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Re: Headphones

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Macy monkeys

Re: Headphones

If the manual says the headphone must accept any interference, I doubt Bose will do much.

John K7FD

> On May 9, 2020, at 1:32 PM, Mark Goldberg <[hidden email]> wrote:
>
> Have you contacted Bose? They are FCC part 15 and even say this in the user
> manual:
>
> This device complies with part 15 of the FCC Rules and with Industry Canada
> license-exempt RSS standard(s).
> Operation is subject to the following two conditions: (1) This device may
> not cause harmful interference, and (2) this
> device must accept any interference received, including interference that
> may cause undesired operation.
>
> I think it is incumbent upon them to make them work.
>
> I know they have the capability. Their aircraft headsets have to operate in
> very similar conditions. Aircraft have HF radios.
>
> I operate a station in our small RV with a KPA500 and a collection of other
> electronics and bluetooth devices, with good bonding and ferrites in
> hopefully the right places. Everything works with no issues.
>
> 73,
>
> Mark
> W7MLG
>
>> On Sat, May 9, 2020 at 11:47 AM John Reilly <[hidden email]> wrote:
>>
>> FWIW, I bought a pair of the Bose 700 headphones, and I'm NOT happy.
>> They are very susceptible to RF, especially on 40 and 80m. They make
>> their system "bong" sound when I transmit. I have tried several toroid
>> chokes, even one close to the ear piece -- no help. On 40m, I have the
>> problem at power levels ranging from 5 to 1200 w. Too bad, they fit and
>> sound great.
>> - John, N0TA
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Phil Kane-2

Re: Headphones

In reply to this post by Mark Goldberg

On 5/9/2020 1:32 PM, Mark Goldberg wrote:

> Have you contacted Bose? They are FCC part 15 and even say this in the user
> manual:

> (2) this device must accept any interference received, including
> interference that may cause undesired operation.
Part 15 deals with *generating* unwanted RF (i.e. causing interference).
It has nothing to do with acceptability to external RF causing
malfunction. The excerpt that you posted is very clear on that point.

73 de K2ASP - Phil Kane
Elecraft K2/100 s/n 5402

From a Clearing in the Silicon Forest
Beaverton (Washington County) Oregon
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Nr4c

Re: Headphones

Beg to differ. Part 15 devices have no legal protection from interference. You use at your own risk.

Sent from my iPhone
...nr4c. bill

> On May 9, 2020, at 9:49 PM, Phil Kane <[hidden email]> wrote:
>
> On 5/9/2020 1:32 PM, Mark Goldberg wrote:
>
>> Have you contacted Bose? They are FCC part 15 and even say this in the user
>> manual:
>
>> (2) this device must accept any interference received, including
>> interference that may cause undesired operation.
> Part 15 deals with *generating* unwanted RF (i.e. causing interference).
> It has nothing to do with acceptability to external RF causing
> malfunction. The excerpt that you posted is very clear on that point.
>
> 73 de K2ASP - Phil Kane
> Elecraft K2/100 s/n 5402
>
> From a Clearing in the Silicon Forest
> Beaverton (Washington County) Oregon
> ______________________________________________________________
> Elecraft mailing list
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Phil Kane-2

Re: Headphones

On 5/9/2020 7:08 PM, Nr4c wrote:

> Beg to differ. Part 15 devices have no legal protection from
interference. You use at your own risk.

That's what I said. We deal with that professionally.

>> (2) this device must accept any interference received, including
>>> interference that may cause undesired operation.--

Philip M. Kane Esq / P.E. - K2ASP
VP - General Counsel & Executive Engineer
CSI Telecommunications, Inc. - Consulting Engineers
San Francisco, CA - Beaverton, OR
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Jim Brown-10

Re: Headphones

In reply to this post by Nr4c

On 5/9/2020 7:08 PM, Nr4c wrote:
> Beg to differ.

Ummm, K2ASP is a retired FCC inspector. Now works as a consultant to
those who need help with communications systems issues. I think we can
take anything he says to the bank. :)

73, Jim K9YC
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Mark Goldberg

Re: Headphones

In reply to this post by Phil Kane-2

I do want to understand what "must accept" means. Why did the FCC put #2 in
there?

I'm from the avionics industry. We have to not produce unwanted RF
interference and we have to operate correctly in the presence of high
levels of RF. Especially in recent years, someone could put their phone
down on top of your unit and subject it to huge fields. We test in fields
of hundreds of volts per meter and have to work.

My products also have to work with 4V of ripple on the power input with no
effect.

Bose knows how to design for these environments. I was on regulatory
committees with people from Bose and they were very sharp. So, if they are
not obligated to fix this, I was just suggesting that they still might if
contacted and that they have the knowledge to fix it.

