Federal Communications Commission DA 07-808
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Communications Specialists, Inc.
Orange, CA
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File No. EB-06-SE-349
NAL/Acct. No. 200732100005
FRN # 0001520170
ORDER
Adopted:  February 27, 2007 Released:  March 1, 2007
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau and Communications Specialists, Inc. (“CSI”).  The Consent Decree terminates the 
forfeiture proceeding initiated by the Spectrum Enforcement Division of the Enforcement Bureau against 
CSI for its possible violations of Section 302(b) of the Communications Act of 1934, as amended (“Act”),1
and Section 2.803(a)(1) of the Commission’s Rules (“Rules”).2  
2. The Enforcement Bureau and CSI have negotiated the terms of a Consent Decree that 
would resolve this matter and terminate the forfeiture proceeding.  A copy of the Consent Decree is 
attached hereto and incorporated by reference.
3. Based on the record before us, we conclude that no substantial or material questions of 
fact exist with respect to this matter as to whether CSI possesses the basic qualifications, including those 
related to character, to hold or obtain any FCC license or authorization.
4. After reviewing the terms of the Consent Decree, we find that the public interest would 
be served by adopting the Consent Decree and terminating the forfeiture proceeding.
5. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act,3 and Sections 
0.111 and 0.311 of the Rules,4 the attached Consent Decree IS ADOPTED.
6. IT IS FURTHER ORDERED that the Enforcement Bureau’s forfeiture proceeding IS 
TERMINATED. 
7. IT IS FURTHER ORDERED that CSI shall make its voluntary contribution to the 
United States Treasury, as specified in the Consent Decree, by credit card through the Commission’s Debt 
and Credit Management Center at (202) 418-1995, or by mailing a check or similar instrument, payable to 
the order of the Federal Communications Commission, to the Federal Communications Commission, P.O. 
Box 358340, Pittsburgh, PA 15251-8340.  Payment by overnight mail may be sent to Mellon Bank/LB 
  
1 47 U.S.C. § 302a(b).
2 47 C.F.R. § 2.803(a)(1).
3 47 U.S.C. § 154(i).
4 47 C.F.R. §§ 0.111, 0.311.
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358340, 500 Ross Street, Room 1540670, Pittsburgh, PA 15251.  Payment by wire transfer may be made 
to ABA Number 043000261, receiving bank Mellon Bank, and account number 911-6106.
8. 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 Albert Spencer Porter, President, 
Communications Specialists, Inc., 426 West Taft Avenue, Orange, CA 92865-4296, and to Ramsey L. 
Woodworth, Esq., Irwin, Campbell & Tannenwald, P.C., 1730 Rhode Island Avenue, NW, Suite 200, 
Washington, DC 20036-3101.
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief, Enforcement Bureau
Federal Communications Commission DA 07-808
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CONSENT DECREE
The Enforcement Bureau (“Bureau”) of the Federal Communications Commission 
(“Commission”), and Communications Specialists, Inc. (“CSI”), by their authorized representatives, 
hereby enter into this Consent Decree regarding possible violations of Section 302(b) of the 
Communications Act of 1934, as amended (“Act”),1 and Section 2.803(a)(1) of the Commission’s Rules 
(“Rules”)2 concerning CSI’s marketing of a certain radio frequency device known as the PT-1 “Petlocator” 
transmitter.
I.  BACKGROUND
1. On April 20, 2004, CSI was issued a grant of equipment certification for the PT-1 
Petlocator transmitter under the FCC Identifier CFXPT-1.  
2. On July 28, 2006, the Commission’s Office of Engineering and Technology (“OET”) 
Laboratory requested a sample unit of CSI’s PT-1 Petlocator transmitter, which CSI promptly provided.  
Thereafter, on October 3, 2006, the Bureau by letter advised CSI that testing conducted by OET indicated 
that the sample unit substantially exceeded radiated emission limits for intentional radiators specified by 
Section 15.209 of the Rules3 and did not comply with the periodic operation limits set forth in Section 
15.231 of the Rules,4 and requested further information with respect to the sale and marketing of the 
device.5 CSI promptly provided all information requested on October 10, 2006.6
3. On November 22, 2006, the Bureau’s Spectrum Enforcement Division released a Notice 
of Apparent Liability for Forfeiture7 (“NAL”) to CSI in the amount of $7,000 for apparent willful and 
repeated violation of Section 302(b) of the Act and Section 2.803(a)(1) of the Rules.  
II.  DEFINITIONS
4. For the purposes of this Consent Decree the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended U.S.C. §§ 151 et seq.;
(b) “Adopting Order” means an order of the Bureau adopting the terms and conditions of 
this Consent Decree;
(c) “Bureau” means the Enforcement Bureau of the Federal Communications Commission;
  
1 47 U.S.C. § 302a(b).
