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Before the
Federal Communications Commission
Washington, D.C. 20554
)
)
In the Matter of File No.: EB-10-SE-107
)
Cross Wireless, L.L.C. Acct. No.: 201232100007
)
d/b/a Sprocket Wireless, L.L.C. FRN: 0007258973
)
)
ORDER
Adopted: December 14, 2011 Released: December 14, 2011
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered into
between the Enforcement Bureau ("Bureau") of the Federal
Communications Commission and Cross Wireless, L.L.C. d/b/a Sprocket
Wireless, L.L.C. ("Cross Wireless"). The Consent Decree resolves and
terminates the Bureau's investigation into Cross Wireless's compliance
with sections 20.19(c)(3)(ii) and 20.19(d)(3)(ii) of the Commission's
rules concerning the deployment of digital wireless hearing
aid-compatible handsets. These hearing aid compatibility requirements
serve to ensure that consumers with hearing loss have access to
advanced telecommunications services.
2. The Bureau and Cross Wireless have negotiated the Consent Decree that
resolves this matter. A copy of the Consent Decree is attached hereto
and incorporated herein by reference.
3. After reviewing the terms of the Consent Decree and evaluating the
facts before us, we find that the public interest would be served by
adopting the Consent Decree and terminating the investigation.
4. In the absence of material new evidence relating to this matter, we
conclude that our investigation raises no substantial or material
questions of fact as to whether Cross Wireless possesses the basic
qualifications, including those related to character, to hold or
obtain any Commission license or authorization.
5. Accordingly, IT IS ORDERED that, pursuant to sections 4(i) and 503(b)
of the Communications Act of 1934, as amended, and sections 0.111 and
0.311 of the Commission's rules, the Consent Decree attached to this
Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS
TERMINATED.
7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
shall be sent by first class mail and certified mail, return receipt
requested, to John Chris Ruhl, General Manager, Wireless, Cross
Wireless, L.L.C., P.O. Box 250, Earlsboro, OK 74840-0250, and Pamela
L. Gist, Counsel for Cross Wireless, L.L.C., Lukas, Nace, Gutierrez &
Sachs, L.L.P., 8300 Greensboro Drive, Suite 1200, McLean, VA 22102.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Before the
Federal Communications Commission
Washington, D.C. 20554
)
)
In the Matter of File No.: EB-10-SE-107
)
Cross Wireless, L.L.C. Acct. No.: 201232100007
)
d/b/a Sprocket Wireless, L.L.C. FRN: 0007258973
)
)
CONSENT DECREE
The Enforcement Bureau of the Federal Communications Commission and Cross
Wireless, L.L.C. d/b/a Sprocket Wireless, L.L.C., by their authorized
representatives, hereby enter into this Consent Decree for the purpose of
terminating the Bureau's investigation into possible violations of
sections 20.19(c)(3)(ii) and 20.19(d)(3)(ii) of the Commission's rules
pertaining to the deployment of digital wireless hearing aid-compatible
handsets.
I. DEFINITIONS
1. For the purposes of this Consent Decree, the following definitions
shall apply:
a. "Act" means the Communications Act of 1934, as amended, 47 U.S.C. S:
151 et seq.
b. "Adopting Order" means an order of the Bureau adopting the terms of
this Consent Decree without change, addition, deletion, or
modification.
c. "Bureau" means the Enforcement Bureau of the Federal Communications
Commission.
d. "Commission" and "FCC" mean the Federal Communications Commission and
all of its bureaus and offices.
e. "Communications Laws" means collectively, the Act, the Rules, and the
published and promulgated orders and decisions of the Commission to
which Cross Wireless is subject by virtue of its business activities,
including but not limited to the Hearing Aid Compatibility Rules.
f. "Compliance Plan" means the compliance obligations and compliance
program described in this Consent Decree at paragraph 8.
g. "Covered Employees" means all employees and agents of Cross Wireless
who perform, or supervise, oversee, or manage the performance of,
duties that relate to Cross Wireless's responsibilities under the
Hearing Aid Compatibility Rules.
h. "Cross Wireless" means Cross Wireless, L.L.C. d/b/a Sprocket Wireless,
L.L.C., and its predecessors-in-interest and successors-in-interest.
i. "Effective Date" means the date on which the Bureau releases the
Adopting Order.
