• David Case commented on 2009-10-20 09:23:13.63:
  

  Cisco System supports the release of this document to provide guidance to TCB’s to allow them  review SDR applications, it is a very positive step forward in streamlining the approval process.  Cisco supports the paper as drafted but has several suggestions and comments on it.

   

  The document should point out more clearly to the TCB that the information on the security measures and the operation theory must be filed as confidential. Public disclosure of such information could allow users to modify and defeat mechanisms to prevent unauthorized modifications to the radio.
   
  On the issue of uploading software and the restrictions on US version only, in addressing master devices and base stations we fully support the guidance as written.  However Cisco believes clarity is needed in addressing client cards where operation is restricted to control of the master or base station.  Therefore the ability to upload non US software is not an issue if the device can only operate under control of the master or base station.  Therefore we suggest adding text to the document stipulating that loading non US software which the US frequency band and requirements operate as part of the operation is allowed if the device can only transmit under the control of a base station or master device and operate under US bands when in the US.
   

  In reviewing the requirements to verify a SDR, on the issue of labeling  the device in order to determine the correct software version is loaded to a radio, we have a small concern.  We agree that only the correct software should be loaded on, however we must also insure we do not create additional challenges which could impact the production process. For example by restricting to a specific revision this could prevent the manufacturer from making non radio upgrades to the device which could require a revision of the software.  In this case the change being that the radio is not affected would be a Class I change to the product instead of a class III not requiring a FCC review.  Further for those not using electronic labelling, the cost of changing the product label is cost prohibitive and cannot support upgrades in the field.  Cisco recommends further discussion on this with the industry and FCC lab.

   

   

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Note: It is important to understand that the staff guidance provided in the KDB is intended to assist the public in following Commission requirements and does not constitute rules. Accordingly, the guidance is not binding on the Commission and will not prevent the Commission from making a different decision in any matter that comes to its attention for resolution.