73,

Mark
W7MLG

On Sat, May 9, 2020 at 8:06 PM Phil Kane <[hidden email]> wrote:

> On 5/9/2020 7:08 PM, Nr4c wrote:
>
> > Beg to differ. Part 15 devices have no legal protection from
> interference. You use at your own risk.
>
> That's what I said. We deal with that professionally.
>
> >> (2) this device must accept any interference received, including
> >>> interference that may cause undesired operation.--
>
> Philip M. Kane Esq / P.E. - K2ASP
> VP - General Counsel & Executive Engineer
> CSI Telecommunications, Inc. - Consulting Engineers
> San Francisco, CA - Beaverton, OR
> ______________________________________________________________
> Elecraft mailing list
> Home: http://mailman.qth.net/mailman/listinfo/elecraft
> Help: http://mailman.qth.net/mmfaq.htm
> Post: mailto:[hidden email]
>
> This list hosted by: http://www.qsl.net
> Please help support this email list: http://www.qsl.net/donate.html
> Message delivered to [hidden email]
>

Dave Sublette-2

Re: Headphones

The answer to your question seems obvious to me. I am not a lawyer. Your
equipment had to operate too much more stringent requirements because human
life is at stake. The part 15 "must accept" clause says that if you are
being interfered with on your Part 15 device, is it not legal grounds to
award damages in a court case. It won't keep someone from from filing a
suit. But without that clause we hams might be hauled into court by every
one who is interfered with. We have been, but Part 15 has kept the
practice from proliferating. Devices sold under part 15 are not used in
situations where human life is at stake. Well they probably are, but are
not designed specifically to operate that way as are aircraft radio and
navigation systems.

In addition, the "must accept" clause releases hams from the legal and
financial obligations to correct the problem. I should think that it also
releases the manufacturer from that also.

I'm not a lawyer. It's just my take on it.

73,

Dave, K4TO

On Sat, May 9, 2020 at 11:38 PM Mark Goldberg <[hidden email]>
wrote:

> I do want to understand what "must accept" means. Why did the FCC put #2 in
> there?
>
> I'm from the avionics industry. We have to not produce unwanted RF
> interference and we have to operate correctly in the presence of high
> levels of RF. Especially in recent years, someone could put their phone
> down on top of your unit and subject it to huge fields. We test in fields
> of hundreds of volts per meter and have to work.
>
> My products also have to work with 4V of ripple on the power input with no
> effect.
>
> Bose knows how to design for these environments. I was on regulatory
> committees with people from Bose and they were very sharp. So, if they are
> not obligated to fix this, I was just suggesting that they still might if
> contacted and that they have the knowledge to fix it.
>
> 73,
>
> Mark
> W7MLG
>
> On Sat, May 9, 2020 at 8:06 PM Phil Kane <[hidden email]> wrote:
>
> > On 5/9/2020 7:08 PM, Nr4c wrote:
> >
> > > Beg to differ. Part 15 devices have no legal protection from
> > interference. You use at your own risk.
> >
> > That's what I said. We deal with that professionally.
> >
> > >> (2) this device must accept any interference received, including
> > >>> interference that may cause undesired operation.--
> >
> > Philip M. Kane Esq / P.E. - K2ASP
> > VP - General Counsel & Executive Engineer
> > CSI Telecommunications, Inc. - Consulting Engineers
> > San Francisco, CA - Beaverton, OR
> > ______________________________________________________________
> > Elecraft mailing list
> > Home: http://mailman.qth.net/mailman/listinfo/elecraft
> > Help: http://mailman.qth.net/mmfaq.htm
> > Post: mailto:[hidden email]
> >
> > This list hosted by: http://www.qsl.net
> > Please help support this email list: http://www.qsl.net/donate.html
> > Message delivered to [hidden email]
> >
> ______________________________________________________________
> Elecraft mailing list
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Gwen Patton

Re: Headphones

It's clear that if you are the one with the Part 15 device, and someone
else interferes with that device, because of the law you have to just suck
it up because Part 15 devices aren't made to be "hardened" against
interference to the same degree other devices under different parts of the
law might be. But it's not commutative -- just because the Part 15 device
"must accept" interference doesn't mean that owners of other devices under
different parts of the law "must accept" interference FROM Part 15 devices.
It's not a case of *modus ponens*, where if A implies B, then B implies A.

So if I have a case of a Part 15 device causing spurious signals on my HF
station, then the Part 15 manufacturer should DEFINITELY be informed, since
while they must accept interference from my HF station on their headphones,
I do NOT have to accept interference on my HF station FROM their
headphones. They have to keep their spurious radiation in bands operated by
other services within the specifications. This is why there can be FCC
enforcement procedures against grow lamp manufacturers and wall wart
manufacturers because of interference in Amateur bands generated by those
consumer devices. The attached FCC bulletin would seem to corroborate my
understanding.