j. "Hearing Aid Compatibility Rules" means section 20.19 of the Rules and
other Communications Laws governing digital wireless hearing aid
compatibility, such as the Rules governing the design, selection, or
acquisition of wireless handsets and the marketing or distribution of
such handsets to consumers in the United States.
k. "Investigation" means the investigation commenced by the Bureau's
September 8, 2010 letter of inquiry regarding Cross Wireless's
deployment of digital wireless hearing aid-compatible handsets.
l. "Operating Procedures" means the standard, internal operating
procedures and compliance policies established by Cross Wireless to
implement the Compliance Plan.
m. "Parties" means Cross Wireless and the Bureau, each of which is a
"Party."
n. "Rules" means the Commission's regulations found in Title 47 of the
Code of Federal Regulations.
II. BACKGROUND
2. In the 2003 Hearing Aid Compatibility Order, the Commission adopted
several measures to enhance the ability of consumers with hearing loss
to access digital wireless telecommunications. The Commission
established technical standards for radio frequency interference (the
"M" rating) and inductive coupling (the "T" rating) that digital
wireless handsets must meet to be considered compatible with hearing
aids operating in acoustic coupling and inductive coupling (telecoil)
modes, respectively. For each of these standards, the Commission
further established deadlines by which manufacturers and service
providers were required to offer specified numbers or percentages of
digital wireless handsets per air interface that are compliant with
the relevant standard. In February 2008, as part of a comprehensive
reconsideration of the effectiveness of the Hearing Aid Compatibility
Rules, the Commission released an order that, among other things,
adopted new compatible handset deployment benchmarks.
3. On January 15, 2010, Cross Wireless submitted its annual hearing aid
compatibility status report for the January 1, 2009 to December 31,
2009 reporting period. After reviewing Cross Wireless's status report
for the 2009 reporting period, the Wireless Telecommunications Bureau
referred this matter to the Bureau for investigation and possible
enforcement action. On September 8, 2010, the Bureau's Spectrum
Enforcement Division ("Division") issued the letter of inquiry ("LOI")
to Cross Wireless, directing the company to submit a sworn written
response to a series of questions regarding the company's compliance
with the Hearing Aid Compatibility Rules. Cross Wireless responded to
the LOI on September 29, 2010 ("LOI Response"). In its LOI Response,
Cross Wireless stated that it no longer relies on "second source
suppliers" as its primary provider of digital wireless handsets and
that it has joined the CDMA Associated Carriers Group consortium in
order to maintain a current lineup of handsets. The Bureau and Cross
Wireless executed tolling agreements to toll the statute of
limitations.
III. TERMS OF AGREEMENT
4. Adopting Order. The Parties agree that the provisions of this Consent
Decree shall be subject to final approval by the Bureau by
incorporation of such provisions by reference in the Adopting Order.
5. Jurisdiction. Cross Wireless agrees that the Bureau has jurisdiction
over it and the matters contained in this Consent Decree and that the
Bureau has the authority to enter into and adopt this Consent Decree.
6. Effective Date; Violations. The Parties agree that this Consent
Decree shall become effective on the Effective Date as defined herein.
As of the Effective Date, the Adopting Order and this Consent Decree
shall have the same force and effect as any other order of the
Commission. Any violation of the Adopting Order or of the terms of
this Consent Decree shall constitute a separate violation of a
Commission order, entitling the Commission to exercise any rights and
remedies attendant to the enforcement of a Commission order.
7. Termination of Investigation. In express reliance on the covenants
and representations in this Consent Decree and to avoid further
expenditure of public resources, the Bureau agrees to terminate the
Investigation. In consideration for the termination of the
Investigation, Cross Wireless agrees to the terms, conditions, and
procedures contained herein. The Bureau further agrees that in the
absence of new material evidence, the Bureau will not use the facts
developed in this Investigation through the Effective Date, or the
existence of this Consent Decree, to institute on its own motion any
new proceeding, formal or informal, or take any action on its own
motion against Cross Wireless concerning the matters that were the
subject of the Investigation. The Bureau also agrees that in the
absence of new material evidence it will not use the facts developed
in the Investigation through the Effective Date, or the existence of
this Consent Decree, to institute on its own motion any proceeding,
formal or informal, or take any action on its own motion against Cross
Wireless with respect to Cross Wireless's basic qualifications,
including its character qualifications, to be a Commission licensee or
to hold Commission licenses or authorizations.
