Title: Comments on: MobileID-BPRS-20080505.pdf Contact: Michael McCabe rmmccabe@Comcast.net Date: June 5, 2008 Document: A

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FBI 1 All te The EBTS is still under revision and will go through 

another version change soon so referring to EBTS 8.002 

might become confusing at some point in the near future. 

Reference EBTS without a version numb

FBI/2 13 

Ge ge Sections 7 and 8 do not align with section 6 in regards to 

the placement of tables 7.1 and 8.1 within those sections. 

Not sure which is better, but the three secshould be consistent with regard to the lo

these tables. 

FBI/3 1 Ge Doesn’t’ seem to be much specific information regarding 

minutiae v/s images – interoperability between different 

systems. Readers of this document may not recognize the difference Perhaps a separate section regarding this topic could be included in this document. 

MOT 1 

Ge Ge What is the expected implementation time frame? Provide expected implementation time fra

ITAL/ 8 Ge Ge There are existing ISO Standards (19794-X) that already 

covers some requirements described in the draft. 

Refer to existing ISO standards if the subalready been covered by ISO. 

BPRA 1 

Ge Ge Consistency in document terminology Use ‘enrolment, identification, and authen

throughout. Sometimes the phrase ‘enrol

authentication, and identification’ is used

BPRA 3 

Ge Ge System needs possibility of extensions to other modalities 

built in. 

Palm? Mobile DNA analysis systems, nex

years? 

BPRA 4 

Ge Ge Cross Match, Identix, I3 ID Flats fingerprint capture 

devices are currently carried into the field for mobile 

‘Mobile’ needs some definition work. 
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capture. A laptop PC is mobile, while a desktop PC isn’t? 

BPRA 6 

Ge Ge Standards for interoperability are certainly referenced 

repeatedly, as are FBI certification standards for 

fingerprint devices. 

Don’t apologize for preparing the way for standards – use the ‘best practice’ term a

currently useful place holder for what is fuexpected to be a set of standards in the nfuture. 

BPRA 8 

Ge Ge Need a full bibliography. 

BPRA 2 

Ge Title page Ge Many of the topics covered in the document refer to parts 

of the capture system beyond just the device: software, 

communications, etc. 

Replace ‘device’ with ‘system’. 

WK 4 Title Change title to: Mobile ID Device Best Practice Recomm

& Specification

Noblis/ 1 

TOC ed Include a list of tables and figures Include a list of tables and figures 

TXDPS 1 

1 - Intro 1st

paragraph, 6th line 

ed HUMVEE should not be all caps – it is not an acronym. It 

is slang for High Mobility Multipurpose Wheeled Vehicle 

or HMMWV. 

Replace HUMVEE with Humvee. 

NPIA/ 1 - Intro 2nd sentence ed Wording – ‘...it may consist of an untethered device 
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1 ‘ In the strictest sense, it may require an untethered 

device used to capture one or more......’ 

used to capture one or more...’ 

CMT/ 1 

1 3rd Sentence ge Intent of 3rd sentence not clear (really the 4th) Add “repository” before “... in a nearby ve

FBI/2 1 

1 Para. 3 ed Second sentence “enables” should be “enable” 

NPIA/ 2 

1- intro 3rd para ed Wording – 

‘If a match is not found, an access or privileges may otherwise be denied.’ 

‘If a match is not found, access rights or pmay be denied’ 

CMT/ 2 

1 3rd par next 

to last sen. 

 ge Remove “otherwise” 

TXDPS 3 

1- Intro 3rd 

Paragraph, 

16th line 

te DHS may take action on a hit or a no hit, depending upon 

which database is searched. 

Modify sentence to indicate that dependindatabase searched, DHS may use the re

no hit) to deny an access or a privilege. 

FBI/1 4 1 Paragraph 3 ed Incorrect punctuation. Remove second period after “future..” 

TXDPS 2 

1- Intro 3rd 

Paragraph, 

14th line 

ed There are two periods after the word “future”. Delete extra period. 

MOT 2 

1 Paragraph 3 ed Line 14 in the 3rd paragraph ends with 2 periods. Remove double period. 
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TXDPS 4 

1 - Intro 6th

paragraph, 11th line 

Ge Sentence indicates that this document will address best 

practices for current equipment and prescribes an 

approach that defines standards to which future acquisitions should adhere. While this is a good idea, the rest of the document is not consistent with the APB recommendation to the IS and IIETF for the development of best practices associated with the use of currently available equipment in specific. 

Best practices for current systems need taddressed. I see this as being along the 

standards for scanner development . Withad Appendix F (where we wanted to goAppendix G (what was available at the timsame type of approach should be utilized Some of the best practices would involve for systems that support the mobile devicetc) 

TXDPS 5 

1- Intro 7th

paragraph, 4th line 

te Sentence indicates that, for IAFIS or NGI, INCITS 

standards can be used. It needs to indicate that INCITS standards will only be used for modalities not defined in ANSI/NIST- ITL 1-2007. 

Modify sentence to read “..... or INCITS (for modalities not defined in ANSI/NIST- 

2007). 

BPRA 5 

Ge Ge Access control in many current applications does not 

follow FBI/NIST standards. Not AFIS oriented. May use 

BioAPI. 

Avoid tying specifications to AFIS or NGIcomparable contexts. 

Noblis/ 2 

Intro last para te Does "series of profiles" refer to Biometric Acquisition 

Profiles (BAP), Subject Acquisition Profiles (SAP), or application profiles like those defined by INCITS M1? 

State clearly what is meant by "profiles", 

Biometric Acquisition Profiles (BAP), SubAcquisition Profiles (SAP), or application like those defined by INCITS M1 

NPIA/ 3 

2 - Scope te While the focus of this report is on the use of mobile ID to 

identify ‘suspects’, in many applications it is equally 

important that the operator of the device is properly 

Suggest adding a sentence to the scope out that accurate user authentication is a

important factor and is within the scope o
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authenticated. document, even though the main focus o

report is concerned with identification of 3

parties. 

TXDPS 6 

2- Scope 1st

paragraph, 4th line 

ed “Often, these applications typically....” Use of often and 

typically is redundant. 

Delete “typically”. 

LM/ 1 2.0 P7, pp1 ge Use of term “court challenges” may cause company 

lawyers to refuse to participate 

Perhaps tone down implication that it mucourt challenges 

TXDPS 7 

2 - Scope 2nd

paragraph, 3 +4th line 

ed “sets of best practices requirements”??? Are they best 

practices or requirements? 

Delete “requirements”. 

BPRA 7 

Ge Scope, para. 

2 

Ge Interoperability should be the main focus. Improvements 

in image capture processes, image quality, and accuracy 

are driven by other factors in the marketplace much more than standards. 

Purpose is too broad. Data quality won’t improved by a best practice or standard, 

we say that mere size of an image is a mingredient of image quality. 

COGT 1 

2 3 ge The last sentence of this paragraph is “As the BAP 

numbers increase, so do the capabilities of the device”. There are no “BAP numbers” defined in this draft. Does this sentence mean “As the SAP numbers increase ...”? 

