 Good afternoon. My name is Doug Mone. I'm Editor-in-Chief at Vaughan Magazine. I'm here to talk about TV white spaces, what might be the next Wi-Fi. Let me give you a 30-second intro about who I am. I've been a contributor to Motable Radio Technology magazine since January of 2003. I've been hearing policy wonks talk about the use of 700 megahertz spectrum. Basically, all that TV spectrum, and I'm going to get a little bit more into the freed-up TV spectrum that's coming. As well as the use of unlicensed spectrum, talk about this stuff in DC for years. My day job is Editor-in-Chief at Vaughan Magazine. We did an interview with Phil Zimmerman in early 2007. I guess Phil liked it so much he put the interview on the cover of his website, so I guess we did something right. And what would you suggest? 640 by 480? Yes or no? Alright, let's see. 124 by 768, yes? Alright, let's go ahead and apply. Yeah, okay, let's hit OK. Yes, okay, I got the yes part right. Alright, now let's try this again. Okay, we more better here? Okay. It took longer than King Tuna did too. Unlicensed TV white spaces. I'm going to talk about what the definition of white spaces is. How did the concept got created? The technical proposals surrounding white TV white spaces. Talk about the FCC findings which were released just this week. And then a little bit as to what's going to happen in terms of final word on this, which is expected in October. First of all, what's white spaces? The current U.S. analog or NTSC television system uses VHF and UHF frequencies. So today on your TV dial, should you be one of the five people in the U.S. that don't have cable or satellite? You've got TV channels 2 through 69 on your dial. As of February 18, 2009, assuming there's no last minute political panic and, you know, I'm not willing to bet against that. It's a long shot, but channels 2 through 51 will be for digital, will be for TV and it's all digital. Okay, let's take a step back here. In any given geographic area, as you know, if you are one of those five people that has a broadcast that's still getting TV through the airwaves, you can receive a handful of stations due to the basics of geography, i.e. where you're located and careful licensing. You know, if you've got, you know, you don't have a TV station per channel from channels 2 all the way up through 51. Once you go up higher on the scale, they tend to leave spaces between TV stations so there's no interference there. And then in smaller markets, you know, you just can't support, you know, if you're in Po-Dunk, you can't support 3 TV stations. You're lucky to support one TV station. So with 51 channels, less of a handful, and I'll get into what a less of a handful is, you've got lots of open, unused, what they call white spaces channels because there's no TV broadcast, there's no use of the TV channel with 6 megahertz of bandwidth because there's no TV signal to receive. Now, each digital TV channel has got a 6 megahertz chunk of bandwidth. And again, if I apologize if I say something wrong because I'm not a ham operator and I know somewhere along the rhymes, I'm going to step on something and the ham people are going to chew me out, so apologize in advance. But you've got 6 megahertz channel and you've got, and within that 6 megahertz channel using the existing DTV stack created back in God, I don't know, the Dark Ages of 1980, you've got 27 megahertz of broadcast bandwidth that you can, data that you can cram into there right now using the existing DTV specs. Sidebar there is some TV stations are using a part of their digital TV spectrum to broadcast or data cast digital information, but not digital information, data rather than TV programming. But it varies from place to place and it hasn't caught on a lot. Sidebars, when the Congress finally cut this grand bargain or grand satanic deal with the National Association of Broadcasters to move from analog TV over to digital TV, all of a sudden a lot of people started looking at moving TV stations out of their existing channels and moving them down and said, hey, while we're going to have all this free spectrum, we got to do something with it. You heard, so there's been three major fights over this spectrum, one of which I'm specifically going to get into today, but I want to touch in on the other two because a couple of you in the audience have asked about what's going on here. The first type of fight that was just publicly discussed or got the most coverage this week was the rules for the spectrum auctions for 700 megahertz. There's a second spectrum auction coming up for that chunk of, for chunks of spectrum between 52 through 69 and Google basically wanted to set a net neutrality set of rules on how the spectrum was going to be used. As you would expect, the incumbent vendors as well as the incumbent vendors, i.e., the cellular companies, people who are in the cellular companies said, well, we don't really want to do that. What happened was a compromise put through in the FCC where they said, well, okay, you're going to have to have open devices to get rights to this spectrum. It's going to be interesting to see how that works out because this is a Carter phone like decision where you're going