8. Compliance Plan. For purposes of settling the matters set forth
herein, Cross Wireless agrees that it shall within sixty (60) calendar
days after the Effective Date, develop and implement a Compliance Plan
to help ensure future compliance with the Communications Laws,
including the Hearing Aid Compatibility Rules, and with the terms and
conditions of this Consent Decree. The Compliance Plan shall include,
without limitation, the following components:
a. Compliance Officer. Within thirty (30) calendar days after the
Effective Date, Cross Wireless shall designate a senior corporate
manager with the requisite corporate and organizational authority to
serve as Compliance Officer and to discharge the duties set forth
below. The person designated as the Compliance Officer shall be
responsible for developing, implementing, and administering the
Compliance Plan and ensuring that Cross Wireless complies with the
terms and conditions of the Compliance Plan and this Consent Decree.
In addition to the general knowledge of the Communications Laws
necessary to discharge his/her duties under this Consent Decree, the
Compliance Officer shall have specific knowledge of the Hearing Aid
Compatibility Rules prior to assuming his/her duties.
b. Operating Procedures on Hearing Aid Compatibility. Within sixty (60)
calendar days after the Effective Date, Cross Wireless shall establish
Operating Procedures that all Covered Employees must follow to help
ensure Cross Wireless's compliance with the Hearing Aid Compatibility
Rules. Cross Wireless's Operating Procedures shall include internal
procedures and policies specifically designed to ensure that Cross
Wireless offers the requisite number or percentage of hearing
aid-compatible digital wireless handsets to consumers as required by
the Hearing Aid Compatibility Rules. Cross Wireless also shall develop
a Compliance Checklist that describes the steps that a Covered
Employee must follow to ensure that the inclusion of a new handset
model, or discontinuance of an existing handset offering, will not
result in a violation of the Commission's digital wireless hearing
aid-compatible handset deployment requirements. At a minimum, the
Compliance Checklist shall require Covered Employees to use the
Commission's equipment authorization database to verify the hearing
aid compatibility rating of each existing and proposed handset
offering.
c. Compliance Manual. Within sixty (60) calendar days after the
Effective Date, the Compliance Officer shall develop and distribute a
Compliance Manual to all Covered Employees. The Compliance Manual
shall explain the Hearing Aid Compatibility Rules and set forth the
Operating Procedures that Covered Employees shall follow to help
ensure Cross Wireless's compliance with the Hearing Aid Compatibility
Rules. Cross Wireless shall periodically review and revise the
Compliance Manual as necessary to ensure that the information set
forth therein remains current and complete. Cross Wireless shall
distribute any revisions to the Compliance Manual promptly to all
Covered Employees.
d. Compliance Training Program. Cross Wireless shall establish and
implement a Compliance Training Program on compliance with the Hearing
Aid Compatibility Rules and the Operating Procedures. As part of the
Compliance Training Program, Covered Employees shall be advised of
Cross Wireless's obligation to report any noncompliance with the
Hearing Aid Compatibility Rules under paragraph 9 of this Consent
Decree and shall be instructed on how to disclose noncompliance to the
Compliance Officer. All Covered Employees shall be trained pursuant to
the Compliance Training Program within sixty (60) calendar days after
the Effective Date, except that any person who becomes a Covered
Employee at any time after the Effective Date shall be trained within
thirty (30) calendar days after the date such person becomes a Covered
Employee. Cross Wireless shall repeat the compliance training on an
annual basis, and shall periodically review and revise the Compliance
Training Program as necessary to ensure that it remains current and
complete and to enhance its effectiveness.
e. Consumer Outreach. Cross Wireless shall periodically advertise the
availability of hearing aid-compatible digital wireless handsets to
ensure that all of its retail customers are aware of its hearing
aid-compatible digital wireless handset offerings.
f. Termination Date. Unless stated otherwise, the requirements of this
paragraph 8 of the Consent Decree shall expire twenty-four (24) months
after the Effective Date.
