" would include fixing the emissions or turning the
> unit
> >> off.
> >>
> >> The 120dB safety margin is there.  We can't argue whether it is right
> or
> >> wrong.  It's a fact.I agree that it would be wrong for anybody to
> >> abuse the safety margin and willfully produce a non-compliant product.
> >> One 911 that gets slammed by a non-compliant product would be too much.
> >>
> >> More to the point.
> >>
> >> I assume that you have a good enough background in EMC to make a sound
> >> judgement. (probably more so than I)  What would you do with a product
> >> that you evaluated using my checklist?  Would you have your company
> write
> >> the check for a re-test?
> >>
> >> Chris
> >>
> >> -Original Message-
> >> From: Ken Javor [SMTP:ken.ja...@emccompliance.com]
> >> Sent: Friday, June 22, 2001 3:21 PM
> >> To: Chris Maxwell; 'emc-p...@majordomo.ieee.org'
> >> Subject: Re: FCC + FCC = FCC? - Outlaw
> >>
> >> NO
> >>
> >> The 120 dB safety margin comment and point number 7 are self-consistent
> >> but
> >> consistently WRONG!
> >>
> >> If you screw up "I Love Lucy" reception, regardless of your subjective
> >> assessment of the nuisance value that represents, you are in violation
> of
> >> not only the philosophy of FCC emissions control, but also the verbiage
> >> attached to the FCC sticker that says regardless of measured
> compliance,
> >> if
> >> it causes interference, fix it or turn it off.
> >>
> >> I reiterate, the fact that your product could be out not 30 - 40% but
> 30 -
> >> 40 dB has no safety impact to a non-antenna connected receiver.  But if
> it
> >> interferes with either I Love Lucy, or

Re: FCC + FCC = FCC? - Outlaw

2001-06-22 Thread Ken Javor

I have no trouble with your checklist except #7.  Like it or not, the FCC RE
limits protect "I Love Lucy" broadcasts.  More basically, the limits protect
the broadcasters' market.  If excess RE from consumer appliances interfere
with reception in fringe areas, the broadcaster's customer base is reduced,
which in turn reduces the value of advertising time that he can charge.  You
are literally putting him out of business, and he has a license to transmit
and your appliance does not.

--
>From: Chris Maxwell 
>To: "'EMC-PSTC Internet Forum'" 
>Subject: FW: FCC + FCC = FCC? - Outlaw
>Date: Fri, Jun 22, 2001, 2:59 PM
>

>
>> Hi Ken,
>>
>> Come on guys, these flames are burning me :-)
>>
>> I'm just advocating sound engineering judgement.  I understand that a user
>> would have to take "adequate measures" if his/her appliance was messing up
>> the neighbor's "I Love Lucy" reception.   I understand that those
>> "adequate measures" would include fixing the emissions or turning the unit
>> off.
>>
>> The 120dB safety margin is there.  We can't argue whether it is right or
>> wrong.  It's a fact.I agree that it would be wrong for anybody to
>> abuse the safety margin and willfully produce a non-compliant product.
>> One 911 that gets slammed by a non-compliant product would be too much.
>>
>> More to the point.
>>
>> I assume that you have a good enough background in EMC to make a sound
>> judgement. (probably more so than I)  What would you do with a product
>> that you evaluated using my checklist?  Would you have your company write
>> the check for a re-test?
>>
>> Chris
>>
>> -Original Message-
>> From: Ken Javor [SMTP:ken.ja...@emccompliance.com]
>> Sent: Friday, June 22, 2001 3:21 PM
>> To: Chris Maxwell; 'emc-p...@majordomo.ieee.org'
>> Subject: Re: FCC + FCC = FCC? - Outlaw
>>
>> NO
>>
>> The 120 dB safety margin comment and point number 7 are self-consistent
>> but
>> consistently WRONG!
>>
>> If you screw up "I Love Lucy" reception, regardless of your subjective
>> assessment of the nuisance value that represents, you are in violation of
>> not only the philosophy of FCC emissions control, but also the verbiage
>> attached to the FCC sticker that says regardless of measured compliance,
>> if
>> it causes interference, fix it or turn it off.
>>
>> I reiterate, the fact that your product could be out not 30 - 40% but 30 -
>> 40 dB has no safety impact to a non-antenna connected receiver.  But if it
>> interferes with either I Love Lucy, or a cell phone calling in 911, you
>> are
>> violating the spirit and letter of the law.
>>
>>
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
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Re: FCC + FCC = FCC? - Outlaw

2001-06-22 Thread John Woodgate

<83d652574e7af740873674f9fc12dbaa675...@utexh1w2.gnnettest.com>, Chris
Maxwell  inimitably wrote:
>Why not call a vertically-
>applied manulo-pedally-operated quasi-planar chernozem-penetrating and 
>excavating implement a SPADE?  
>
>BECAUSE SOMETIMES IT'S A SHOVEL!

