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January 28, 2008

**[VIA CERTIFIED MAIL]{.underline}**

**[RETURN RECEIPT REQUESTED]{.underline}**

Ms. Murina C. Bollaro, President

Mr. Rocco A. Bollaro, Jr., Secretary

Garden State Investigations and Security

2 Overlook Drive

Jackson, New Jersey 08527-4849

> Re: File No. EB-07-SE-347

Dear Ms. and Mr. Bollaro:

This is an official **CITATION**, issued pursuant to Section 503(b)(5)
of the Communications Act of 1934, as amended ("Act"), 47 U.S.C. §
503(b)(5), to Garden State Investigations and Security ("Garden State")
for marketing in the United States unauthorized radio frequency devices
in violation of Section 302(b) of the Act, 47 U.S.C. § 302a(b), and
Sections 2.803 and 15.205(a) of the Commission's Rules ("Rules"), 47
C.F.R. §§ 2.803 and 15.205(a). As explained below, future violations of
the Commission's rules in this regard may subject your company to
monetary forfeitures.

By letter of inquiry dated October 2, 2007, the Spectrum Enforcement
Division of the Commission's Enforcement Bureau ("Division") initiated
an investigation into whether Garden State is marketing in the United
States, an unauthorized radio frequency jamming or blocking device
listed as the "GPS Blocker."[^1] The Division observed an advertisement
for the GPS Blocker jammer device on Garden State's web site,
www.gardenstateinvestigations.com, on September 25, 2007.

In Garden State's October 9, 2007 response,[^2] you admit that you
imported 15 units of the GPS Blocker jammer device into the United
States and began advertising this device on your web site,
www.gardenstateinvestigations.com, in August 2007. You also admit to the
sale of eight of the GPS Blocker jammer devices to clients within the
United States. You state that upon receipt of the Division's October 2,
2007 letter of inquiry, you ceased all advertisement of the GPS Blocker
jammer device. You further state that you destroyed your remaining
inventory of seven devices.

Section 302(b) of the Act provides that "\[n\]o person shall
manufacture, import, sell, offer for sale, or ship devices or home
electronic equipment and systems, or use devices, which fail to comply
with regulations promulgated pursuant to this section." Section
2.803(a)(1) of the Commission's implementing regulations provides that:

no person shall sell or lease, or offer for sale or lease (including
advertising for sale or lease), or import, ship, or distribute for the
purpose of selling or leasing or offering for sale or lease, any radio
frequency device unless ... \[i\]n the case of a device subject to
certification, such device has been authorized by the Commission in
accordance with the rules in this chapter and is properly identified and
labeled as required by § 2.925 and other relevant sections in this
chapter.

Additionally, Section 2.803(g) of the Rules, 47 C.F.R. § 2.803(g),
provides in pertinent part that:

\[R\]adio frequency devices that could not be authorized or legally
operated under the current rules ... shall not be operated, advertised,
displayed, offered for sale or lease, sold or leased, or otherwise
marketed absent a license issued under part 5 of this chapter or a
special temporary authorization issued by the Commission.

Pursuant to Section 15.201(b) of the Rules, 47 C.F.R. § 15.201(b),
intentional radiators[^3] must be authorized in accordance with the
Commission's certification procedures prior to the initiation of
marketing[^4] in the U.S. It does not, however, appear that the
above-cited jammer device is capable of receiving a grant of
certification. In this regard, the main purpose of the jammer device is
to block or interfere with radio communications. Such use is clearly
prohibited by Section 333 of the Act, 47 U.S.C. § 333, which states that
"\[n\]o person shall willfully or maliciously interfere with or cause
interference to any radio communications of any station licensed or
authorized by or under this Act or operated by the United States
Government." Moreover, the GPS Blocker operates within restricted
frequency bands listed in Section 15.205(a) of the Commission's
rules.[^5] Thus, these devices cannot comply with the FCC's technical
standards and therefore cannot be certified or marketed. Finally, you
note that you received inquiries and had purchases from local law
enforcement and federal law enforcement bureaus. While radio frequency
devices intended for the federal government or agencies thereof are
exempt from the Commission's rules,[^6] there is no similar exemption
for sales to state and local law enforcement. Accordingly, it appears
that Garden State has violated Section 302(b) of the Communications Act
and Sections 2.803 and 15.205(a) of the Commission's rules by marketing
in the United States radio frequency devices that are not eligible for
certification.