9. Reporting Noncompliance. Cross Wireless shall report any noncompliance
with the Hearing Aid Compatibility Rules and with the terms and
conditions of this Consent Decree within fifteen (15) calendar days
after discovery of such noncompliance. Such reports shall include a
detailed explanation of (i) each instance of noncompliance; (ii) the
steps that Cross Wireless has taken or will take to remedy such
noncompliance; (iii) the schedule on which such remedial actions will
be taken; and (iv) the steps that Cross Wireless has taken or will
take to prevent the recurrence of any such noncompliance. All reports
of noncompliance shall be submitted to the Chief, Spectrum Enforcement
Division, Enforcement Bureau, Federal Communications Commission, Room
3-C366, 445 12th Street, S.W. Washington, D.C. 20554, with a copy
submitted electronically to Kevin Pittman at Kevin.Pittman@fcc.gov and
to Pamera Hairston at Pamera.Hairston@fcc.gov. The reporting
obligations set forth in this paragraph 9 shall expire twenty-four
(24) months after the Effective Date.
10. Compliance Reports. Cross Wireless shall file Compliance Reports with
the Commission ninety (90) calendar days after the Effective Date,
twelve (12) months after the Effective Date, and twenty-four (24)
months after the Effective Date.
a. Each compliance report shall include a detailed description of Cross
Wireless's efforts during the relevant period to comply with the terms
and conditions of this Consent Decree and the Hearing Aid
Compatibility Rules. In addition, each Compliance Report shall include
a certification by the Compliance Officer, as an agent of and on
behalf of Cross Wireless, stating that the Compliance Officer has
personal knowledge that Cross Wireless (i) has established and
implemented the Compliance Plan; (ii) has utilized the Operating
Procedures since the implementation of the Compliance Plan; and (iii)
is not aware of any instances of noncompliance with the terms and
conditions of this Consent Decree, including the reporting obligations
set forth in paragraph 9 hereof.
b. The Compliance Officer's certification shall be accompanied by a
statement explaining the basis for such certification and must comply
with section 1.16 of the Rules and be subscribed to as true under
penalty of perjury in substantially the form set forth therein.
c. If the Compliance Officer cannot provide the requisite certification,
the Compliance Officer, as an agent of and on behalf of Cross
Wireless, shall provide the Commission with a detailed explanation of
the reason(s) why and describe fully (i) each instance of
noncompliance; (ii) the steps that Cross Wireless has taken or will
take to remedy such noncompliance, including the schedule on which
proposed remedial actions will be taken; and (iii) the steps that
Cross Wireless has taken or will take to prevent the recurrence of any
such noncompliance, including the schedule on which such preventive
action will be taken.
d. All Compliance Reports shall be submitted to the Chief, Spectrum
Enforcement Division, Enforcement Bureau, Federal Communications
Commission, 445 12th Street, S.W., Washington, D.C. 20554, with a copy
submitted electronically to Kevin Pittman at Kevin.Pittman@fcc.gov and
to Pamera Hairston at Pamera.Hairston@fcc.gov.
11. Section 208 Complaints; Subsequent Investigations. Nothing in this
Consent Decree shall prevent the Commission or its delegated authority
from adjudicating complaints filed pursuant to section 208 of the Act
against Cross Wireless or its affiliates for alleged violations of the
Act, or for any other type of alleged misconduct, regardless of when
such misconduct took place. The Commission's adjudication of any such
complaints will be based solely on the record developed in that
proceeding. Except as expressly provided in this Consent Decree, this
Consent Decree shall not prevent the Commission from investigating new
evidence of noncompliance by Cross Wireless with the Communications
Laws.
12. Voluntary Contribution. Cross Wireless agrees that it will make a
voluntary contribution to the United States Treasury in the amount of
fifty thousand dollars ($50,000). The payment must be made within
thirty (30) calendar days after the Effective Date. The payment must
be made by check or similar instrument, payable to the order of the
Federal Communications Commission. The payment must include the
Account Number and FRN referenced in the caption to the Adopting
Order. Payment by check or money order may be mailed to Federal
Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.
Payment by overnight mail may be sent to U.S. Bank - Government
Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
63101. Payment by wire transfer may be made to ABA Number 021030004,
receiving bank TREAS/NYC, and Account Number 27000001. For payment by
credit card, an FCC Form 159 (Remittance Advice) must be submitted.
When completing the FCC Form 159, enter the Account Number in block
number 23A (call sign/other ID) and enter the letters "FORF" in block
number 24A (payment type code). Cross Wireless shall also send
electronic notification to Kevin Pittman at Kevin.Pittman@fcc.gov,
Pamera Hairston at Pamera.Hairston@fcc.gov, and Samantha Peoples at
Sam.Peoples@fcc.gov on the date said payment is made.