Noblis/ 3 

3 1st para te At a high level, Clause 3 speaks to capture (Clauses 6-8), 

use (Clause 9), security (Clause 10), and transmission 

(Clause 11) of mobile identification data, but it does not include environmental requirements (Clause 12). 

Replace: This specification provides guidelines for 

capture, use, security, and transmission oidentification data that can be interoperabsimilar and dissimilar systems. with: 
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This specification provides guidelines for capture (Clauses 6-8), use (Clause 9), se(Clause 10), and transmission (Clause 11mobile identification data that can be intewith similar and dissimilar systems. It alsprovides guidelines for environmental requirements for mobile identification dev(Clause 12). 

FBI/2 2 

3 Para. 1 ed Second to last sentence “of” should be “on” 

TXDPS 8 

3- Purpose 

1st paragraph, 

9th line 

ed “Choice of the level will depend of....” Change “of” to “on” 

MOT 3 

3 Paragraph 3 Te When will EBTS Version 8.002 be supported by the FBI? Provide date EBTS Version 8.002 will be 

supported by the FBI. 

CMT/3 4 4th bullet ed Spelling of “building” Add the g to spell “building” FBI/1 1 4 Bullet 4 ed Incorrect spelling. Correct spelling of “buildins” to “buildingsL1/ 1 4, P. 8 4th bullet ed Change “buildins” to “buildings” TXDPS 9 

4-Appl. 1st 

paragraph, 

4th bullet 

ed “buildins” This document will be used outside of West 

Virginia – there should be a “g” in this word! 

Change to “buildings” 

NPIA/ 4 

4 - Applicabil

1st bullet ed The use of the word ‘watchlist’ implies a targeted search 

of a subset of data, whereas in many cases a mobile 

Delete ‘watchlist’ or reword to ‘...check aone or more biometric databases and / o
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ity search may be against a national database. watchlists’. 

NPIA/ 5 

4 - Applicabil

ity 

4th bullet ed ‘Access control’ may apply to both 3rd party users 

(subjects) and also to the operators of mobile devices 

Reword – ‘Access control for buildings, cand networks, both for 3rd party users (su

well as to authenticate the operator of the device itself. 

NPIA/ 6 

4 - Applicabil

ity 

Bullets ed Mobile ID may also be used as part of process for the 

enforcement of arrest warrants to ensure that the correct 

person is being arrested. Mobile ID is also extremely useful when deployed at high profile public events (for example - football matches, G8 

summits, music festivals etc). 

Add extra bullets: 

- ‘Enforcement of arrest warrants’ 

‘High profile, major public events, where systems may not be practical or appropri

NPIA/ 7 

4 - Applicabil

ity 

Final Para te There is no mention of ‘voice’ and yet speaker 

recognition, especially if combined with speech 

recognition, can provide the capability to continuously authenticate the user as well as for voice activated control of the device / system. There may also be occasions where it is useful to be able to take a voice / speech sample of the subject, either for 

immediate comparison or for later use. 

Include a sentence on voice as part of lonmobile biometric capabilities, even thouganalysis is not within scope of this docum(Or alternatively add it to the scope!) 

MOT 4 

5.1 Paragraph 1 ed First sentence – there is an extra space after "processing" 

before comma. 

Delete extra space after "processing" befcomma. 

FBI/1 5 5.1 Paragraph 1 ed Incorrect punctuation. Remove trailing space after “processing ,NPIA/ 8 

5.1 - Functions 

Te While the focus of this document is on mobile devices, 

these cannot be considered in isolation. The document 

would benefit from a more thorough analysis of the issues surrounding the ‘middle’ and ‘back’ end systems, and the implications on system architectures of adopting particular mobile solutions. 

Include a more detailed discussion of the end’ process, and requirements of other 

the overall system (either as a new sectioan annex) See attached logical architecture diagram 
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LM/ 2 5.1 P10, diagram ed Immediate look at figure is not clear where networks 

come into play. 

Add the word “network” within the clouds diagram. Perhaps put “stand-alone” as s

(a). 

NPIA/ 9 

5.1 - Functions 

ed The diagram would benefit from some explanatory text 

and perhaps also better distinction between what is ‘local’ and what is ‘remote’. What does ‘signal processing’ entail - image processing / feature extraction / encryption ? 

Diagram also needs a Ref adding. 

Expand supporting text Add reference 

MOT 5 

5.1 Graphic te Example (b) in the graphic does not logically make sense 

to have the network between Matching and Decision 

because the Matching and Decision should be together. 

Remove example (b) from the graphic. 

FBI 2 5.1 Te The document talks about a database on the capture 

device and this implies that this is allowed as a best practice when this should really only be a last resort (if then) practice. 

Re-write section 5.1, including picture, to 

reference to a database on the capture d

CMT/4 5.1 Functions 

over networks 

Te Decision on Device, there is no recommendation on how 

to ensure database download is secure and trusted. 

Need to specify encryption and digital sigdownload of Database (Watchlist) on dev

CMT/5 5.1 Functions 

over networks 

Te (a) Decision made on mobile device but not logged. Recommendation to log the device decis
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CMT/6 5.1 Functions 

over networks 

Te Need an (a.5) – Need a method/network to pass decision 

on to central repository 

Add additional network security (SAML) tdecision to repository SAML (Security AsMarkup Language) is an “XML-based communications framework for secure do

CMT/7 5.1 Functions 

over networks 

Te Need an (b) – Need a method/network to pass match 

score on to central repository 

Add additional network security (SAML) tmatch score to repository SAML (Security Assertion Markup Language) is an “XML-communications framework for secure do

CMT/8 5.1 Functions 

over networks 

Te ( c) & (d) – there is no security recommended for passing 

of the EFTs 

Need to identify some security method visignature and encryption 

CMT/9 5.1 Functions 

over networks 

Te There is no indication of any key management scheme 

for data encryption 

Need to identify key management for datencryption passing between device and cdatabase. Perhaps a second key scheme is needed in-vehicle database also. 

Noblis/ 4 

5.1 figure ed The figure "Functions over Networks" is not captioned. Add a caption to the figure. 

Noblis/ 5 

5.2 figure ed The figure "Physical Architecture" is not captioned. Add a caption to the figure. 

FBI/2 3 

5.2 Para. 3 ed Bullets describing the two types of sensors seem to be 

missing words. 

FBI/1 6 5.2 Paragraph 3 Ed Sentence in first bullet is nonsensical. Change to “A Peripheral device where th

biometric sensor is connected via a stan

interface (e.g., USB connection). “ 

FBI/1 7 5.2 Paragraph 3 ed Sentence in second bullet is nonsensical. Remove the word “that” from the sentenc
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NPIA/ 10 

5.2 - Physical 

3rd para, 1st

bullet 

ed Wording 

...the biometric sensor via a standard interface.. 

Change to ‘the biometric sensor is connected via a ...