All the rest of what you said is true, but a shovel is not quasi-planar:
it has a caustic curve cross-section, like '{'. (;-)
-- 
Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839
Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Why not call a vertically-
applied manulo-pedally-operated quasi-planar chernozem-penetrating and 
excavating implement a SPADE?

---
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Technical Committee emc-pstc discussion list.

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To cancel your subscription, send mail to:
 majord...@ieee.org
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 unsubscribe emc-pstc

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 Michael Garretson:pstc_ad...@garretson.org
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 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.rcic.com/  click on "Virtual Conference Hall,"




Re: FCC + FCC = FCC? - Outlaw

2001-06-22 Thread Ken Javor

NO

The 120 dB safety margin comment and point number 7 are self-consistent but
consistently WRONG!

If you screw up "I Love Lucy" reception, regardless of your subjective
assessment of the nuisance value that represents, you are in violation of
not only the philosophy of FCC emissions control, but also the verbiage
attached to the FCC sticker that says regardless of measured compliance, if
it causes interference, fix it or turn it off.

I reiterate, the fact that your product could be out not 30 - 40% but 30 -
40 dB has no safety impact to a non-antenna connected receiver.  But if it
interferes with either I Love Lucy, or a cell phone calling in 911, you are
violating the spirit and letter of the law.

--
>From: Chris Maxwell 
>To: "'emc-p...@majordomo.ieee.org'" 
>Subject: RE: FCC + FCC = FCC? - Outlaw
>Date: Fri, Jun 22, 2001, 12:15 PM
>

>
> Hi all,
>
> This thread has been interesting.  However it has taken a somewhat
> philisophical turn.  I'd like to "distill" it a little bit.  In short,  FCC
> + FCC does equal FCC in certain circumstances just like CE + CE = CE in
> certain circumstances.
>
> You need to ask yourself: (honestly and sincerley without the influence of
> mind altering substances)
>
> Self,
>
> 1.  Do I manufacture all of the pieces of this system?
> 2.  Are all of the pieces of this system already FCC approved?
> 3.  Is the FCC approval appropriate for my intended environment (i.e needs
> Class B for residential)?
> 4.  Am I satisfying the test assumptions for the pieces that are already FCC
> approved? (i.e am I using shielded cables where required, am I following the
> grounding recommendations?)
> 5.  Am I using the pieces of this system in their intended environments?
> 6.  Do I have design control over the pieces of the system? (i.e did you or
> your company layout the circuitboards, choose the components ...)
> 7.  Will my system be used in situations in which interference could
> comprimise public or personal safety? (as opposed to simply screwing up the
> neighbor's reception of "I Love Lucy".)
> 8.  Have I spent a couple of years in compliance engineering?  Do I feel
> comfortable making these decisions? Have I reviewed the test data?
>
> If you can answer:
> 1. No   (A "yes" hurts only slightly)
> 2. Yes
> 3. Yes
> 4. Yes
> 5. Yes
> 6. No (A "yes" hurts only slightly)
> 7. No  (This one MUST be "No")
> 8. Yes, Yes, Yes
>
> Then you can be 95% certain that FCC+FCC = FCC.
> Only 95%!!  Oh no!
> Hold on, before you write that $5,000 check for EMC testing,  remember that
> most EMC tests themselves have double digit percentage errors.
>
> One warning.  If you are going to make a "Large Number" of IDENTICAL
> systems, and you plan to make "alot" of money off of them; or if you have
> any gut feeling that someone could get hurt; do the test anyway.  It's just
> good sense.
> (I'll let you decide what "Large Number" and "alot" mean :-)
>
> You can use the same reasoning for CE + CE = CE  (from an EMC perspective)
>
> Yes, yes I know that there are some that will say that every system must be
> tested, even if you build it in your basement.  But the reality is that EMC
> measurements are a "fuzzy" realm.  Tests are fuzzy approximations of real
> world conditions.  Some of the tests have error margins of 30-40%.  The
> emissions and immunity standards have a built in 120dB "safety margin" to
> account for this (or you could argue that the "safety margin" was
> accidentally put there because the emissions standards were designed to
> protect antenna coupled receivers).  Either way, it is there.  It doesn't
> mean that we can be cavalier with EMC; but we can use good judgement to save
> time, money and hassles.  The same time and money that can be better spent
> mitigating real EMC and safety problems.  All of these rationales are behind
> why both the EMC directive and the FCC rules give some leeway with the
> Declaration of Conformity process.
>
> With many "fuzzy" logic questions the best piece of test equipment that you
> can use is a trained neural network.  An experienced brain is a prime
> example.
>
> Why not call a vertically-
> applied manulo-pedally-operated quasi-planar chernozem-penetrating and
> excavating implement a SPADE?
>
> BECAUSE SOMETIMES IT'S A SHOVEL
>
> My opinions only.
>
> Chris
>
>
>
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
> Visit our web site at:  http://www.e

