Overview of the Forfeiture Order
On May 29, 2009, the Federal Communications Commission's Enforcement Bureau released a Forfeiture Order (DA 09-1198) against Orvac Electronics, Inc. of Fullerton, California. The order assesses a monetary forfeiture of $7,000 for willful and repeated violations of Section 302(b) of the Communications Act of 1934, as amended, and Section 2.803(a)(1) of the Commission's Rules.
The enforcement action concludes proceedings initiated after multiple inspections by the Enforcement Bureau's Los Angeles Office revealed that Orvac Electronics displayed and offered for sale uncertified intentional radiators operating in the 2.4 GHz band.
Investigation History and Store Inspections
The investigation began on November 22, 2006, when an FCC agent inspected Orvac's Fullerton retail store and identified several models of uncertified wireless cameras and stand-alone video transmitters. Following this inspection, the Los Angeles Office issued an official Citation on January 23, 2007, warning the retailer that marketing unauthorized equipment violated federal communications regulations.
Despite the formal Citation, subsequent inspections conducted on March 8, 2007, March 5, 2008, and April 4, 2008, revealed ongoing marketing and display of uncertified 2.4 GHz equipment. A database check on March 6, 2008, confirmed that multiple devices on offer lacked FCC equipment authorization.
- Cop Security wireless video camera models 15-2400 CTSL, 2400 CTSL, and 2400 CTJ
- Speco Technologies wireless camera model WC-2503
- WIV stand-alone video transmitter model TRX-20
FCC Analysis and Rejection of Orvac's Defense
On May 30, 2008, the Los Angeles Office issued a Notice of Apparent Liability for Forfeiture (NAL) proposing a $7,000 fine. In its response dated June 16, 2008, Orvac did not contest marketing the cited models, but asserted that its products were registered with the FCC, citing FCC Identifier NK2-2400 and submitting a 2006 equipment authorization grant for FCC Identifier TW4-906T issued to Shenzhen AEE Technology Co., Ltd.
The Enforcement Bureau rejected these arguments, finding no evidence that the referenced grants covered the equipment marketed in the Fullerton store or authorized modular transmitters for those models. Furthermore, none of the units observed during inspections carried the required FCC ID labeling mandated under Section 2.803(a)(1) and Section 2.925 of the Rules, and Orvac provided no documentation regarding the WIV video transmitter.
- The Shenzhen Grant (TW4-906T) contained no documentation or remarks establishing modular approval covering Speco or Cop Security devices.
- The CIC Grant (NK2-2400) was granted to CIC Components Ind Co Ltd, but inspected Cop Security devices bore no compliant FCC ID labeling.
- No certification evidence was provided for the WIV TRX-20 2.4 GHz video transmitter.
Compliance Directive and Payment Terms
The FCC affirmed the full forfeiture amount of $7,000 without reduction. In addition to the monetary penalty, Orvac was ordered pursuant to Section 403 of the Act to submit a sworn compliance report within 30 days.
The required report must detail how Orvac achieved compliance with equipment marketing rules and include the names, addresses, and contact details of the wholesalers, importers, and manufacturers of all cited equipment, accompanied by relevant invoices.