CMT/10 5.2 Physical 

Architecture 

 ed Box not large enough for text “ Data Capture” Enlarge box to show full text 

NPIA/ 11 

5.3 Data Format 

1st bullet ed Data formats may vary depending on whether data is 

being sent from, or returned to, the device 

Change to ‘Format in transport, both for transmitting receiving data’ 

L1/ 2 5.3, P. 11 te Add bullet for “Encryption, both storage a

transmission” 

Noblis/ 6 

6 7 8 

ge Recommend consistent approach to defining 

requirements for SAP levels. Clause 6 specifies "capture and transmission", Clause 7 specifies "capture and interchange", and Clause 8 specifies "capture, interchange, and matching". 

Apply consistent approach to definition of levels for face, finger, and iris image captdevices. 

FBI/2 4 

6.1 Para. 1 ed First sentence, “a high quality ... images” , “a” should be 

stricken or “images” changed to “image” 

BPRA 9 

Ge Fingerprint 

capture devices 

Ge Other things equal, a larger image is better than a smaller 

image, and images of more fingers are better than images of fewer fingers. This is not about quality, but about quantity. 

‘High quality’ confusing in use in the docuPIV device that has a platen size of .5”x.6produce a very high quality image, just a one. And a single finger device may prodimage that is equal in quality to the 4 fingproduced by a 4-4-2 scanner. 
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NPIA/ 12 

6.1 6th sentence te There may be occasions when fingerprint images with a 

NFIQ of 4 or 5 are all that can be obtained. Whether or not they should be used for enrolment is dependent on the particular business process. 

Change ‘should not be used for enrolmenshould not normally be used for enrolmen

TXDPS 10 

6 –Mobile ID Devices 

Chart, SAP5 ed There is no entry for the “Acquire Rolled Images” row for 

SAP 5 

Enter “No” into the “Acquire Rolled ImageSAP 5 

ITAL/ 1 6.1 Table 1 Te Minimum resolution tolerance for SAP Levels 5 to 30 (+/- 

5 ppi or 1%) is not in line with PIV sensor specifications. 

Minimum resolution for SAP Levels 5 to 3be 500 ppi +/- 10 ppi (2%). 

ITAL/ 2 6.1 Table 1 Te Specifying only the minimum number of greylevels does 

not guarantee an image with good contrast. 

A requirement for the minimum dynamic should be added (i.e. >=80). 

MOT 6 

6.1 Table 1 Te For multiple finger submissions, are simultaneous slap 

captures supported, e.g. fingers 2 and 3? 

Define if simultaneous slap captures are supported. 

FBI 3 Table 1 te Include the “best practice” fingers to include in order to 

achieve interoperability with most systems. I know this has been discussed at the meetings but I think it is important information to include. It may be an important bit of information for people just beginning mobile ID. 

Table should include the best practice fin7) that should be included for interoperab
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FBI/1 8 6.1 Table 1 ed Label is ambiguous. Suggest changing 9th row title from “Num

fingers or images” to “# of simultaneous fto avoid misinterpretation. 

NPIA/ 13 

Table 1 ed Target Compression ratio can give the impression that 

images must be compressed by this amount, whereas 

this is better thought of as a maximum compression ratio. 

‘Number of Fingers’ would be better labelled ‘Max No. of Fingers that can be simultaneously captured’ 

Change ‘target’ to ‘maximum’ Clarify that Number of fingers refers to simultaneous capture 

L1/ 3 

6.1 Table 1 Te With the advent of zero tolerance policies, DAs won’t 

prosecute without biometric evidence to verify the identity of a subject in court. Mobile booking (enrolling prints into AFIS databases and retention of demographics and photo) allows cite out of subjects. This is seen by many officers as more important than mobile identification. 

The requirement to have Appendix F IQS for all enrolls will add significant size, weight, and cost to mobile devices. PIV quality levels are sufficient for AFIS matching. They are certainly sufficient for biometric verification in court. 

Add an SAP 35 that is equivalent to SAP the exception that image quality requiremPIV, vs. Appendix F. 

COGT 3 

6.1 Table 1 te Sensor certification -- The tenth item in the “CAPTURE” 

section: 

App F is proposed for SAP=40 while device of SAP=40 can be single finger device per current draft. Currently, FBI doesn’t issue App F certification to single finger device. The certification for single finger device is categorized into PIV certification (see FBI website). 

If the device supports only single finger cPIV certification is required. If the device two-finger capture, App F is required. 
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L1/ 5 6.1 Table 1 Te Target Compression Ratio of 10:1 will increase the file 

size transmitted. 15:1 will maintain the image contents and reduce the file size. 

Change the Target Compression Ratio foand 30 to 15:1. 

LM/ 3 6.1 Table 1 ed Only image compression listed is WSQ Should also list JPEG2000, especially for 

1000-ppi images as described in 6.2.3 buthe table 

Noblis/ 6 

6.1 1st para 

Table 1 

ed Replace "M1 378" with "INCITS 378-2004" Replace "M1 378" with "INCITS 378-2004

Noblis/ 7 

6.1 Table 1 ed "ANSI/NIST" is ambiguous. 

Replace "ANSI/NIST" with "ANSI/NIST IT

2007" 

- or - Replace "ANSI/NIST-ITL 1-2007" with "ANSI/NIST-ITL 1-2007 [hereinafter ANSin Introduction, paragraph 7. 

COGT 2 

6.1 Table 1 te Minimum image dimension -- The fifth item in the 

“CAPTURE” section: 

 The proposed dimensions for all but one single finger SAP levels are corresponding to a rectangular area with its height being larger than its width. The only exception is SAP=20, for which a square of 8’ X .8’ is proposed. Because of the shape of human finger, a flat fingerprint tends to have a longer span vertically than horizontally when fingertip is pointing up or down. Therefore, a rectangular area with its height being larger than its width is the optimized solution for sensing area of singer fingerprint sensor. This should be taken into consideration 

It is suggested that the requirements for Sto be modified to 0.6’ X 0.8’. 
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when the minimum image dimension for each level is defined. SAP 5, 10 and 30 are already consistent with the optimized solution. It is suggested that the requirements for SAP=20 to be modified. 

CMT/11 6.2.1 ed “± 5 ppi” should be same font point size as rest of text. Change text format size FBI/1 9 6.2.1 Paragraph 1 te Limiting options for the user/system integrator. Suggest removing the second half of the 

sentence that requires down-sampling to We don’t want to force this requirement amandate a loss of resolution. There may systems in the future that can handle and effectively exploit the additional detail in 1imagery. Let’s leave this one open to the integrator. 

NPIA/ 14 

6.2.2 – Minimum Image Size 

Last sentence 

ed Wording 

‘As the SAP level increases so does the size of the image and number of fingers captured’ 

Suggest changing to ‘As the SAP level increases so does the osize of the image and number of fingers wbe simultaneously captured.’ 

FBI/1 10 6.2.3 Paragraph 1 te Limiting options for the user/system integrator. Suggest adding the following to the last s

“that require 500ppi imagery compressed WSQ.” 