RE: FCC + FCC = FCC? - Outlaw

2001-06-22 Thread Chris Maxwell

Hi all,

This thread has been interesting.  However it has taken a somewhat
philisophical turn.  I'd like to "distill" it a little bit.  In short,  FCC
+ FCC does equal FCC in certain circumstances just like CE + CE = CE in
certain circumstances.

You need to ask yourself: (honestly and sincerley without the influence of
mind altering substances)

Self, 

1.  Do I manufacture all of the pieces of this system?
2.  Are all of the pieces of this system already FCC approved?
3.  Is the FCC approval appropriate for my intended environment (i.e needs
Class B for residential)?
4.  Am I satisfying the test assumptions for the pieces that are already FCC
approved? (i.e am I using shielded cables where required, am I following the
grounding recommendations?)
5.  Am I using the pieces of this system in their intended environments?
6.  Do I have design control over the pieces of the system? (i.e did you or
your company layout the circuitboards, choose the components ...)
7.  Will my system be used in situations in which interference could
comprimise public or personal safety? (as opposed to simply screwing up the
neighbor's reception of "I Love Lucy".)
8.  Have I spent a couple of years in compliance engineering?  Do I feel
comfortable making these decisions? Have I reviewed the test data?

If you can answer:   
1. No   (A "yes" hurts only slightly)
2. Yes 
3. Yes 
4. Yes  
5. Yes  
6. No (A "yes" hurts only slightly) 
7. No  (This one MUST be "No")
8. Yes, Yes, Yes

Then you can be 95% certain that FCC+FCC = FCC. 
Only 95%!!  Oh no!  
Hold on, before you write that $5,000 check for EMC testing,  remember that
most EMC tests themselves have double digit percentage errors.

One warning.  If you are going to make a "Large Number" of IDENTICAL
systems, and you plan to make "alot" of money off of them; or if you have
any gut feeling that someone could get hurt; do the test anyway.  It's just
good sense.
(I'll let you decide what "Large Number" and "alot" mean :-)

You can use the same reasoning for CE + CE = CE  (from an EMC perspective)

Yes, yes I know that there are some that will say that every system must be
tested, even if you build it in your basement.  But the reality is that EMC
measurements are a "fuzzy" realm.  Tests are fuzzy approximations of real
world conditions.  Some of the tests have error margins of 30-40%.  The
emissions and immunity standards have a built in 120dB "safety margin" to
account for this (or you could argue that the "safety margin" was
accidentally put there because the emissions standards were designed to
protect antenna coupled receivers).  Either way, it is there.  It doesn't
mean that we can be cavalier with EMC; but we can use good judgement to save
time, money and hassles.  The same time and money that can be better spent
mitigating real EMC and safety problems.  All of these rationales are behind
why both the EMC directive and the FCC rules give some leeway with the
Declaration of Conformity process.

With many "fuzzy" logic questions the best piece of test equipment that you
can use is a trained neural network.  An experienced brain is a prime
example.

Why not call a vertically-
applied manulo-pedally-operated quasi-planar chernozem-penetrating and 
excavating implement a SPADE?  

BECAUSE SOMETIMES IT'S A SHOVEL

My opinions only.  

Chris




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 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.rcic.com/  click on "Virtual Conference Hall,"




RE: FCC + FCC = FCC? - Outlaw

2001-06-22 Thread Gary McInturff

Ed,
Not a problem with my relatives - they never pay for anything!
Gary

-Original Message-
From: Price, Ed [mailto:ed.pr...@cubic.com]
Sent: Thursday, June 21, 2001 3:54 PM
To: 'Doug McKean'; EMC-PSTC Discussion Group
Subject: RE: FCC + FCC = FCC? - Outlaw



I hesitate only a bit in adding my opinion here,  as I'm a known
possessor of amplifiers that exhibit gain at 27 MHz and receivers which can
tune the 900 MHz region.