to be able to, if let's say a Verizon or a Sprint, well, let me rephrase it, a Verizon or an AT&T gets use of the 700 megahertz spectrum, you're going to be able to buy any device and use it with their service or are there going to be more strings attached? Nobody knows. In theory, you should be able to bring your own device just like you'd be able to take your own telephone now and plug it into the PSTN, but I don't know. Second war has been over public safety. Public safety, especially after 9-11, wants 700 megahertz spectrum for an interoperable broadband network. There was some rules at the FCC set that a part of the spectrum that will be auctioned off is going to be dedicated to some sort of public-private partnership to build out a broadband network for public safety across the United States. What that looks like, who knows, they got to get the bids, they got to negotiate all that stuff. And then the third thing that I'm going to talk about is TV white spaces. Before we get into that, why is 700 megahertz RF band? Why is it loved and coveted by all? Well, the first obvious fact is, hey, it's all this chunk of big free spectrum, but not only that, the propagation characteristics are great because it goes through walls, obstacles relatively easily. And then in a licensed use mode, you can cover a city with either one or two base stations versus lots of cells or transmitter sites when you're using Wi-Fi and higher frequencies. I saw one slide presented a couple of years ago that showed 700 megahertz overlay network on a typical city like Seattle versus a Y-max type of network in 2.5 gigahertz. And there's like one base station in the center of town with 700 megahertz. And when you got into Y-max, it was like, you know, 8, 9, 10 base stations just to cover the same territory. So it's pretty powerful stuff. More importantly, there's a lot of white spaces available the farther away from cities you go. You know, if we were to take a ride out and go out right out in the desert and make a couple of turns, assuming we could find a place to plug in a TV, it's very quiet out there electronically speaking. So policy wonks see this opening up of white spaces and 700 megahertz as a savior for the digital vibe in rural America. They want more broadband, but carriers don't want to invest in infrastructure, i.e., copper, fiber, or whatever, to go out to Podunk. So a lot of rural senators are saying, well, broadband can get us to... Okay, excuse me. RF can get us to broadband without having to deal with expensive infrastructure. Another FYI, there's a lot of lurking licensed 700 megahertz space that's already been bought. The first auction was conducted several years ago, and there's a bunch of speculators sitting on it. The two largest are Aloha Networks and Vulcan Ventures. Does anybody know who Vulcan Ventures is? Well, I don't even call Paul Allen the guy from Apple. I think he's the guy from Microsoft. But yeah, Paul Allen Vulcan Ventures has got like the second biggest chunk of 700 megahertz... Biggest chunk of licenses aside from this one-man band called Aloha Networks. As another side, Aloha owns some 700 megahertz spectrum in Las Vegas, and they've talked about doing a demo of their system. And then Qualcomm, I think nationwide, they have the equivalent of Channel TV 59 locked up. So if you're talking about mobile TV, you guys may have seen Verizon where you can walk around and watch your mobile TV on our Verizon phone. That's Qualcomm stuff, and that's what was Channel 59. The second auction is coming up as I noted. Out of this, there's speculation that cable companies, Google, or others may raise enough money to go bid on these licenses. And obviously, as I said before, there's a lot of infighting on how the auction should be conducted. Google has pushed for liberalized auction rules and the CTI, the sell guys and the incumbent carriers, like the way things are currently worked. So how did this concept of wiped spaces get created? Why is this a good thing for America? What happened was as policymakers started looking at the need for more spectrum, for more bandwidth, for more uses, seeing with the success of Wi-Fi, they said, well, okay, what else can we do? And they looked at the fact that broadcast TV was moving out of 700 megahertz and they started thinking a little bit well and thinking about, well, there's all this extra bandwidth because with TV, the way TV broadcast licenses are set up, you're not putting TV channels back to back. You're licensing TV stations where there's one or two or three or four within a geographic region. And then there's all these empty channels that are available for broadcast. And again, there's recognition for demand for more unlicensed bandwidth because there's a belief that if we have more unlicensed stuff, it'll stimulate the use of consumer devices, blah, blah, blah. Some more widgets were all good. One of the other things that the policy wonks brought to the table is the concept of the cognitive or smart radio as an enabling technology to be able to find unused TV bandwidth and utilize it. And DARPA has done a lot of work, what they call cognitive radio. This is a recent history of where white spaces is in terms of the