13. Waivers. Cross Wireless waives any and all rights it may have to seek
administrative or judicial reconsideration, review, appeal, or stay,
or to otherwise challenge or contest the validity of this Consent
Decree and the Adopting Order, provided the Bureau issues an Adopting
Order as defined herein. Cross Wireless shall retain the right to
challenge Commission interpretation of the Consent Decree or any terms
contained herein. If either Party (or the United States on behalf of
the Commission) brings a judicial action to enforce the terms of the
Adopting Order, neither Cross Wireless nor the Commission shall
contest the validity of the Consent Decree or of the Adopting Order,
and Cross Wireless shall waive any statutory right to a trial de novo.
Cross Wireless hereby agrees to waive any claims it may have under the
Equal Access to Justice Act, 5 U.S.C. S: 504 and 47 C.F.R. S: 1.1501
et seq., relating to the matters addressed in this Consent Decree.
14. Invalidity. In the event that this Consent Decree in its entirety is
rendered invalid by any court of competent jurisdiction, it shall
become null and void and may not be used in any manner in any legal
proceeding.
15. Subsequent Rule or Order. The Parties agree that if any provision of
the Consent Decree conflicts with any subsequent Rule or order adopted
by the Commission (except an order specifically intended to revise the
terms of this Consent Decree to which Cross Wireless does not
expressly consent) that provision will be superseded by such Rule or
Commission order.
16. Successors and Assigns. Cross Wireless agrees that the provisions of
this Consent Decree shall be binding on its successors, assigns, and
transferees.
17. Final Settlement. The Parties agree and acknowledge that this Consent
Decree shall constitute a final settlement between the Parties with
respect to the Investigation. The Parties further agree that this
Consent Decree does not constitute either an adjudication on the
merits or a factual or legal finding or determination regarding any
compliance or noncompliance with the requirements of the
Communications Laws.
18. Modifications. This Consent Decree cannot be modified without the
advance written consent of both Parties.
19. Paragraph Headings. The headings of the paragraphs in this Consent
Decree are inserted for convenience only and are not intended to
affect the meaning or interpretation of this Consent Decree.
20. Authorized Representative. The individual signing this Consent Decree
on behalf of Cross Wireless represents and warrants that he is
authorized by Cross Wireless to execute this Consent Decree and to
bind Cross Wireless to the obligations set forth herein. The FCC
signatory represents that she is signing this Consent Decree in her
official capacity and that she is authorized to execute this Consent
Decree.
21. Counterparts. This Consent Decree may be signed in any number of
counterparts (including by facsimile), each of which, when executed
and delivered, shall be an original, and all of which counterparts
together shall constitute one and the same fully executed instrument.
________________________________
P. Michele Ellison
Chief
Enforcement Bureau
________________________________
Date
________________________________
John Chris Ruhl
General Manager, Wireless
Cross Wireless, L.L.C.
________________________________
Date
47 C.F.R. S: 20.19(c)(3)(ii), (d)(3)(ii).
47 U.S.C. S:S: 154(i), 503(b).
47 C.F.R. S:S: 0.111, 0.311.
47 C.F.R. S: 20.19(c)(3)(ii), (d)(3)(ii).
Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
Enforcement Bureau, Federal Communications Commission, to John C. Ruhl,
General Manager, Cross Wireless, L.L.C. (Sept. 8, 2010).
The Commission adopted these requirements for digital wireless telephones
under the authority of the Hearing Aid Compatibility Act of 1988, codified
at section 710(b)(2)(C) of the Act, 47 U.S.C. S: 610(b)(2)(C). See Section
68.4(a) of the Commission's Rules Governing Hearing Aid-Compatible
Telephones, Report and Order, 18 FCC Rcd 16753, 16787 P: 89 (2003);
Erratum, 18 FCC Rcd 18047 (2003) ("Hearing Aid Compatibility Order");
Order on Reconsideration and Further Notice of Proposed Rulemaking, 20 FCC
Rcd 11221 (2005).
As subsequently amended, section 20.19(b)(1) provides that, for the period
beginning June 6, 2008 and ending December 31, 2009, a newly certified
wireless handset is deemed hearing aid-compatible for radio frequency
interference if, at minimum, it meets the M3 rating associated with the
technical standard set forth in either the standard document "American
National Standard Methods of Measurement of Compatibility between Wireless
Communication Devices and Hearing Aids," ANSI C63.19-2006 (June 12, 2006)
or ANSI C63.19-2007 (June 8, 2007). Beginning January 1, 2010, a newly
certified handset must meet at least an M3 rating under ANSI C63.19-2007
to be considered hearing aid-compatible for radio frequency interference.