I think that you can build a device for your own use (as earlier defined),
even up to the official 5 devices, but you get on very infirm ground when
you SELL them (even at cost), even to your relatives.

Regards,

Ed


Ed Price
ed.pr...@cubic.com
Electromagnetic Compatibility Lab
Cubic Defense Systems
San Diego, CA  USA
858-505-2780  (Voice)
858-505-1583  (Fax)
Military & Avionics EMC Services Is Our Specialty
Shake-Bake-Shock - Metrology - Reliability Analysis


>-Original Message-
>From: Doug McKean [mailto:dmck...@corp.auspex.com]
>Sent: Thursday, June 21, 2001 12:11 PM
>To: EMC-PSTC Discussion Group
>Subject: Re: FCC + FCC = FCC? - Outlaw
>
>
>
>Decide among yourselves who of you are outlaws ...
>
>" TITLE 47--TELECOMMUNICATION
>  CHAPTER I--FEDERAL COMMUNICATIONS COMMISSION
>  PART 15--RADIO FREQUENCY DEVICES--Table of Contents
>  Subpart A--General
>  Sec. 15.23  Home-built devices.
>
>  (a) Equipment authorization is not required for devices that are not
>   marketed, are not constructed from a kit, and are built in
>quantities
>   of  five or less for personal use.
>
>  (b) It is recognized that the individual builder of home-built
>   equipment may not possess the means to perform the measurements
>   for determining compliance with the regulations. In this case,
>the
>   builder is expected to employ good engineering practices to
>meet
>   the specified technical standards to the greatest extent
>practicable.
>   The provisions of Sec. 15.5 apply to this equipment.
>..."
>
>- Doug  McKean
>

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RE: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread Price, Ed

I hesitate only a bit in adding my opinion here,  as I'm a known
possessor of amplifiers that exhibit gain at 27 MHz and receivers which can
tune the 900 MHz region.

I think that you can build a device for your own use (as earlier defined),
even up to the official 5 devices, but you get on very infirm ground when
you SELL them (even at cost), even to your relatives.

Regards,

Ed


Ed Price
ed.pr...@cubic.com
Electromagnetic Compatibility Lab
Cubic Defense Systems
San Diego, CA  USA
858-505-2780  (Voice)
858-505-1583  (Fax)
Military & Avionics EMC Services Is Our Specialty
Shake-Bake-Shock - Metrology - Reliability Analysis


>-Original Message-
>From: Doug McKean [mailto:dmck...@corp.auspex.com]
>Sent: Thursday, June 21, 2001 12:11 PM
>To: EMC-PSTC Discussion Group
>Subject: Re: FCC + FCC = FCC? - Outlaw
>
>
>
>Decide among yourselves who of you are outlaws ...
>
>" TITLE 47--TELECOMMUNICATION
>  CHAPTER I--FEDERAL COMMUNICATIONS COMMISSION
>  PART 15--RADIO FREQUENCY DEVICES--Table of Contents
>  Subpart A--General
>  Sec. 15.23  Home-built devices.
>
>  (a) Equipment authorization is not required for devices that are not
>   marketed, are not constructed from a kit, and are built in
>quantities
>   of  five or less for personal use.
>
>  (b) It is recognized that the individual builder of home-built
>   equipment may not possess the means to perform the measurements
>   for determining compliance with the regulations. In this case,
>the
>   builder is expected to employ good engineering practices to
>meet
>   the specified technical standards to the greatest extent
>practicable.
>   The provisions of Sec. 15.5 apply to this equipment.
>..."
>
>- Doug  McKean
>

---
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Re: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread John Woodgate

<20010621143204.UCHV1335.femail1.sdc1.sfba.home.com@[65.11.150.27]>, Ken
Javor  inimitably wrote:
>The limits as placed prevent most but not all
>interference.  For instance, some AM radios are susceptible to conducted
>interference below 48 dBuV.  The limits were placed, both in amplitude and
>frequency, to prevent the large majority of interferences, but not all.
>Whether it was done right or not may be open to debate, but the philosophy
>was to optimize: to get the least amount of interference while imposing the
>minimum design cost impact. 

Correct. The new(ish) CISPR/H committee is to review these radiated
emission limits, some of which are very 'traditional'.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839
Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Why not call a vertically-
applied manulo-pedally-operated quasi-planar chernozem-penetrating and 
excavating implement a SPADE?

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RE: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread Dick Grobner
 


 
I forgot to mention, however we do test four equipment for emissions to FCC
Class B.