So would this paragraph from the ARRL site on FCC Enforcement Actions
specifically about Part 15 devices interfering with amateur operations: *"The
FCC Part 15 regulations are clear that the manufacturers of unlicensed
devices must meet the appropriate conducted - or radiated-emissions
requirements and that the operators of those devices are responsible for
resolving any harmful interference to radio services that might occur from
their use."*

IANAL, and I didn't stay at a Holiday Inn Express last night.

https://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet63/oet63rev.pdf

-=-=-=-=-=-=-=-=-
73,
Gwen, NG3P

On Sun, May 10, 2020 at 7:27 AM Dave Sublette <[hidden email]> wrote:

> The answer to your question seems obvious to me. I am not a lawyer. Your
> equipment had to operate too much more stringent requirements because human
> life is at stake. The part 15 "must accept" clause says that if you are
> being interfered with on your Part 15 device, is it not legal grounds to
> award damages in a court case. It won't keep someone from from filing a
> suit. But without that clause we hams might be hauled into court by every
> one who is interfered with. We have been, but Part 15 has kept the
> practice from proliferating. Devices sold under part 15 are not used in
> situations where human life is at stake. Well they probably are, but are
> not designed specifically to operate that way as are aircraft radio and
> navigation systems.
>
> In addition, the "must accept" clause releases hams from the legal and
> financial obligations to correct the problem. I should think that it also
> releases the manufacturer from that also.
>
> I'm not a lawyer. It's just my take on it.
>
> 73,
>
> Dave, K4TO
>
>
>
> On Sat, May 9, 2020 at 11:38 PM Mark Goldberg <[hidden email]>
> wrote:
>
> > I do want to understand what "must accept" means. Why did the FCC put #2
> in
> > there?
> >
> > I'm from the avionics industry. We have to not produce unwanted RF
> > interference and we have to operate correctly in the presence of high
> > levels of RF. Especially in recent years, someone could put their phone
> > down on top of your unit and subject it to huge fields. We test in fields
> > of hundreds of volts per meter and have to work.
> >
> > My products also have to work with 4V of ripple on the power input with
> no
> > effect.
> >
> > Bose knows how to design for these environments. I was on regulatory
> > committees with people from Bose and they were very sharp. So, if they
> are
> > not obligated to fix this, I was just suggesting that they still might if
> > contacted and that they have the knowledge to fix it.
> >
> > 73,
> >
> > Mark
> > W7MLG
> >
> > On Sat, May 9, 2020 at 8:06 PM Phil Kane <[hidden email]> wrote:
> >
> > > On 5/9/2020 7:08 PM, Nr4c wrote:
> > >
> > > > Beg to differ. Part 15 devices have no legal protection from
> > > interference. You use at your own risk.
> > >
> > > That's what I said. We deal with that professionally.
> > >
> > > >> (2) this device must accept any interference received, including
> > > >>> interference that may cause undesired operation.--
> > >
> > > Philip M. Kane Esq / P.E. - K2ASP
> > > VP - General Counsel & Executive Engineer
> > > CSI Telecommunications, Inc. - Consulting Engineers
> > > San Francisco, CA - Beaverton, OR
> > > ______________________________________________________________
> > > Elecraft mailing list
> > > Home: http://mailman.qth.net/mailman/listinfo/elecraft
> > > Help: http://mailman.qth.net/mmfaq.htm
> > > Post: mailto:[hidden email]
> > >
> > > This list hosted by: http://www.qsl.net
> > > Please help support this email list: http://www.qsl.net/donate.html
> > > Message delivered to [hidden email]
> > >
> > ______________________________________________________________
> > Elecraft mailing list
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> > Post: mailto:[hidden email]
> >
> > This list hosted by: http://www.qsl.net
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> > Message delivered to [hidden email]
> >
> ______________________________________________________________
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>

Phil Kane-2

Re: Headphones

On 5/10/2020 8:14 AM, Gwen Patton wrote:

> I didn't stay at a Holiday Inn Express last night.

Neither did I, but I am a lawyer who deals in this area.

Part 15 sets the minimum standard for RF emissions from devices that do
not require individual or blanket station licenses. If they don't
comply, they can't be used legally or be marketed (a "term of art" that
covers manufacture, sell, offer for sale, ship, modify, and in some
cases, use). Compliant devices must be certified by the manufacturer
and labeled as meeting those standards. There are certain exemptions
for home-brew ham equipment and school projects.

Regulatory law is clear - even if the emissions from a device comply
with the levels mandated in Part 15, if they cause harmful interference
(another "term of art") to licensed/authorized communications, the
operator of the Part 15 device is required to cease such operation until
the interference is abated.

Conversely, as many have noted, if the Part 15 device gets interfered
with by signals from a licenses/authorized station or device, it's
"tough". What part of "must accept" is not clear?

A good part of my early legal career was devoted to assisting and
defending hams against claims of interference to consumer-level
entertainment equipment. Much of that has gone away, because the
European Union has regulations about how such equipment must reject
outside signals and reputable manufacturers are adhering to those
standards if they want to sell in the worldwide market. The FCC has
kicked around establishing similar standards for decades with no action,
relying on the broad "must accept" to protect the public.

When is the last time that we here have had to deal with a substantial
claim of causing TVI ("Tennessee Valley Indians)? Not since I have been
running my K2.

73 de K2ASP - Phil Kane
ARRL Volunteer Counsel
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