In the US, ยง97.3 Definitions. (a) The definitions of terms used in Part 97 are:
(1) Amateur operator. A person named in an amateur operator/primary license station grant on the ULS consolidated licensee database to be the control operator of an amateur station. Generally a dongle is used to control a repeater station (out there somewhere). I believe it is a rare instance to have a dongle to dongle chat not involving a radio station transmitter, hence in my humble opinion, with very few exceptions, the DV Dongle controls radio transmitters and is amateur radio. nu5d