2 47 C.F.R. § 2.803(a)(1).
3 47 C.F.R. § 15.209.
4 47 C.F.R. § 15.231.
5 See Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division, Enforcement Bureau, to 
Communications Specialists, Inc. (October 3, 2006).
6 See Letter from Albert Spencer Porter, President, Communications Specialists, Inc., to Thomas D. Fitz-Gibbon, 
Spectrum Enforcement Division, Enforcement Bureau (October 10, 2006).
7 Communications Specialists, Inc., Notice of Apparent Liability for Forfeiture, 21 FCC Rcd 13532 (Enf. Bur., 
Spectrum Enf. Div., 2006).
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(d) “Commission” means the Federal Communications Commission;
(e) “Compliance Plan” means the processes and procedures developed by CSI to ensure 
compliance with the Communications Act and the Commission’s Rules regarding the 
sale or offering for sale of radio frequency devices, as summarized in this Consent 
Decree;
(f) “CSI” means Communications Specialists, Inc.;
(g) “Enforcement Proceeding” means the investigation of the alleged Rule violations by 
CSI culminating in the Notice of Apparent Liability for Forfeiture;
(h) “Effective Date” means the date the Bureau releases the Adopting Order;
(i) “Notice of Apparent Liability for Forfeiture” or “NAL” means Communications 
Specialists, Inc., Notice of Apparent Liability, 21 FCC Rcd 13532 (Enf. Bur., Spectrum 
Enf. Div., 2006);
(j) “Parties” means CSI and the Bureau; and
(k) “Rules” means the Commission’s Rules found in Title 47 of the Code of Federal 
Regulations.
III.  TERMS OF AGREEMENT
5. 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.
6. The Parties agree that this Consent Decree shall become binding on the Parties on the 
Effective Date.  CSI and the Bureau represent and warrant that its signatory is duly authorized to enter 
into this Consent Decree on its behalf.  Upon release, the Adopting Order and this Consent Decree shall 
have the same force and effect as any other final order of the Commission and any violation of the terms 
or conditions of this Consent Decree shall constitute a violation of a Commission order.
7. CSI acknowledges that the Bureau has jurisdiction over it and the matters contained in 
this Consent Decree and the authority to enter into and adopt this Consent Decree.
8. The Parties waive any and all rights they 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 that the Adopting Order adopts the Consent Decree without 
change, addition or modification.
9. CSI waives any rights it may have under any provision of the Equal Access to Justice 
Act, 5 U.S.C. § 504 and 47 C.F.R. § 1.1501 et seq., relating to the matters discussed in this Consent 
Decree.
10. The Parties agree that this Consent Decree does not constitute either an adjudication on 
the merits or a factual or legal finding or determination of any compliance or noncompliance by CSI with 
the Act or the Rules.  The Parties further agree that this Consent Decree is for settlement purposes only 
and that by agreeing to the Consent Decree, CSI does not admit or deny any noncompliance, violation, or 
liability associated with or arising from its acts or omissions involving the Act or the Rules that are the 
subject of this Consent Decree.
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11. In express reliance on the covenants and representations in this Consent Decree, the 
Bureau agrees to terminate the Enforcement Proceeding.
12. CSI agrees that, as of the Effective Date of this Consent Decree, it will implement the 
following FCC Regulatory Compliance Plan:
(a) CSI agrees to cease the sale and marketing of the PT-1 “Petlocator” transmitter in the 
United States and consents to the cancellation by the Commission of the equipment 
authorization, FCC Identifier, CFXPT-1, granted April 20, 2004, for the equipment.  
CSI agrees to not sell or market the device in the United States unless or until the 
device has been retested by an independent accredited testing laboratory and recertified 
by the Commission.
(b) Should the PT-1 “Petlocator” transmitter be recertified for sale within the United 
States, CSI will implement specific product quality control manufacturing procedures 
to ensure that all units of the product manufactured by CSI conform to the parameters 
of the FCC certification and manufacturing standards set forth in Section 2.931 0f the 
Commission’s rules.
(c) Compliance Officer. CSI will place compliance with this Consent Decree under the 
direct supervision of CSI’s President, Mr. Albert Spencer Porter. 
(d) Written Advisory.  Within 45 days of the Effective Date of the Consent Decree, the 
Compliance Officer will send a written advisory on Parts 2 and 15 of the FCC’s Rules 
and the requirements of the Consent Decree to each officer and employee of CSI who 
have or will have responsibilities related to the design, development, testing, 
marketing, and distribution of radiofrequency products on behalf of CSI. 