Noblis/ 8 

6.2.3 1st para ed Replace "Profile for 1000ppi fingerprint" with "Profile for 

1000ppi Fingerprint Compression" 

Insert footnote or add reference to Profile for 1000ppi Fingerprint Compression, 

http://www.mitre.org/work/tech_papers/tech_papers_04/le

Replace "Profile for 1000ppi fingerprint" w"Profile for 1000ppi Fingerprint CompressInsert footnote or add reference to Profile 1000ppi Fingerprint Compression, http://www.mitre.org/work/tech_papers/te
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pley_fingerprint/lepley_fingerprint.pdf s_04/lepley_fingerprint/lepley_fingerprint

NPIA/ 15 

6.2.3 Compression Algorithm 

2nd sentence ed What is meant by ‘Profile for 1000ppi fingerprint’? Clarify what this means or add reference 

CMT/12 6.2.4 te The reference to “transcoded down to 100 ppi”is 

confusing. The best practice levels all are 500 ppi. Why mentioned 100 ppi? 

Either explain the reference to 100ppi or it. Should this 100ppi be 500ppi? 

FBI/1 11 6.2.4 Paragraph 1 Te Incorrect value. I think the last numeric value in this parag

should be 500 ppi vice 100 ppi. 

FBI/2 5 

6.2.4 Para. 1 ed 100ppi should be 500ppi? 

Noblis/ 9 

6.2.4 1st para ed Replace "transcoded down to 100 ppi" with "transcoded 

down to 500 ppi" 

Replace "transcoded down to 100 ppi" wi"transcoded down to 500 ppi" 

MOT 7 

6.2.4 Te Are the compression ratios on average or will any 

submission with a compression ratio larger than 10:1 (for SAP levels 10, 20, or 30)/15:1 (for SAP levels 40 or higher) be rejected? 

Define if compression ratios larger than 115:1 will be rejected. 

L1/ 6 6.2.4 Te Same as L1/5. Change 6.2.4 to read “For small area ima

than .7” x .6”, the maximum compression be used is 10:1. For larger image areas compression ratio may increase to 15:1.” 

MOT 8 

6.2.5 Te When will Appendix F certification of sensors be available 

(when will a procedure be defined to start issuing this certification) 

Define Appendix F certification. 

L1/ 7 6.2.5 Ed Need to clarify “smaller sensors”. Change “Smaller sensors should have th
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“Sensors with SAP levels below 40 shouthe PIV”. 

FBI/1 12 6.2.6 Paragraph 1 ed Incorrect syntax. Change “compliance” to “compliant”. NPIA/ 16 

6.2.6 Extractor Cerification 

te Is one SAP level enough for minutia based searching? 

Bandwidth restrictions may mean that a sensor meeting SAP 40 (or above) may be installed on the device but it is not possible to transmit the image(s) over the network A MINEX certified extractor is mandated for minutia based searching for interoperability, but No 9 in Table 2 states that SAP5 is not intended for use between systems. While MINEX may be best for interoperability, this may not be the key factor in some applications or environments and there may be applications where other extractors are better suited. This report as a whole does not really include any discussion of minutia based searching, focussing almost entirely on the use of images. 

Include a section discussing the advantagdisadvantages of using minutia in conjunmobile ID. 

Noblis / 10 

6.2.7 1st para ed Replace "the INCITS 378 minutiae data format standard 

developed by the M1 committee" with "INCITS 378-2004" 

Replace "the INCITS 378 minutiae data fstandard developed by the M1 committee"INCITS 378-2004" 

NPIA/ 17 

6.3 – Use Cases and Table 2 

te More explanation of how to interpret this table would help. 

For example - Whether or not 2 fingers is sufficient for a moderate (or even severe) level identification depends on the size (and quality) of the database(s) being searched, as well as the supporting business processes. 

Expand Use Cases and/ or add additionasupporting text 

FBI/1 13 6.3 Table 2 ed Misplaced information in table. Remove the “/” and the second numeric v
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 2-4 letter abbriviation) 

the “SAP Levels” column. Remove the “/remaining entries in the SAP Levels colu

LM/ 4 6.3 Table 2 te Fingerprint use case 1 (severe/enrollment) uses 10 

fingers, but it’s not immediately clear that the profiles in Table 1 support a 10-finger capture device. I believe the intention of “Number of fingers or images” row in Table 1 for SAP levels 40-60 actually represent slap images rather than single-finger images. 

Clarify content of “Number of fingers or imrow in Table 1. Perhaps adding a “Maximnumber of fingers” row would suffice. 

COGT 4 

6.1 Table 2 te Number of fingers enrolled are proposed to be 6+ and 4+ 

for cases of ‘moderate’ and ‘mild’, respectively. That is, not all 10 fingers are enrolled. Therefore, knowledge of finger position is very important at the time of identification/verification. 

It will be helpful if preferred finger positionenrolment fingers are specified. It is suggthat the number of fingers are evenly divitwo hands. 

COGT 5 

6.1 Table 2 te Number of fingers required for ‘moderate/identification’ is 

4+ while the corresponding ‘number of fingers enrolled’ is 6+. It might be beneficial in terms of usability if the number of fingers required for identification is set to be half of the number of enrolled fingers (3+ in this case) so that it is possible to use fingerprints from one hand for search. 

It is suggested to change 4+ to 3+ in row (moderate/identification). 

L1/ 4 6.3 Table 2 Te Same as L1/3. 

With the advent of zero tolerance policies, DAs won’t prosecute without biometric evidence to verify the identity of a subject in court. Mobile booking (enrolling prints into AFIS databases and retention of demographics and photo) allows cite out of subjects. This is seen by many officers as more important than mobile identification. The requirement to have Appendix F IQS for all enrolls 

Change the SAP level for entry no. 4, MoEnroll, to 35+. Alternative would be to change entry no. Moderate Enroll SAP to 30 and eliminate 
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will add significant size, weight, and cost to mobile devices. PIV quality levels are sufficient for AFIS matching. They are certainly sufficient for biometric verification in court. 

L1/ 8 6.3 Table 2 ed The “SAP Levels” column includes (in some lines) the 

number of finger references. 

Eliminate all but the SAP levels from the labelled “SAP Levels”. 

ITAL /3 6.3 Table 2 Te According to this table, devices with SAP Levels 5 and 10 

are limited to verification only, in non-critical contexts. Our experience is that, using PIV compliant sensors, with a good quality database, it is possible to perform also identification in a law enforcement context (criminal AFIS) with good results. 

The table should be edited so that deviceSAP Levels 10 can also be used for iden

FBI/1 14 6.3 Table 2 Te Insufficient rigor applied to selection of SAP level. Concerning row 3 (and the entire table, re

we have test data that shows an acceptaaccuracy level when performing an AFIS with data from a .8x.8 PIV device? More generally, should we define a target FAR use case and put this in the Notes columwhat is an acceptable accuracy level for escenario)? It seems as though we should applying a more quantitative approach to at the suggested SAP levels, in order to gchosen level more real-world meaning. 

FBI 4 Table 2 te What does “40+ / 10” mean in the SAP levels column? This is used in the first two rows of the ta

without any explanation. Can be left in if meaning and is explained. 

