Save WiFi/Questions

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What questions do we have for the FCC? We will be meeting with them soon (awaiting confirmation on date). Let's work together to craft them below. All meeting minutes will be filed according to Sunshine laws.


That 4(i) of §2.1033 (80 FR 46919) and 8(e) of think our first goal with these questions is to make sure that the FCC acknowledges that it the rules as they are written are mandating proprietary software at a national level. The way they have gone about doing this is bad, not only as a matter of liberty, but it is also a matter of both individual and national security. Firs tand foremost, we need them to acknowledge and confirm for us that they understand the implications of the rules they have proposed.

System Software definition and framing

Throughout this document we will use the term System Software to refer to software that controls the radio or other parameters subject to the Commission's rules.


The Commission proposes new rules that will require an applicant for certification to describe the RF device's capabilities for software configuration and upgradeability in the application for certification (Paragraph 46). Such a description would include how the System Software may control the frequency bands, power levels, modulation types, or other modes of operation for which the device is designed to operate, including modes not enabled in the device as initially marketed. However, depending on the configuration of the computer hardware in question, the System Software used to control the RF device, may also have the ability to control and access other parts of the computer unrelated to the RF-device, including the CPU or other processors on the computer as well as system memory (RAM, cache, drives, et al).


ability to access and transmit user information

  • Does the Commission acknowledge that the System Software software may

have the ability to access the user's private information stored on the computer?

  • Does the Commission acknolwedge that such System Software may also be

designed to transmit the private information of the user via the RF device, such as over Wifi or Bluetooth, with or without the user's knowledge?

end-user or owner not an authorized party by default

The commission states that "an applicant for certification would have to specify which parties will be authorized to make software changes (e.g., the grantee, wireless service provider, other authorized parties) and the software controls that are provided to prevent unauthorized parties from enabling different modes of operation."

Does the Commission acknowledge that the end-user and owner of a device may not, by default, be considered an authorized party that will be able to install new System Software onto the computing device?

unable to replace or change the software on device ever

Does the Commission acknowledge that since the device is designed to to only run software that is authorized by a party that is not the owner or end-user, that the end-user may, in some cases, be unable to ever replace or change the software on the device?

no requirement on user controlling software updates

Does the Commission acknowledge that, while only authorized parties would be allowed to provide new software to be updated, that the Commission has not put in place any requirements that it **must** be at the choice of the end-user or purchaser of a product to decide **if** new software will be installed on the device?

authorized parties not bound by US law

Does the Commission acknowledge that it may, in some cases, be the case that the only authorized parties listed and able to install new System Software are companies not located in the United States and that are otherwise not required to abide by the laws of the United States?

remote control of device

Does the Commission acknowledge that because the System Software may have the ability to conrol the wireless capabilities of the device that the System Software may be designed to connect and share information, or even allow for the authorized party to be able to effectively remotely control the device without the user's knowledge or consent, when that device has connected to the Internet or a local area network for which the RF device is designed to interact with?

control of authorized parties

Does the Commission acknowledge that the authorized parties may be corporations that may be controlled or may eventually be acquired by other companies, governments, or foreign entities?

authorized parties may disappear

Does the Commission acknowledge that authorized parties may sieze to exist and therefore it may be the case that an individual may never be able to update the computer again?

authorized parties compromised

Does the Commission acknowledge that authorized parties based outside of the United States may be compelled by their local governments or other entities to share the means or methods for providing software updates for authorized equipement?

computing device may contain private or secret information

Does the Commission acknowledge that the computing devices maybe purchased by officials within all branches of state and local Governments which may or may not be using the computing devices for viewing or producing confidential information including, but not limited to, secret information and private medical information?