-Original Message-
From: Dick Grobner 
Sent: Thursday, June 21, 2001 3:33 PM
To: 'Tania Grant'
Cc: 'emc-p...@majordomo.ieee.org'
Subject: RE: FCC + FCC = FCC? - Outlaw


"Will put Tania" and I agree with your reasoning!
We don't deal with the FCC as we are a medical manufacturer, but we do deal
with the FDA and the Europeans. We are a small medical manufacture compared
to the Big Boys and we must play by the same rules! Size and dollars has
nothing to do with it and shouldn't. 

-Original Message-
From: Tania Grant [mailto:taniagr...@msn.com]
Sent: Thursday, June 21, 2001 11:23 AM
To: Doug McKean; emc-p...@majordomo.ieee.org
Subject: Re: FCC + FCC = FCC? - Outlaw


Hello Doug,
 
I may or may not agree with FCC (on some issues I agree, on others I don't);
however, ignorance of the law is no excuse.
 
The FCC Rules do make the assembler responsible for compliance.  And the FCC
was NOT created to protect big companies from themselves but to allocate
spectrum and watch for abuses.   The air waves were consigned to bona-fide
communication equipment.  The early computers were nothing more than
super-whiz-bang typewriters-cum-adding machines and not considered
communication devices.   Thus, they were not supposed to interfere with
communication equipment;-- e.g., the Rules.
 
The fact that you can assemble your own, and that you are small fry compared
to the big companies, has nothing to do with the fact that your assembled
equipment need not  comply with the Rules.  (I sympathize with small fry,
being one myself.)  If you disagree with the Rules, you have ample
opportunity to write to the FCC and present your case to them;-- they have
to publish your letter and present an argument for or against your position.
And the FCC in the past has relented and conceded many points when presented
with convincing evidence from the industry and from communication companies.
(Witness the recent changes to accept DoC instead of the cumbersome
Certification procedure for Class B devices.)  I believe that this is the
democratic and responsible way of addressing the problem rather than
disregarding the law because it is inconvenient for you, or because your
equipment is just a small pebble in a big pond of boulders and no one will
notice.
 
Tania Grant
taniagr...@msn.com

- Original Message -
From: Doug McKean
Sent: Thursday, June 21, 2001 12:19 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: FCC + FCC = FCC? - Outlaw
 

Sorry but I respectfully disagree ...

If the FCC were to say yes to anyone being an
outlaw for building their own PC and not having
it tested, then why does the FCC label essentially
tell everyone suffering from interefernce to take
care of it themselves?

The FCC was created to protect the big alphabet
communication companies from themselves. Me building
my own PC is peanuts compared to some of the issues
these guys deal with.  And cable tv is starting to
make the issue of interfering with commercial
broadcast a moot point.  Heck, I don't even see
the pixels blink at all anymore even with the
microwave being used only 10 feet away.

I was told, not sure how true it is, that the
FCC in the early years of Part 15 took to task
a famous computer company selling computers
which hooked up to your tv screen.  They were
famous for intereference.  I know, I had one.
So the FCC threatened to confiscate the units
from said company.  Well, the sales were going
down and the company said, "sure big brother,
to ahead ..."  So the FCC took them.  Lots of
them.  In fact, so many, they had to store them
all in an area which closed down part of the
FCC facility.  The company went on to declare
it all as a loss.  The FCC got stuck with the
inventory.

I don't think they want to repeat that again.

And thus the reason for the wording of the
label.  Unless you're a real threat to
commercial communications (such as a ham)
they really don't want to be bothered.

Just my 3.1415 cents worth ...

- Doug McKean


---
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http://www.rcic.com/  click on "Virtual Conference Hall,"





RE: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread Dick Grobner
"Will put Tania" and I agree with your reasoning!
We don't deal with the FCC as we are a medical manufacturer, but we do deal
with the FDA and the Europeans. We are a small medical manufacture compared
to the Big Boys and we must play by the same rules! Size and dollars has
nothing to do with it and shouldn't. 

-Original Message-
From: Tania Grant [mailto:taniagr...@msn.com]
Sent: Thursday, June 21, 2001 11:23 AM
To: Doug McKean; emc-p...@majordomo.ieee.org
Subject: Re: FCC + FCC = FCC? - Outlaw


Hello Doug,
 
I may or may not agree with FCC (on some issues I agree, on others I don't);
however, ignorance of the law is no excuse.
 