(e) Employee Training. CSI will train and provide materials concerning Parts 2 and 15 of 
the FCC’s Rules and the requirements of the Consent Decree to all of its employees 
who are involved directly or indirectly in the design, development, testing, marketing, 
and distribution of radiofrequency products.  Specifically, CSI will, within 60 days of 
the Effective Date of the Consent Decree, conduct a training program regarding: 
(1) compliance with the technical requirements of Part 15 of the FCC’s 
Rules in the design and manufacture of radio frequency equipment;
(2) compliance with Part 2 of the FCC’s Rules regarding the sale, marketing, and 
distribution of radio frequency equipment; and
(3) the requirements of the Consent Decree. 
New employees who are involved directly or indirectly in the design, development, 
testing, marketing, and distribution of radiofrequency products will be trained within 60 
days of being hired.  Existing employees who are reassigned to jobs with such 
responsibilities will be trained within 60 days of reassignment.  All employees who are 
involved directly or indirectly in the design, development, testing, marketing, and 
distribution of radiofrequency products will receive “refresher” training at least annually.
13. The Parties acknowledge that this Consent Decree shall constitute a final settlement 
between CSI and the Bureau regarding possible violations of Section 302(b) of the Act and Section 
2.803(a)(1) of the Rules specified in the NAL.  In consideration for termination by the Bureau of the 
Enforcement Proceeding and in accordance with the terms of this Consent Decree, CSI agrees to the 
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terms set forth herein.
14. The Bureau agrees that, in the absence of new material evidence, it will not entertain, or 
institute on its own motion, any new proceeding, formal or informal, or take any action on its own motion 
against CSI for the possible violations of Section 302(b) of the Act or Section 2.803(a) of the Rules 
specified in the  NAL.  The Bureau also agrees that, in the absence of new material evidence, it will not 
initiate or recommend to the Commission any new proceeding, formal or informal, against CSI regarding 
the matters that were the subject of the Enforcement Proceeding.  The Bureau further agrees that, in the 
absence of new material evidence, it will not use the facts developed in the Investigation through the 
Effective Date to initiate on its own motion, or recommend to the Commission, any proceeding, formal or 
informal, or take any action on its own motion against CSI with respect to CSI’s basic qualifications to 
hold Commission licenses or authorizations.  Nothing in this Consent Decree shall prevent the 
Commission from instituting investigations or enforcement proceedings against CSI in the event of any 
other alleged misconduct that violates this Consent Decree or that violates any provision of the Act or the 
Rules.
15. The Parties agree that each is required to comply with each individual condition of this 
Consent Decree.  Each specific condition is a separate condition of the Consent Decree as approved.  To 
the extent that CSI fails to satisfy any condition, in the absence of Commission alteration of the condition, 
it will be deemed noncompliant and may be subject to possible future enforcement action with respect to 
such failure to satisfy the condition.
16. The Parties also agree that any provision of this Consent Decree which conflicts with any 
subsequent rule, order of general applicability or other decision of general applicability adopted by the 
Commission will be superseded by such Commission rule, order or other decision.
17. CSI agrees to make a voluntary contribution to the United States Treasury in the amount 
of Five Thousand Six Hundred Dollars ($5,600) within thirty (30) calendar days of the Effective Date.  
Such contribution shall be made, without further protest or recourse, by credit card through the 
Commission’s Debt and Credit Management Center at (202) 418-1995, or by mailing a check or similar 
instrument, payable to the order of the Federal Communications Commission, to the Federal 
Communications Commission, P.O. Box 358340, Pittsburgh, PA 15251-8340.  Payment by overnight 
mail may be sent to Mellon Bank/LB 358340, 500 Ross Street, Room 1540670, Pittsburgh, PA 15251.  
Payment by wire transfer may be made to ABA Number 043000261, receiving bank Mellon Bank, and 
account number 911-6106.  The payment should reference NAL/Acct. No. 200732100005 and FRN 
00015200170.  
18. 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 CSI nor the Commission shall contest the continuing 
validity of the Consent Decree or Adopting Order.  The Parties agree to comply with, defend and support 
the validity of this Consent Decree and the Adopting Order in any proceeding seeking to nullify, void or 
otherwise modify the Consent Decree or the Adopting Order.
19. The Parties agree that in the event that any court of competent jurisdiction renders this 
Consent Decree invalid, this Consent Decree shall become null and void and may not be used in any 
manner in any legal proceeding.
20. The Parties agree that the requirements of this Consent Decree shall expire two (2) years 
after the Effective Date.
21. This Consent Decree cannot be modified without the advance written consent of all of the 
Parties.
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22. This Consent Decree may be signed in counterparts.
For: Federal Communications Commission
Enforcement Bureau
By: __________________________ ________________________
Kris Anne Monteith Date
Chief, Enforcement Bureau
For: Communications Specialists, Inc.
By: __________________________ _________________________
Albert Spencer Porter Date
President