NPIA/ 18 

Table 2 No 9 te If SAP level 5 is not intended for use between systems, 

why insist on using MINEX certified extractors? (see NPIA 16) 
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CMT/13 7 No indication of dynamic range of the camera image 

sensor. From my understanding this as important as the resolution because the camera will be used for outside operations and therefore varying light conditions can be expected. Î recommendation: 60db/10 bit

Recommend dynamic range as; 60db/10 

CMT/14 7 te Is there a requirement to store facial images on device? 

Although the local recording of facial images is not mentioned, it is certainly be implicated by providing the device with memory. 

Explicitly state use case for facial imagesCapture and transmit or is there a capture store on device needed? 

CMT/15 7.1 te It is not clear from the document where the image quality 

check (according to ISO 19794-5 or ANSI/NIST Type-10) has to be done. Internally or externally of the device? 

Need to add Image quality statement in oas done in section 6.1. 

CMT/16 7.1, 8.1 Table 3,4, 5 Ed Title of table font size needs to be enlarged Enlarge font size of title. NPIA/ 19 

7.1 - Overview 

1st sentence 

and bullets 

ed Re-word to clarify the purpose. Suggested text – 

Mobile Identification devices may provide functionality for capturing and / or displayimages for two distinct purposes: 

1 Linking the return information to 

correct subject (e.g. for subseq
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manual verification of identity fofingerprint search) 

2 Mobile Identification (using the f

image to search against a databother facial images) 

NPIA/ 20 

7.2.1 – Focal Length 

2nd sentence ed There is no explanation given as to why the operator 

would want to take images of themselves. 

Add note explaining the value of taking oimages (user authentication, audit trail et

ITAL/ 6 7.2.1 Te If the lens focal length is increased (see previous 

comment) the proposed minimum separation (2 feet) is too low. 

Increase minimum separation as required lens focal length (approx. 1,5 m.). 

CMT/17 7.2.1 Table 3 Te Table 3 specifies a focal length for a lens, which doesn’t 

make sense. Spec states f = 40 to 135 mm and specifies capture distance of 600 to 2000mm. If I pick a 1280 x 1024 array by 5.2 pixels I only get a 60 x 40 mm capture area using a 135mm lens at 2000 mm. What is important for a spec should be what the area to capture on the face and maybe the capture distance. After that, it’s up to the design engineer to chose a sensor and based upon the sensor physical size (e.g., in mm) the magnification required is set, which will set the focal length. In other words, focal length changes based upon sensor size, so focal length shouldn’t be part of the spec. 

This looks like a spec for a 35mm film camera! Need specs for area size to be captured including boarder areas around subject. 

Take focal length out of spec or Is there aresolution spec t others would recommenthe iris and fingerprint specify both opticaelectronic resolutions. Shouldn’t facial haoptical resolution spec? 
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MOT 9 

7.2.3 Te It says camera display rate of 15 fps, with 12 fps 

adequate. It then says "Facial recognition frame rates are typically 5-10 fps". What does that mean? Based on Table 3 under “capture device controls”, the face requirements appear to mean continuous face detection. I realize hardware is always improving, but you are referring to 2010 and right now. Even if we had face detection, most likely it would be more in the realm of 1 to 2 fps. 

Re-define frames per second specificatio

NPIA/ 21 

7.2.6 – Camera Sensitivity 

Last sentence 

te Whether or not images are suitable for facial recognition 

does not directly depend on the sensitivity of the camera. 

Reword final sentence – ‘Images taken ulighting conditions will not normally be of quality for automated facial recognition.’ 

Noblis / 11 

7.2.7 1st para te Recommend citing specific sections and/or paragraphs of 

ANSI/NIST ITL 1-2007 for facial image compression guidelines. 

Cite specific sections and/or paragraphs ANSI/NIST ITL 1-2007 for facial image compression guidelines. 

CMT/18 7.2.3 Table 3 te The frame rate of 12 fps may be used for positioning (as 

proposed in the draft), but probably not for image capturing at full resolution. Although the device is specified for products in 2010, I do have my doubts that somebody would be able to provide a frame rate of 12fps for full resolution (which is about 4 Mega pixel (!!!) for Level 50) 

If it is intended to provide two streams:  for the face detection: min. 3 fps  for live video stream: 10 fps (for VGA resi.e. 640-480)

Noblis / 12 

7.3 1st para ed Strike "This section is included for the purpose of 

compatibility with fingerprints!" 

Strike "This section is included for the pucompatibility with fingerprints!" 

NPIA/ 22 

7.3 – Use Cases 

ed Facial images can be used in situations where 

fingerprints cannot be taken and this should be pointed out in the Use Cases. 

1 Capturing facial images provide

contact form of ID for situations physical contact may not be pos
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practical for whatever reason 

2 Capture of facial images can be 

distance and therefore provides capability for covert mobile ID 

3 Capturing facial images may be 

value than taking fingerprints in circumstances. For example, Cdatabases / watchlists are more contain facial images than finge

L1 / F1 7 Table 3 

(Face) 

Te values for sensor resolution are inconsistent - relax inter-eye distance for level 51 to 3

(twice as many as in level 40) 

- increase relative centering error of level 50% to 72%. - change minimum sensor sizes for levels and 51 to 400x533, 900x1200 and 1800xDelete all other sensor size specifications

NPIA / 23 

Table 3 Sensor 

resolution 

ed Why are two values given for resolution? Explain what the second value means 

BPRA 10 

Face Use Cases 

Table 3 Te X+i: 51? Not 50? 

BPRA 11 

Face Use Cases 

Table 3 Te More poses improve likelihood of a match. Mug shots 

have profile as well as frontal. Number of poses is in the next table, should be here. 

Multiple 2D poses, at least one profile, mboth, maybe 45 degrees? 

BPRA Face Use Table 3 Te Formally an improvement though there are fits and starts 3D? 
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12 Cases in applications. ITAL/ 4 7.3 Table 3 Te A given image size can be obtained with sensors of 

different sizes, mounted in portrait or landscape modes. For example, an image of 768 x 1024 pixel can also be obtained by using a 1280 x 1024 pixel sensor mounted in landscape mode. 

Remove the sensor resolution and the rethat the sensor has to be mounted in portmode. 

ITAL/ 5 7.3 Table 3 Te The proposed minimum focal length of 40 mm (35 mm 

format) is too low (since it’s equivalent to a mild wideangle lens) and this creates radial distorsion of the image. 

The recommended lens focal length shou3 times the sensor diagonal or approx. 90(35 mm format equivalent). See ISO 1979(Annex A, 2.8). 

NPIA/ 24 

Table 3 Relative 

centering error 

ed What does this mean? Add explanation 

FBI/1 15 7.3 Table 3 Te Multiple values for single parameter. Are there supposed to be two values in e

column for sensor resolution? This is consuspect the top numbers should remain, should delete the specs on the bottom. Isets should remain, please label the row reflect what each value represents. 

NPIA/ 25 

Table 4 ed Many of the examples relate to fingerprints Derive examples that are more relevant t

NPIA/ 26 

8 - Iris ed Considerable work still needed! No suggestions at this time! 

