![](media/image1.png){width="1.2902777777777779in"
height="1.229861111111111in"} June 9, 2005

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

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

Shaker Hassan,

Sales Manager, Grand Trades Co.

4701 15th Avenue, N.E.

Apartment 108

Seattle, WA 98105

> Re: File No. EB-05-SE-059

Dear Shaker Hassan:

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

By letter dated March 15, 2005, the Spectrum Enforcement Division of the
Commission's Enforcement Bureau initiated an investigation into whether
Grand Trades Co. ("Grand Trades") is marketing in the United States
unauthorized radio frequency devices, specifically, cell phone jammers,
wireless device jammers and long range cordless telephones.

At the time of that letter, March 15, 2005, we observed on your website,
www.grandtrades.net, your advertisement for sale of the following radio
frequency devices:

1.  SH-066BM2 A/B-R cell phone jammer. The website indicated that there
    were two models of this device available, including one for
    "USA/Canada."

2.  SH066PL2A/B portable cell phone jammer. The website indicated that
    there were two models of this device available, including one for
    "USA/Canada."

3.  GT-200 cell phone jammer. The website indicated that there were two
    models of this device available, including one for "USA/Canada."

4.  SRC300 cell phone jammer. The website indicated that there were two
    models of this device available, including one for "USA/Canada."

5.  GT300 cell phone jammer. The website described this device as a
    "Worldwide" cell phone jammer.

6.  2.4 GHz wireless jammer. The website stated that this device
    interferes with the video signals of wireless cameras and blocks the
    communications of wireless LANs and Bluetooth devices.

7.  Senao 358 long range cordless phone. The website indicated that this
    device has a range of 20 km.

8.  Senao 668 long range cordless phone. The website indicated that this
    device has a range of 128 km.

9.  Senao 869 long range cordless phone. The website indicated that this
    device has a range of 20 km.

Your advertisement of these products specifically listed shipping costs
to customers in the United States. Your website also listed your "USA"
business address as 4701 15th Avenue, N.E., Apartment 108, Seattle,
Washington 98105, and your "USA" fax number as (206) 309-0271.
Furthermore, your website stated that "\[w\]e run the business from more
than one location in Taiwan, Egypt & USA" and that "we gladly served
many customers worldwide from USA, UK, Canada, Germany, Ireland, France,
Italy, Portugal & more."

In response to our letter of inquiry, you sent us two undated written
responses by facsimile, one received on or about March 20, 2005 and one
received on or about March 30, 2005. In these faxes, you claimed that
your company is based in Taiwan and Egypt, that you don't have any
import or export business activity or distributors inside the U.S., and
that you don't have an office or branch of Grand Trades or hold any
inventory in the U.S. You further claimed that Grand Trades is "not
directing our business to USA." Nevertheless, you admitted that since
Grand Trades began its business about five months ago, it has sold about
10 cell phone jammers, two video jammers, and four long range cordless
telephones to U.S. customers. You did not provide FCC Identification
numbers or other documentation showing that the devices have been
certified in accordance with the Commission's equipment authorization
requirements. Finally, you stated that you do not manufacture the
devices and are not aware of the regulations of each country.

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.

Pursuant to Section 15.201(b) of the Rules, 47 C.F.R. § 15.201(b),
intentional radiators must be authorized in accordance with the FCC's
certification procedures prior to the initiation of marketing[^1] in the
U.S. Based on your failure to provide FCC Identification numbers or
other documentation showing that the jammers and cordless telephones
marketed in the U.S. by Grand Trades have been certified, as well as our
review of the Commission's equipment authorization database, it appears
that these devices have not been certified. Moreover, it does not appear
that these devices are capable of receiving a grant of certification. In
this regard, the main purpose of cell phone and other wireless jammers
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." A device such as a jammer which intentionally
interferes with radio communications is not eligible for
certification.[^2] Similarly, considering the long ranges cited in your
advertisements for the cordless telephones, it appears that they do not
comply with FCC technical requirements and therefore could not receive a
grant of certification. Accordingly, it appears that Grand Trades has
violated Section 302(b) of the Act and Section 2.803(a) of the Rules by
marketing in the United States the nine unauthorized radio frequency
devices listed above. Finally, we note that the evidence before us
contradicts Grand Trades' claim that it is not directing its business to
the United States. In this regard, we note, among other things, that
Grand Trades' website advertised "USA/Canada" models of several of its
cell phone jammers, listed shipping costs to the United States for its
products, and stated that "\[w\]e run the business from more than one
location in Taiwan, Egypt & USA" and that "we gladly served many
customers worldwide from USA, UK, Canada . . ."

**[If, after receipt of this citation, you violate 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}** [^3]

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 you are taking to ensure
that you do not violate the Commission's rules governing the marketing
of radio frequency equipment in the future.

**The nearest Commission field office appears to be the Seattle District
Office, in Kirkland, Washington. Please call Katherine Power at
202-418-0919 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 Berthot

Deputy Chief, Spectrum Enforcement Division

Enforcement Bureau

Federal Communications Commission

445-12^th^ Street, S.W., Rm. 7-C802

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 Berthot

> Deputy Chief, Spectrum Enforcement Division

Enforcement Bureau

Federal Communications Commission

[^1]: 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).

[^2]: Section 2.803(g) of the Rules provides that radio frequency
    devices that could not be authorized or legally operated under the
    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." 47 C.F.R. § 2.803(g).

[^3]: *See* 47 C.F.R. § 1.80(b)(3).