47 C.F.R. S: 20.19(b)(1). Section 20.19(b)(2) provides that, for the
period beginning June 6, 2008 and ending December 31, 2009, a newly
certified wireless handset is deemed hearing aid-compatible for inductive
coupling if, at minimum, it meets the T3 rating associated with the
technical standard as set forth in ANSI C63.19-2006 or ANSI C63.19-2007,
and beginning January 1, 2010, it is deemed hearing aid-compatible for
inductive coupling if it meets at least a T3 rating under ANSI
C63.19-2007. 47 C.F.R. S: 20.19(b)(2). Grants of certification issued
before June 6, 2008, under previous versions of ANSI C63.19 remain valid
for hearing aid compatibility purposes.
The term "air interface" refers to the technical protocol that ensures
compatibility between mobile radio service equipment, such as handsets,
and the service provider's base stations. Currently, the leading air
interfaces include Code Division Multiple Access ("CDMA"), Global System
for Mobile Communications ("GSM"), Integrated Digital Enhanced Network
("iDEN") and Wideband Code Division Multiple Access ("WCDMA") a/k/a
Universal Mobile Telecommunications System ("UMTS").
See Hearing Aid Compatibility Order, 18 FCC Rcd at 16780 P: 65; 47 C.F.R.
S: 20.19(c), (d).
See Amendment of the Commission's Rules Governing Hearing Aid-Compatible
Mobile Handsets, First Report and Order, 23 FCC Rcd 3406 (2008) ("Hearing
Aid Compatibility First Report and Order"), Order on Reconsideration and
Erratum, 23 FCC Rcd 7249 (2008) ("Order on Reconsideration and Erratum").
These handset deployment requirements do not apply to service providers
and manufacturers that meet the de minimis exception. The de minimis
exception provides that manufacturers or mobile service providers that
offer two or fewer digital wireless handset models per air interface are
exempt from the hearing aid compatibility requirements, and manufacturers
or service providers that offer three digital wireless handset models per
air interface must offer at least one compliant model. 47 C.F.R. S:
20.19(e). Effective September 10, 2012, the de minimis exception will not
be available to manufacturers or mobile service providers that do not meet
the definition of a "small entity" beginning two years after their initial
offerings. 47 C.F.R. S: 20.19(e)(1)(ii); see also Amendment of the
Commission's Rules Governing Hearing Aid-Compatible Mobile Handsets,
Policy Statement and Second Report and Order and Further Notice of
Proposed Rulemaking, 25 FCC Rcd 11167, 11180-11189 P:P: 35-59 (2010)
("Hearing Aid Compatibility Second Report and Order").
See Cross Wireless, L.L.C., Hearing Aid Compatibility Report, Docket No.
07-250 (Jan. 15, 2010), available at
http://wireless.fcc.gov/hac_documents/100317/Cross%20Wireless,%20L.L._221.PDF.
On January 15, 2010, Cross Wireless submitted a hearing aid compatibility
status report under its "Sprocket Wireless" trade name. This status report
was inadvertently filed under the name "Sprocket Wireless, Inc." See
Sprocket Wireless, Inc. Hearing Aid Compatibility Status Report, Docket
No. 07-250 (Jan. 15, 2010), available at
http://wireless.fcc.gov/hac_documents/100317/Sprocket%20Wireless,%20I_234.PDF.
See supra note 2.
See Letter from Pamela L. Gist, Esq., Lukas, Nace, Gutierrez & Sachs,
L.L.P., Counsel for Cross Wireless, L.L.C., to Marlene H. Dortch,
Secretary, Federal Communications Commission (Sept. 28, 2010).
LOI Response at 5.
See e.g., Tolling Agreement Extension, File No. EB-10-SE-107, executed by
and between John D. Poutasse, Acting Chief, Spectrum Enforcement Division,
Enforcement Bureau, Federal Communications Commission, and Chris Ruhl,
Wireless General Manager, Cross Wireless, L.L.C. (Aug. 31, 2011).
47 C.F.R. S: 1.16.
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