L1 / F4 8 various 

locations 

ed The term “iris scan” falsely indicates that capturing an iris 

image involves linear scanning and laser light. 

Replace all occurrences of “iris scan” by image capture”. 

L1 / F2 8 Table 5 (Iris) Te Columns 40 and 51 are incorrectly labelled with respect 

to the user convenience of the devices they describe. The columns should be ranked the other way around, so 

Flip or re-discuss SAP labels. 
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that the device that enables touch-less capture of both irises gets a higher rank than the device that requires a mechanical alignment aid to be held against the subjects forehead. 

Noblis / 13 

8.1 1st para ed Non-sequitur Strike "Iris capture devices have features 

facial capture but with significant differen

- or - Explain the statement in greater detail. 

CMT/19 8.1 ed Take out bookmark error message in second sentence Remove bookmark or link to proper sourcMOT 10 

8.1 ed Error – Reference source is not found Fix error in reference. 

FBI 5 8.1 Ed Reference to table 5 has not been set correctly so an 

error is displayed in bold. 

Set this reference to the correct table. 

CMT/20 8.1 Table 5 te SAP 51 Irradiance 40 w/M2 should have a time limit Add pulse flash with a value for max puls

There should be some caveat stated that an eye safety standard to set an upper bo

CMT/21 8.1 Table 5 te For Level 30 recommendation states 160 pixels. Is 

there a reason why this document should differ from ANSI INCITS 379 that states 150 pixels for Medium Quality? For High Quality they state 200 pixels which matches your Level 40 and 51.

Refer to ANSI INCITS 379 standard 150 level 30 

CMT/22 8.2.2 ed Illumination spelling 

Add the “I” between m&n in Illumination 

CMT/23 8.2.2 te Should refer to the Illumination standards and safety 

specification. 

Refer to IEC 825 and ISO 60825-1 

L1 / F3 8.2.2 Te The infrared light used for iris capture may be visible to Change sentence “The illumination is not 
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the human eye in some cases. range visible to the eye.” to “The illumina

spectral range only partly visible to the hueye.“ 

Noblis / 14 

8.3 1st para ed Strike "This section is included for the purpose of 

compatibility with fingerprints!" 

Strike "This section is included for the pucompatibility with fingerprints!" 

MOT 11 

8.3 Ed Iris section says use cases for “facial capture” not “iris 

capture” 

Should be "...use cases for iris capture...

CMT/24 8.3 Table 5 te Table 5 states an image margin in percentage. 

Percentage of what? Is it percentage of the iris diameter? This border is less than the 70 pixels stated in ANSI INCITS 379-2004. 

Please clarify what the percentage is from

BPRA 13 

Iris Use Cases 

Table 5 Te Newer technologies, but arguably relevant to Mobile ID. 

Capturing from 6 feet may be more manageable than capturing from 18 inches, for instance. 

Iris at a distance? Iris on the move? 

COGT 6 

8.3 Table 5 te The “number of eyes simultaneously captured” is 

proposed to be 2 for both level 40 and level 51. This means that all single-eye capture devices can only be level 30, no matter how good the device is in other features and how many other capabilities the device has. 

While two-eye capture device can have advantages if the quality of the iris images it outputs is as good as its single-eye capture counterpart, the advantages are not significant enough so that this single capability ( “two eyes simultaneously captured” ) can be a differencemaker by itself. Capabilities such as high SNR, larger iris diameter are more critical. Single-eye capture device that can have high performance on critical issues should be classified into higher level 40 or 51. 

It is suggested that “number of eyes simultaneously captured” for all three leveset to >=1. 
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COGT 7 

8.3 Table 5 te This draft does not specify if the output of 2-eye devices 

should be two iris images (one for each eye) or one image which contains two irises. Current requirements imply that both are allowed. 

It is suggested that the document explicitif both kinds of outputs are allowed. 

COGT 8 

8.3 Table 5 te The “capture distance in mm” is proposed to be >=100 for 

level 30, >=200 for level 40 and >=150 for level 51. 

The desired capture distance varies from scenario to scenario. A combination of longer capture distance with smaller capture volume is not necessarily better than a combination of relatively shorter capture distance with bigger capture volume. So long capture distance alone is not a sure characteristic for high end device.

It is suggested that the requirements for tto be changed to 100 for all three levels. 

COGT 9 

8.3 Table 5 te For “image margins left, right / top, bottom of iris border: 

Are these values for maximum? 

Please specify 

CMT/25 8.3 Table 6 Ge Table 6 has no SAP levels and # of eyes indicated Add the following into table 6; 

1) 40+, 2 2) 40+, 2? 3) 40+, 2? 4) 40 + , 2 5) 40 +, 1 6) 30 +, 1 7) 40 +, 2 
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8) 40 +, 1 9) 30 +, 1 

CMT/26 9 te no reason to be Fingerprint specific Need to generalize for other biometrics; fMOT 12 

9 Ed Table 1 only mentions up to 4 fingerprints. This bullet 

mentions from 2 to 10 fingerprints. 

Define what number of fingerprints is acturequired. 

FBI/2 6 

9 Para. 2 ed “differe” should be “differ” 

FBI/2 7 

9 Para. 5 ed First sentence, add “s” to “transaction” 

FBI/2 8 

9 Para. 7 ed Bulleted list, type 10 record to be included if photo 

requested 

Could we add “and available”? 

FBI/1 16 9 Paragraphs Ed Misspelling and punctuation errors. Found additional misspelled (e.g. differe 

identy s/b identity) words and multiple pethe end of sentences. Please run spellingrammar check. 

NPIA/ 27 

9 – Transactions and Replies 

5th paragraph te The para refers to returned responses of fingerprint 

images of the candidate with the highest matching score. In many mobile scenarios, returning fingerprints will provide little operational benefit to the operator. 

However, if facial images are available (either within the database being searched or in one linked to it) returning the facial image of the highest scoring candidate(s) 

Add section on the value of returning faci(where available) in response to finger or searches as well as face searches. 
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provides an effective way of determining whether or not the search has returned a true match. 

NPIA/ 28 

9 – Transactions and Replies 

te This section appears to imply that the transaction will be 

ANSI NIST formatted in both directions. However, the response to a mobile enquiry is more likely to be basic demographic / biographic data (possibly with a facial image if available). It may also include data from intelligence databases, warning flags, medical conditions etc. 

In many cases an ANSI NIST ITL2007 formatted response may not be the most appropriate means of sending the information to the mobile device. 

? 

Noblis / 15 

9 ed Recommend creating subsections for Background (para 

1-5) and Requirements (para 6-11) 

Create subsections for Background (para Requirements (para 6-11) 

Noblis /16 

9 2nd para ed Typo Replace "differe" with "differ" 

FBI/1 2 9 Paragraph 2 ed Incorrect punctuation. Remove second period at end of paragraFBI 6 9 2nd Para ed Extra period at the end of sentence. Remove extra period. MOT 13 

9 Paragraph 2 ed Paragraph ends with 2 periods. Remove double period. 

MOT 14 

9 Paragraph 3 Te What is "a very quick response?" Define desired response time. 

MOT 15 

9 Paragraph 3 ed Should be "issue the driver..." not "issues the drive...." Change to “issue the driver”. 
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Noblis / 17 

9 3rd para ed Subject-verb agreement Replace "issues" with "issue" 

Noblis / 18 

9 3rd para ed Replace "identified terrorists" with "KSTs" Replace "identified terrorists" with "KSTs

MOT 16 

9 Paragraph 5 Te Does the Mobile ID officer really want to perform image 

verification? 