legal machinations. The FCC notice went out on May 2004. Whatever licensing is done for TV white spaces, it won't be a Part 15 Wi-Fi type. It'll be something a bit different. First round of comments have come back on the FCC notice saying, hey, we're talking about unlicensed use for TV white spaces. What do you think? And then you had about three major parties commenting in. The white spaces alliance, I'll get into who they are in a minute. Motorola's commented on it. And then the association for maximum service television, which is basically a front for NAB, I think. Best way to put them. And then FCC addressed the comments July 31st. That is this last Tuesday. FCC notice of proposed rulemaking. It was written in part by a guy by the name of Ed Thomas, who is the head of the Office of Engineering and Technology. Remember this name, it will come up again. The statement basically said that the FCC wanted to open up the white spaces channels, open up a dialogue between industry, in other words, you know, here the NAB bitch, and as well as technology companies. So they wanted to get the ball rolling and get everybody talking about how people could use this bandwidth, excuse me, this spectrum. And then the notice of proposed rulemaking throughout this suggested approach is to avoid interference with existing TV stations. Because if you're going to have an unlicensed wireless device, one of the key principles is an unlicensed device shouldn't interfere with a licensed device. So the three suggested proposed approaches in the notice of proposed rulemaking by the FCC was, number one, use a guard signal to tell a device that, hey, okay, these are the available channels in this region, use everything else that was one approach. Second approach was geolocation. In other words, build enough smarts into the device to go, where am I at? Okay, I'm sitting in Las Vegas, so let me go out to the FCC database and go look at where the broadcast signals are, which TV channels are out here. And then from that I can calculate where my open spaces are. Or third, the smartest approach, and probably the most intelligent approach, spectrum sensing, where you look at the RF environment around you and you sense it, you basically smell it and you go, aha, okay, I've got TV channels two, four and five going on here and I've got some other stuff going on in this frequency from wireless microphone use, so I'm going to block those things out and I can use everything else. Now, the National Association of Broadcasters was not happy when it comes to preserving the sanctity of the airwaves and, again, for all five of those people who get broadcast TV, they get really healthy. So they generated a worst case scenario for white spaces, basically saying if you plug into these devices, digital TV is going to go to crap and they try to convince the FCC that it would never work and they sent out like 154 pages going, well, mark, mark, because here, blah, blah, blah, blah. So even before anybody's put together a prototype device, it's saying it's not going to work. Now, white space of devices from the discussion won't be Part 15 Wi-Fi and, again, this is where the hams can go and come up and smack me afterwards. You know, Part 15, I think they say up to one watt of power and you basically principle are, you must take interference from other devices and you must not cause interference with other devices. So, basically, you're screwed both ways. You can't hurt anybody, and not only can you hurt anybody, you can interfere with anybody, but, you know, if the microwave turns on next door, you got to take it. There's no way around it. Comments from the White Spaces Alliance in Motorola indicate that the model for Part 15 Wi-Fi type of uses was not workable because the typical white space device is going to be broadcasting at under one watt and exactly how much under one watt is, I think, up to discussion. But basically under one watt to avoid interference with other operating TV channels. And number two is that you're going to need a cognitive or smart radio to avoid intentional interference. And then the approaches favored by both Motorola and the White Spaces Alliance were a look before broadcast approach and or geolocation. Let's talk a little bit about cognitive or smart more radio. This is another concept that's going to come back and get discussed in future years and hopefully at DEF CON 16, 17, 18, and 19. We'll actually see some of these devices. A smart radio or cognitive radio, the terms sometimes get interchangeable depending upon which policy won't you're talking to. But basically smart radio should be able to sense the RF environment around you. Be able to, after it's profiled the RF environment, it should be able to avoid broadcasting on, in this case, television channels in use. Should be able to find the unused bandwidth and adjust its power accordingly so it doesn't stomp on any broadcasting. Like if there's a wireless mic next door, maybe you don't want to use something on an adjacent channel at power. When you start talking about cognitive white radio, it sounds like a lot like electronic warfare without the war. In other words, you're taking an RF snapshot of the environment or sensing