moko13 firmware

Mychaela Falconia mychaela.falconia at
Sat Oct 14 18:00:45 UTC 2017

Further on the subject of FCC type approval or lack thereof, your
change log at:

lists "Pass the PTCRB certification" under moko5.  Does it imply that
there was no PTCRB certification and thus no FCC approval number prior
to the time of moko5?  Yet you sold quite a few GTA01 devices prior to
that time.  Does it mean that those GTA01s, particularly the earliest
phase 0 devices, were sold or sent free of cost to people who weren't
OM employees without having FCC approval?  If you say that selling
devices without such full approval is absolutely illegal, then how
were you able to get away with it?

And when it comes to my *current* FreeCalypso devices (as opposed to
potential future ones) which lack FCC approval, please keep in mind
that these current devices are *development* boards, not intended for
end users.  These development boards are specifically intended for
developers and tinkerers who will be playing with their own radio fw
builds, and have no other purpose.  I doubt that such developer kits
(as opposed to end user products) are eligible for FCC approval at all.

Yet there are many, many companies that sell gear specifically for
developers, specifically for lab use in controlled environments, gear
that does not have FCC approval for end user operation.  Even TI back
in the day when they made cellular baseband chipsets made and sold
such development kits, and I even managed to score one of those
historical TI dev kits on ebay:

TI's cellular development kits like the one pictured above were sold
to chipset customers who were developing their own products with TI's
chips, were delivered along with those infamous NDA-controlled firmware
sources or semi-sources, and were specifically intended for engineers
to try out their own fw builds.  I somehow doubt that these development
kits had FCC approval of the same kind as end user devices, yet I also
doubt that TI were breaking laws by selling these kits.

Thus if a piece of gear is explicitly sold as a development kit for
engineers, not as an end user product, and it is very clearly indicated
that it is not FCC-approved as an end user product and that the
engineer-customer must take the full personal responsibility for its
radio operation, then maybe it is not so totally illegal for the dev
kit manufacturer to sell such kits?

You are of course correct that if someone buys a non-type-approved
cellular development kit like TI's D-Sample or my FCDEV3B and uses it
to do their own radio fw development, they have a responsibility to do
their initial tests in a controlled environment, either without an
antenna, using a conducted connection to an RF tester like R&S CMU200
(that's my setup), or with radiated transmissions in an anechoic
chamber like you said.

But there also exists a phase in the development and testing cycle in
which a device has not received full approval yet, but is being tested
on real live GSM networks.  Such tests are conducted with the full
knowledge and cooperation of the network operator, with the test
device operator ready to unplug the power supply at any moment should
the device under test cause any kind of disruption or interference to
the live network.

The ONLY way in which my process deviates from the "fully legitimate"
process described above is that I do not seek special approval from
T-Mobile prior to sticking one of their SIM cards into one of my
development devices, but just do it.  But I never leave such a setup
unattended while powered on, and I always closely monitor the operation
of my devices whenever I conduct operational tests on the live T-Mobile
GSM network.  If the device ever misbehaves in any way (which has yet
to happen), I will most certainly power it off immediately.  Because
my devices function 100% correctly and in accord with the GSM specs,
no interference or disruption of any kind takes place, and absolutely
no harm is caused to anyone.


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