The FCC Rules do make the assembler responsible for compliance.  And the FCC
was NOT created to protect big companies from themselves but to allocate
spectrum and watch for abuses.   The air waves were consigned to bona-fide
communication equipment.  The early computers were nothing more than
super-whiz-bang typewriters-cum-adding machines and not considered
communication devices.   Thus, they were not supposed to interfere with
communication equipment;-- e.g., the Rules.
 
The fact that you can assemble your own, and that you are small fry compared
to the big companies, has nothing to do with the fact that your assembled
equipment need not  comply with the Rules.  (I sympathize with small fry,
being one myself.)  If you disagree with the Rules, you have ample
opportunity to write to the FCC and present your case to them;-- they have
to publish your letter and present an argument for or against your position.
And the FCC in the past has relented and conceded many points when presented
with convincing evidence from the industry and from communication companies.
(Witness the recent changes to accept DoC instead of the cumbersome
Certification procedure for Class B devices.)  I believe that this is the
democratic and responsible way of addressing the problem rather than
disregarding the law because it is inconvenient for you, or because your
equipment is just a small pebble in a big pond of boulders and no one will
notice.
 
Tania Grant
taniagr...@msn.com

- Original Message -
From: Doug McKean
Sent: Thursday, June 21, 2001 12:19 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: FCC + FCC = FCC? - Outlaw
 

Sorry but I respectfully disagree ...

If the FCC were to say yes to anyone being an
outlaw for building their own PC and not having
it tested, then why does the FCC label essentially
tell everyone suffering from interefernce to take
care of it themselves?

The FCC was created to protect the big alphabet
communication companies from themselves. Me building
my own PC is peanuts compared to some of the issues
these guys deal with.  And cable tv is starting to
make the issue of interfering with commercial
broadcast a moot point.  Heck, I don't even see
the pixels blink at all anymore even with the
microwave being used only 10 feet away.

I was told, not sure how true it is, that the
FCC in the early years of Part 15 took to task
a famous computer company selling computers
which hooked up to your tv screen.  They were
famous for intereference.  I know, I had one.
So the FCC threatened to confiscate the units
from said company.  Well, the sales were going
down and the company said, "sure big brother,
to ahead ..."  So the FCC took them.  Lots of
them.  In fact, so many, they had to store them
all in an area which closed down part of the
FCC facility.  The company went on to declare
it all as a loss.  The FCC got stuck with the
inventory.

I don't think they want to repeat that again.

And thus the reason for the wording of the
label.  Unless you're a real threat to
commercial communications (such as a ham)
they really don't want to be bothered.

Just my 3.1415 cents worth ...

- Doug McKean


---
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Re: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread Doug McKean

Decide among youselves who of you are outlaws ...

" TITLE 47--TELECOMMUNICATION
  CHAPTER I--FEDERAL COMMUNICATIONS COMMISSION
  PART 15--RADIO FREQUENCY DEVICES--Table of Contents
  Subpart A--General
  Sec. 15.23  Home-built devices.

  (a) Equipment authorization is not required for devices that are not
   marketed, are not constructed from a kit, and are built in
quantities
   of  five or less for personal use.

  (b) It is recognized that the individual builder of home-built
   equipment may not possess the means to perform the measurements
   for determining compliance with the regulations. In this case,
the
   builder is expected to employ good engineering practices to
meet
   the specified technical standards to the greatest extent
practicable.
   The provisions of Sec. 15.5 apply to this equipment.
"

- Doug  McKean



---
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Re: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread Tania Grant
Hello Doug,

I may or may not agree with FCC (on some issues I agree, on others I don't); 
however, ignorance of the law is no excuse.

The FCC Rules do make the assembler responsible for compliance.  And the FCC 
was NOT created to protect big companies from themselves but to allocate 
spectrum and watch for abuses.   The air waves were consigned to bona-fide 
communication equipment.  The early computers were nothing more than 
super-whiz-bang typewriters-cum-adding machines and not considered 
communication devices.   Thus, they were not supposed to interfere with 
communication equipment;-- e.g., the Rules.

The fact that you can assemble your own, and that you are small fry compared to 
the big companies, has nothing to do with the fact that your assembled 
equipment need not  comply with the Rules.  (I sympathize with small fry, being 
one myself.)  If you disagree with the Rules, you have ample opportunity to 
write to the FCC and present your case to them;-- they have to publish your 
letter and present an argument for or against your position.And the FCC in 
the past has relented and conceded many points when presented with convincing 
evidence from the industry and from communication companies.  (Witness the 
recent changes to accept DoC instead of the cumbersome Certification procedure 
for Class B devices.)  I believe that this is the democratic and responsible 
way of addressing the problem rather than disregarding the law because it is 
inconvenient for you, or because your equipment is just a small pebble in a big 
pond of boulders and no one will notice.
  