what your RF environment is around you. But you're not trying to figure out how to jam anything. In this case, you're trying to figure out how not to jam devices. The other principle to take away is that the poster child for cognitive radio right now in consumer devices is for TV white spaces. But there's consideration to use in another like what I call junk bands. White spaces alliance comments. Here's where we get back to you. Remember what I asked to send earlier? White spaces alliance is made up basically of a lot of high tech heavy haters. You've got Dell, Google, HP, Intel, Microsoft, and Philips. Google is very interesting because not only have they been pushing for 700 megahertz usage and said they actually go bid on license spectrum, not only do they want to do things with license spectrum, Google wants to do stuff with unlicensed spectrum. So they're pretty key there. One of the contributors that helped put together an initial package of information to respond to the FCC comments was a guy by the name of Ed Thomas. Well, he used to work for the FCC. Now he's working for a law firm down on K Street. So it's interesting to see how that roped all the doors working. The white spaces alliance people said, look, here's what we propose to do. We're going to block off channels 2 through 20 on the TV dial as well as channel 37 for radio telescope usage anyways. Because we want to avoid an interference with existing licensed users, i.e. the land mobile radio people and the wireless mic people. But we'd also like to propose that we reserve the lower end of channels 2 through 20, the higher end of 2 through 20 for potential public safety white spaces usage. There's a feeling that if you produce a white spaces device, broadband type of device, that's like a Wi-Fi device, that's in channels 21 through 69, then, excuse me, 21 through 52, then if I tweak this model a little bit, I can tap into some of these other channels and in cases where things are available, public safety can use some of those lower channels to build an ad hoc broadband network. White spaces alliance to geolocation is too cumbersome. I start complaining about who would update the database of emitters, how do you get the device to log in to check emitters, how often is that updated, they go through all these reasons why geolocation is too cumbersome. They don't even talk about the guard channel concept about using a broadcast channel that would separate FM type of broadcast channel to tell you what white spaces are available in your region, to forget it, that's just add more part count cost, more parts, more expensive, more complicated device. So they said, hey, spectrum sentries, smart ray is the only way to go, and oh by the way, here's this device that Microsoft built, this is a toy that Microsoft built. I'm probably gonna regret saying toy because we may be something else, but basically what you see here is you got a laptop running Windows XP, probably the version 2.0 will be running under Windows Vista, no doubt. And it's got three black boxes, one of them is a transmitter, actually what do I say, okay. Microsoft called this as usual with their high quality marketing savvy, Microsoft white spaces TV development platform version 1. When the press release first came out earlier this year about it, the few press people that picked this up made it sound like a finished consumer device. This is not a finished consumer device. Microsoft basically provided a prototyping platform to allow the FCC to play around with and evaluate the ability of a device to find open TV white spaces on existing radio spectrum. And then also as a development kit for manufacturers to build products that are Wi-Fi like in nature, if I can say that. Why did white spaces give the FCC device? The FCC test division is able to take this device and go play with the knobs on it, basically the sensitivity of the technology that's being presented, be able to turn some of the knobs and software on it, see what happens if you turn on more power. Does that interfere with the reception of digital TV, turn it down? Well, what's the minimum that we can do to get a signal in there? Test interference with existing devices, that's pretty much a good portion of what the FCC's charter is. And then also test various waveforms to identify digital TV signals and TSC signals, which of course is in some ways moot because after February 2009, NTSC goes away as well as wireless mics. And then, well, how does this thing work? Well, basically, again, it enables developers to create spectrum scanning, in other words, looking at spectrum and figuring out what's being in use and signal recognition software and hardware basically to co-exist and avoid interfering with digital TV operators. And then also it's enabled, developers get a chance to play around with refining power control algorithms, waveform modulation, and then a big key for the FCC is to perform on-air propagation and coverage measurements. So basically, the FCC wanted something to play with. The White Spaces Coalition said, here, well, let me rephrase, the White Spaces Corporation publicly said, here, here is this wonderful device from Microsoft for you to work with. I know, using