Further define the actual role of the Mobiofficer. 

Noblis / 19 

9 para 6-11 te What is the value add of this text over citing FBI EBTS 

8.002? 

Explain the value added by specifying the record requirements for a fingerprint-baseand fingerprint investigative search requeresponse. 

Noblis / 20 

9 last para ed Non-sequitur. If there are specific requirements for face 

image and/or iris image transactions and responses, specify them. 

Strike "Although the above discussion waregard to fingerprints, the same approach tailored for facial or iris image transactionpredicated on the fact that the receiving acapable of accepting and processing suctransactions." 

BPRA 14 

Security & Encryption 

Te Not inherently about interoperability. Users of Mobile ID 

technology have their own security protocols. Unless we want to specify what interoperability means in the context of possibly incompatible encryption methods, we should not leave this in. 

Why in this document? 

Noblis / 21 

10.1 1st para ed Subject-verb agreement Replace "Law enforcement and criminal j

with "Law enforcement and criminal justic
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FBI/2 9 

10.1 Para. 1 ed Sentence 4, “, however,” is not needed and does not 

make sense. 

Remove “, however,” 

FBI/1 17 10.1 Paragraph 2 Ed Sentence 2 is lengthy and nonsensical. Replace with: This best practices docum

intended to establish awareness of mobilhandheld security problems and to specifpractice" counter measures to defend agthese threats. In addition, this document identify key issues that an IT security mamust address while establishing a comprhandheld security policy. 

NPIA/ 29 

10.2 – Data Encryption 

te What about encryption of the responses? Arguably this is 

more important than encrypting the outgoing message. 

Add section – ‘Incoming Transmissions’ 

FBI/2 10 

10.2 Para. 2 ed Second sentence is run-on and seems to be missing 

something around “...and which issues an IT security manager” 

MOT 17 

10.2.2 Te Currently requires FIPS-140-2, which is only appropriate 

for Transmission encryption. This is incorrect. This should instead require a “Data-At-Rest” encryption product instead of FIPS 140-2. Below is a link to a list of GSA approved Data at Rest (DAR) Encryption methods: http://www.gsa.gov/Portal/gsa/ep/contentView.do?programId=8399&channelId=-18846&ooid=22458&contentId=23207&pageTypeId=8169&contentType=GSA_BASIC&programPage=%2Fep%2Fprogram%2FgsaBasic.jsp&P=SBUY

Include “Data-At-Rest” encryption. 

L1/9 10.3 Te Biometric user authentication and log on should be an Eliminate the words “mobile devices shal

this section and replace it with “mobile de
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option on mobile devices, not a mandatory. The mandatory requirement for user authentication then adds the need to specify the level of algorithm certification and needs to allow finger, face, or iris. This is all very attractive but should be optional. 

may provide capability to”. 

NPIA/ 30 

10.3.1 – User Authentication 

ed The word ‘Operator’ is used elsewhere in the document Agree definitions and consistent terminol

Noblis / 22 

10.3.2 1st para te In addition to alphabetical and numeric characters, allow 

for special characters. 

Replace "alphabetical /numeric character"alphabetic/numeric/special characters" 

NPIA/ 31 

10.3.2 – Biometricand Password 

te Best practice should require 2 factor authentication, 

preferably involving a biometric. 

In many cases, users of such devices will have smartcards, either with or without biometric data on them Perhaps authentication requirements should be linked to SAP level or Use Cases? 

Add note on smartcards. Emphasise use of 2 factor authentication practice. 

NPIA/ 32 

10.3.2 – Biometricand Password But also relevant in 9 - Transactions 

te User level authentication details should accompany the 

transaction – especially if searching multiple databases since not all users may be entitled to get the same (or indeed any) response to a hit on certain individuals held in particular databases. 

This issue is not adequately addressed in document at the moment 
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MOT 18 

10.2.3 Te If you encrypt the application, you will also need to 

decrypt the application to run it. This most likely will create a slow application. 

Remove applications from the sentence. 

MOT 19 

10.3.2 te Are there specifications for the minimum lengths? Define specifications. 

MOT 20 

10.3.3 Te Are there specifications for the designated length of time? Define specifications. 

FBI 7 10.3.3 te Section 10.3.3 and section 10.3.4 seem like the same 

thing to me. 

Combine these two sections into one. 

MOT 21 

10.3.4 te Are there specifications for the designated amount of idle 

time? 

Define specifications. 

L1/10 10.3.4 Te Mobile devices running many OS currently provide an idle 

time re-authentication capability that is built into the OS. It uses a PIN rather than a managed password or biometric log on. 

It is acceptable for CJIS security requirements. 

Reword 10.3.4 to state a dedicated idle tidevice shutoff function may be provided ruser re-authentication. 

MOT 22 

10.3.6 te Are there specifications for the maximum limit of failed 

authentication attempts? 

Define specifications. 

MOT 23 

10.3.8 te Are wireless over-the-air updates of local databases 

required? 

Define specifications. 

FBI/2 11 

10.3.8 Para. 1 ed First sentence, “need” should be “needed” 

Noblis / 10.3.9 1st para te Is the reference to FIPS 201-2 correct? Replace "FIPS 201-2" with "FIPS 140-2" 
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23 BPRA 15 

Communication Protocols 

Wireless Technologies 

Te Doesn’t make a contribution in this context. Not under the 

control of any of us. No impact on the major point of this document, which is to sponsor, urge, and facilitate interoperability at the data exchange level. 

Why in this document? 

CMT/27 11.1 Figure 1 Ed Figure 1 is too small for the detail Enlarge Figure 1 Noblis / 24 

11.2 1st para te Are data rates dependent on the image (or transaction?) 

size or the communication protocol employed? 

Replace: Minimum data rates are dependent on thsize to be transmitted and reasonable limtime of detention. with: Acceptable minimum data rates are depethe transaction size to be transmitted, realimits on time of detention, and the selectcommunication protocol. 

CMT/28 11.3.1 te Document references Cingular, should state AT&T State AT&T instead of Cingular MOT 24 

11.3.1 ed Cingular is now AT&T. Change to AT&T. 
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FBI 8 11.3.1 Figure 1 Te Figure shows database on the capture device. The 

document talks about a database on the capture device and this implies that this is allowed as a best practice when this should really only be a last resort (if then) practice. 

Remove database from capture device in picture. 

L1/11 12 te These are not requirements; they are typical 

expectations. 

Move these to an annex. Retitle to “EnviConditions”. 

ITAL/ 7 12 Te This kind of mobile devices can be used in several 

different environments, such as an office environment (court), a homeland security context such as an airport terminal, a law enforcement environment (a patrol officer on the street) or even a military environment. 