Tania Grant
taniagr...@msn.com
- Original Message -
From: Doug McKean
Sent: Thursday, June 21, 2001 12:19 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: FCC + FCC = FCC? - Outlaw
  

Sorry but I respectfully disagree ...

If the FCC were to say yes to anyone being an
outlaw for building their own PC and not having
it tested, then why does the FCC label essentially
tell everyone suffering from interefernce to take
care of it themselves?

The FCC was created to protect the big alphabet
communication companies from themselves. Me building
my own PC is peanuts compared to some of the issues
these guys deal with.  And cable tv is starting to
make the issue of interfering with commercial
broadcast a moot point.  Heck, I don't even see
the pixels blink at all anymore even with the
microwave being used only 10 feet away.

I was told, not sure how true it is, that the
FCC in the early years of Part 15 took to task
a famous computer company selling computers
which hooked up to your tv screen.  They were
famous for intereference.  I know, I had one.
So the FCC threatened to confiscate the units
from said company.  Well, the sales were going
down and the company said, "sure big brother,
to ahead ..."  So the FCC took them.  Lots of
them.  In fact, so many, they had to store them
all in an area which closed down part of the
FCC facility.  The company went on to declare
it all as a loss.  The FCC got stuck with the
inventory.

I don't think they want to repeat that again.

And thus the reason for the wording of the
label.  Unless you're a real threat to
commercial communications (such as a ham)
they really don't want to be bothered.

Just my 3.1415 cents worth ...

- Doug McKean


---
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Technical Committee emc-pstc discussion list.

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All emc-pstc postings are archived and searchable on the web at:
http://www.rcic.com/  click on "Virtual Conference Hall,"


Re: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread Ralph Cameron

Doug:

I think you hit the crux of the matter with one correction, if I may.  Hams
in the U.S. are operating as amateurs but have a legal obligation to the
country in times of need . In Canada , we operate ( myself included) with
"permission" and have no legal obligations to the government. Our equipment
could be comandeered but not the operator. This is a disticntion between our
two countries.

I advise any consumer in a known high ambient RF area ( such as near
broadcast /commercial /ham transmitters to look for the CE mark.  9 times
out of 10  the additional components have not been omitted to seel to North
America.

Likewise in Canada, Industry Canada no longer investigates consumer EMC
complaints ( i.e. lack thereof)  as of two years ago.


Ralph Cameron
EMC Consulting and Suppression of Consumer Electronic Equipment
( after sale)

- Original Message -
From: "Doug McKean" 
To: 
Sent: Thursday, June 21, 2001 2:32 AM
Subject: RE: FCC + FCC = FCC? - Outlaw


>
> Sorry but I respectfully disagree ...
>
> If the FCC were to say yes to anyone being an
> outlaw for building their own PC and not having
> it tested, then why does the FCC label essentially
> tell everyone suffering from interefernce to take
> care of it themselves?
>
> The FCC was created to protect the big alphabet
> communication companies from themselves. Me building
> my own PC is peanuts compared to some of the issues
> these guys deal with.  And cable tv is starting to
> make the issue of interfering with commercial
> broadcast a moot point.  Heck, I don't even see
> the pixels blink at all anymore even with the
> microwave being used only 10 feet away.
>
> I was told, not sure how true it is, that the
> FCC in the early years of Part 15 took to task
> a famous computer company selling computers
> which hooked up to your tv screen.  They were
> famous for intereference.  I know, I had one.
> So the FCC threatened to confiscate the units
> from said company.  Well, the sales were going
> down and the company said, "sure big brother,
> to ahead ..."  So the FCC took them.  Lots of
> them.  In fact, so many, they had to store them
> all in an area which closed down part of the
> FCC facility.  The company went on to declare
> it all as a loss.  The FCC got stuck with the
> inventory.
>
> I don't think they want to repeat that again.
>
> And thus the reason for the wording of the
> label.  Unless you're a real threat to
> commercial communications (such as a ham)
> they really don't want to be bothered.
>
> Just my 3.1415 cents worth ...
>
> - Doug McKean
>
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
> To cancel your subscription, send mail to:
>  majord...@ieee.org
> with the single line:
>  unsubscribe emc-pstc
>
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>  Dave Healddavehe...@mediaone.net
>
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>  Jim Bacher: j.bac...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.rcic.com/  click on "Virtual Conference Hall,"
>
>