**[If, after receipt of this citation, Garden State Investigations and
Security violates the Communications Act or the Commission's Rules in
any manner described herein, the Commission may impose monetary
forfeitures not to exceed \$11,000 for each such violation or each day
of a continuing violation.]{.underline}**[^7]

If you choose to do so, you may respond to this citation within 30 days
from the date of this letter either through (1) a personal interview at
the Commission's Field Office nearest to your place of business, or (2)
a written statement. Your response should specify the actions that
Garden State Investigations and Security is taking to ensure that it
does not violate the Commission's rules governing the marketing of radio
frequency jamming devices in the future.

The nearest Commission field office is the Philadelphia, Pennsylvania
office. Please call Jacqueline Johnson at 202-418-2871, if you wish to
schedule a personal interview. You should schedule any interview to take
place within 30 days of the date of this letter. You should send any
written statement within 30 days of the date of this letter to:

> Kathryn S. Berthot

Chief, Spectrum Enforcement Division

Enforcement Bureau

Federal Communications Commission

445 12^th^ Street, S.W., Rm. 3-C366

Washington, D.C. 20554

Under the Privacy Act of 1974, 5 U.S.C. § 552(a)(e)(3), we are informing
you that the Commission's staff will use all relevant material
information before it, including information that you disclose in your
interview or written statement, to determine what, if any, enforcement
action is required to ensure your compliance with the Communications Act
and the Commission's rules.

The knowing and willful making of any false statement, or the
concealment of any material fact, in reply to this citation is
punishable by fine or imprisonment under 18 U.S.C. § 1001.

Thank you in advance for your anticipated cooperation.

Sincerely,

Kathryn S. Berthot

> Chief, Spectrum Enforcement Division

Enforcement Bureau

[^1]: Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement
    Division, Enforcement Bureau, to Garden State Investigations and
    Security (October 2, 2007).

[^2]: Letter from Murina C. and Rocco A. Bollaro, Jr., Garden State
    Investigations and Security, to Jacqueline Johnson, Spectrum
    Enforcement Division, Enforcement Bureau (October 9, 2007).

[^3]: Section 15.3(o) of the Rules defines an "intentional radiator" as
    a "device that intentionally generates and emits radio frequency
    energy by radiation or induction." 47 C.F.R. § 15.3(o).

[^4]: Section 2.803(e)(4) of the Rules defines "marketing" as the "sale
    or lease, or offering to sale or lease, including advertising for
    sale or lease, or importation, shipment or distribution for the
    purpose of selling or leasing or offering for sale or lease." 47
    C.F.R. § 2.803(e)(4).

[^5]: Section 15.205(a) allows intentional radiators to transmit only
    spurious emissions in the restricted frequency bands. 47 C.F.R. §
    2.1 defines spurious emissions as "\[e\]missions on a frequency or
    frequencies which are outside the necessary bandwidth and the level
    of which may be reduced without affecting the corresponding
    transmission of information. Spurious emissions include harmonic
    emissions, parasitic emissions, intermodulation products and
    frequency conversion products, but exclude out-of-band emissions."
    The GPS Blocker (which operates in the 1450 MHz to 1600 MHz bands)
    intentionally transmits radio frequency energy on restricted
    frequencies.

[^6]: See 47 U.S.C. § 302(c); 47 C.F.R. § 2.807(d).

[^7]: *See* 47 C.F.R. § 1.80(b)(3).