At least 3 different profiles regarding the environmental requirements should be deexample: office, law enforcement, militaryincreasing requirements in terms of operatemperatures, resistance to shock, water etc. Setting these requirements too high wthey are not needed could increase the cdevices and limit their adoption. 

FBI/1 18 12.1 Paragraph 1 Te Incorrect information. 50d C = 122d F CMT/29 12.4 te Need IP level stated Add IP65 for water spray and dust Noblis / 25 

12.4 1st para te Cite more specific requirements or strike 12.4 Cite more specific requirements or strike 

Noblis / 26 

12.5 1st para te Cite more specific requirements or strike 12.5 Cite more specific requirements or strike 

CMT/30 12.5 te Need to state spec or level of vibration and shock Add specification or levl of shock and vib

needed. 

CMT/31 12.6 te Need to state height of drop, Add Mil Spec 810 F- 516.5 26 drops (eac
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and face of device) from 4 ft. onto concre

MOT 25 

12.6 Te Has the "XX" meters been defined? Define specifications. 

FBI/1 3 12.6 Paragraph 1 ed Incorrect punctuation. Remove second period at end of paragraNoblis /27 

13 te Clause 13 offers no concrete guidelines for the use of 

XML. 

Offer concrete guidelines for the use of Xstrike Clause 13 

CMT/32 13 te Intermixing NEIM for NIEM Should state NIEM Noblis / 28 

13 2nd para 2x ed Replace NEIM with NIEM Replace NEIM with NIEM 

MOT 26 

13 Ed "NEIM" should be "NIEM." Change to “NIEM”. 

FBI/1 19 13 Paragraph 2 ed Incorrect acronym. Change all instances of NEIM to NIEM. NPIA/ 33 

13 - XML te The use of XML has implications for data transmission 

size. 

The use of XML may not be appropriate for mobile applications where bandwidth is limited. 

Noblis / 29 

13 2nd para ed Expand 1st use of acronym SIB Expand 1st use of acronym SIB 

L1/12 Annex A te Question was raised as to the purpose of this annex. Consider removing from document. FBI/1 20 A.2 A.2.2 Ed This paragraph is specific to fingerprints, yet the Mobile Remove references to “fingers” and “prin
Title: Comments on: MobileID-BPRS-20080505.pdf Contact: Michael McCabe Date: June 5, 2008 Document: A

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Annex A, 

A.1) 

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NOTE 2 MBs should not change the width of columns, in order to make merging easier. Note 3 Please submit this document in .doc format and NOT .pdf 

ID document is multi-modal in nature. replace them with the generic term “imag

MOT 28 

Annex A 3.2.5 

4 te Currently, finding the core location is difficult when using 

small sensors. 

Re-define statement. 

MOT 29 

Annex A 3.2.9 

te In the 12th bullet, to ensure that sequence errors do not 

occur, you must have Roll-to-Slaps (RTS) to do this properly. 

Re-define statement. 

NPIA/ 34 

A.3.3.3 – Return Data Display 

te This assumes that mobile face recognition units are 

always used in conjunction with a PC and return a line-up of possible matches. 

What about totally mobile handheld devices? Is there a minimum acceptable display size for viewing images? 

Give examples of information which may returned and display requirements for eascenario. 

NPIA/ 35 

A.3.4.1 - Template 

te Why is this limited to the transmission of templates? Include transmission of iris images. 

CMT/ 33 A.3.4 Te Need additional notes for Iris capture Use of sunshields or hoods can facilitate 

capture and reduce the need for high-powillumination sources. Devices without mechanical alignment reframe rates, auto-focus, large capture voand auto-capture. Such devices do not rphysical contact with the subject. Devices with mechanical alignment have imaging and illumination requirements burequire physical contact with the subject. Display of captured images is helpful in thprovides direct feedback to the operator icase that iris image quality is not adequa
Title: Comments on: MobileID-BPRS-20080505.pdf Contact: Michael McCabe Date: June 5, 2008 Document: A

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MB1/ #

(e.g. 

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Paragraph/ 

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Comment (justification for change) by the MB Proposed change by the MB 

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NOTE 2 MBs should not change the width of columns, in order to make merging easier. Note 3 Please submit this document in .doc format and NOT .pdf 

FBI 9 A.5 te Section does not include an idle time power down/off 

feature discussed in section 5. 

Include an idle time power down recommtime. 

CMT/34 A.5.1 ge Sentence not clear State “hot swap” of battery MOT 27 

Annex A A.5.1 

Te What is the required defined length of continuous 

operation without charging? 

Define desired length of time. 

CMT/35 A.5.2 te Charging specification needs to accommodate Military 

vehicles as Humvee. Several Military vehicles use 24 V electric

systems; charge voltage should be increaccommodate this value. 

CMT/36 A.6 te No indication of salt spray certification for navel use. 

Does IP 67 include salt spray? 

MOT 30 

Annex B39 

Paragraph 2 Te How large of a database is being searched for the 5 

minute response time? Is the response time measured from the time of submission to the time a hit/no-hit response is received at the handheld device, including network transmission? 

Define database size and response time measurement. 

FBI/2 12 

B Para. 3 ed Missing word after “resident”? 

MOT 31 

39 Paragraph 4 ed Responses paragraph - "Possible" should be "possible" Change to “possible.” 

MOT 32 

39 Paragraph 6 Te Reporting paragraph - Is any specific content requested 

to be included in the reports? 

Define report requirements. 

CMT/37 Glossary Ge If we define acronyms such as FBI and DHS, I would define the following acronyms used in the spec doc. List all abbreviations/acronyms with their 

in the Glossary. 
Title: Comments on: MobileID-BPRS-20080505.pdf Contact: Michael McCabe Date: June 5, 2008 Document: A

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NOTE 2 MBs should not change the width of columns, in order to make merging easier. Note 3 Please submit this document in .doc format and NOT .pdf 

AFIS, FIPS, NIST, NFIQ, BAP, SAP.

FBI 10 Glossary Ed Include other terms such as EBTS, BAP, 

PIV, NFIQ, FIPS, NEIM . . . 

FBI Federal Bureau of Investigation MOT Motorola ITAL ITALDATA BPRA Bill Long NOBLIS NOBLIS NPIA UK National Police Information Administration TXDPS TX Department of Public Safety CMT Crossmatch LM Lockheed Martin L1 L1 
Title: Comments on: MobileID-BPRS-20080505.pdf Contact: Michael McCabe Date: June 5, 2008 Document: A

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1 MB = Member Body or Organization (enter 2-4 letter abbriviation) 2 Type of comment: ge = minor general Ge = major general te =minor ttechnical Te =major technical ed = minor editorial Ed = major editorial. (Take ca

NOTE 1 Columns 1, 2, 4, 5 and 6 are compulsory. If column 4 is ge, use ge in column two also (and leave column 3 blank) if it applies to the whole document

NOTE 2 MBs should not change the width of columns, in order to make merging easier. Note 3 Please submit this document in .doc format and NOT .pdf