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Re: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread Ken Javor

The reason for the FCC disclaimer is not what you say (although it is 
satisfying to think so).  The limits as placed prevent most but not all
interference.  For instance, some AM radios are susceptible to conducted
interference below 48 dBuV.  The limits were placed, both in amplitude and
frequency, to prevent the large majority of interferences, but not all.
Whether it was done right or not may be open to debate, but the philosophy
was to optimize: to get the least amount of interference while imposing the
minimum design cost impact.  Hence the disclaimer that says that if
interference to broadcast reception still occurs, it is your responsibility
to ameliorate it, up to and including ceasing usage of the offending device.

--
>From: "Doug McKean" 
>To: 
>Subject: RE: FCC + FCC = FCC? - Outlaw
>Date: Thu, Jun 21, 2001, 1:32 AM
>

>
> Sorry but I respectfully disagree ...
>
> If the FCC were to say yes to anyone being an
> outlaw for building their own PC and not having
> it tested, then why does the FCC label essentially
> tell everyone suffering from interefernce to take
> care of it themselves?
>
> The FCC was created to protect the big alphabet
> communication companies from themselves. Me building
> my own PC is peanuts compared to some of the issues
> these guys deal with.  And cable tv is starting to
> make the issue of interfering with commercial
> broadcast a moot point.  Heck, I don't even see
> the pixels blink at all anymore even with the
> microwave being used only 10 feet away.
>
> I was told, not sure how true it is, that the
> FCC in the early years of Part 15 took to task
> a famous computer company selling computers
> which hooked up to your tv screen.  They were
> famous for intereference.  I know, I had one.
> So the FCC threatened to confiscate the units
> from said company.  Well, the sales were going
> down and the company said, "sure big brother,
> to ahead ..."  So the FCC took them.  Lots of
> them.  In fact, so many, they had to store them
> all in an area which closed down part of the
> FCC facility.  The company went on to declare
> it all as a loss.  The FCC got stuck with the
> inventory.
>
> I don't think they want to repeat that again.
>
> And thus the reason for the wording of the
> label.  Unless you're a real threat to
> commercial communications (such as a ham)
> they really don't want to be bothered.
>
> Just my 3.1415 cents worth ...
>
> - Doug McKean
>
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
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RE: FCC + FCC = FCC? - Outlaw

2001-06-21 Thread Doug McKean

Sorry but I respectfully disagree ... 

If the FCC were to say yes to anyone being an 
outlaw for building their own PC and not having 
it tested, then why does the FCC label essentially 
tell everyone suffering from interefernce to take 
care of it themselves? 

The FCC was created to protect the big alphabet 
communication companies from themselves. Me building 
my own PC is peanuts compared to some of the issues 
these guys deal with.  And cable tv is starting to 
make the issue of interfering with commercial 
broadcast a moot point.  Heck, I don't even see 
the pixels blink at all anymore even with the 
microwave being used only 10 feet away. 

I was told, not sure how true it is, that the 
FCC in the early years of Part 15 took to task 
a famous computer company selling computers 
which hooked up to your tv screen.  They were 
famous for intereference.  I know, I had one. 
So the FCC threatened to confiscate the units 
from said company.  Well, the sales were going 
down and the company said, "sure big brother, 
to ahead ..."  So the FCC took them.  Lots of 
them.  In fact, so many, they had to store them 
all in an area which closed down part of the 
FCC facility.  The company went on to declare 
it all as a loss.  The FCC got stuck with the 
inventory. 

I don't think they want to repeat that again. 

And thus the reason for the wording of the 
label.  Unless you're a real threat to 
commercial communications (such as a ham) 
they really don't want to be bothered.

Just my 3.1415 cents worth ... 

- Doug McKean 


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RE: FCC + FCC = FCC? - Outlaw

2001-06-20 Thread ChasGrasso

I think the FCC would say- Yes!!
However - with component level tests you would
not be.  OK - Before you all jump all over me..
Yes there will be cost added to the components.
After all it is hard to skim every cent out of a
part when you do not know the system it will go in.
However the advantages from a compliance standpoint
are many. Here are some I can think of:
1. Testing can be done either on the bench or in a
   chamber
2. Testing can be done without the entire system
3. Testing and debug can be done during the  design
   phase.
4. Once completed - the component can be immediately
   released.
5. System tests can be cut to a minimum.
6. There is some assurance that the assembled
   product has had mitigation work done on the\
   components irrespective of the manufacuring location.
7. Add your own..

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