Microsoft in wonderful in the same sense is kind of an oxymoron, but forgive me. You'll see why I'm saying this sort of shortly. Under the hood of this, there's two systems assemblies. Again, there's a Windows PC-based box using the Internet Explorer browser as an interface. What do you expect from Microsoft? And then there's three boxes. One of them contains a spectrum scanner and a network processor. And then there's a tunable UHF duplex-train-sever in there as well, so they can do broadcast as well. So not broadcasting formalized data, but just showing that you can broadcast and manipulate signal strength and things like that. How does this gizmo work? You turn it on and it goes through, scans channels 21 through 51, does an FFT, and, of course, I'm old, so I can't remember what FFT stands for, but there's math to figure out, okay, what sort of fingerprints we have here, and then it matches those fingerprints to the templates it has for DTV and NTSC, and then things that it doesn't find, and if it doesn't find any DTV channels in there, then it goes, okay, this might be a chunk of spectrum I can use. Let's go ahead and apply another template in there for see if there's a wireless microphone on 700 megahertz or something else in here. Let's see if it's really safe to use. And, of course, it can all be nipped, you'll only get through. So close the page on that. This is what the technology people said this. And Motorola had a different set of comments. Motorola being a much more conservative company in terms of technology said, look, we want to block off channels two through 21 on your TV dial and throw in two other channels for public safety use. Whatever devices are used for white spaces, you've got to have geolocation in there, but maybe spectrum sensing in there maybe later. Spectrum sensing was deemed by Motorola to be too much of an immature technology. I think that's because Motorola hasn't used it that much in terms of hasn't looked at it as... hasn't really looked at it with any passion yet. And there was no discussion again on guard band. When I talked with Motorola in an interview, I was trying to figure out if they had sent in a demo device to the FCC or they had a prototype lurking about and they just got...they didn't say yes, they didn't say no, they just got real quiet. When the tech wants came out, there's a thing called New America down in Washington, D.C. and they've been doing a lot of rah-rah policy and I encourage you to go look up their website. New America's been talking up TV white spaces like I said for years. What they want to do is take all the TV white spaces. There's everything on the TV dial and they said there's no technical excuse not to look at using that extra spectrum. They said the white space coalition, they didn't say they were pussies, but basically it was kind of implied. They said that they blocked off channels 2 through 20 because they didn't want big antennas. They said white space coalition was focused on building portable, i.e., consumer type of devices and then you just turn around and they diss Motorola. They said, well, Motorola is more geared toward fixed broadband devices, so for them geo-location works better. So if you're going to do a canopy or mesh network, that's what you want to do. Now here comes the big news. This just came out on Wednesday and this got lost in the noise about the auction rolls, about 700 megahertz and Google wanting bid on the spectrum, blah, blah, blah. What came out was that not one company, but two companies, have submitted prototype devices to the FCC talking about two prototype devices for TV white space applications. Interestingly, when you read through the FCC report and this kind of gets glossed over by the white space coalition, I'm going to get into that, those two devices did not work as well as anticipated. So I want to talk about what was good, what was bad and speculation of failure. Like I said, two companies supplied devices. The FCC report labels them as prototype A and prototype B. Prototype A has a transmitter included in device based upon my previous slides. Microsoft had a transmitter, prototype A, Microsoft's Gizmo. And then three copies of this Gizmo were provided to the FCC to play with. Prototype B is one device supplied and had a sensing capability only. The only thing that this little Gizmo was doing was prototype B was basically looking at the environment and figuring out whether or not there's DTV or NTSC or wireless microphones out there. The FCC report very clearly states the devices were not intended for actual consumer products, but they're developmental devices. Basically, they're first line hacks, development tools to evaluate spectrum sensing and whether or not there's going to be any potential interference if you start broadcasting. But these devices were not designed. Neither one of the devices submitted was an actual Wi-Fi to Wi-Fi data like type of deal. The FCC tests, they did two tests. One of them was for spectrum scanning and one of them was for wireless microphone usage. For the bench test, they had the devices sense or look for digital TV channels or broadcasts in a range of TV channels from 21 through 51. The FCC desired requirement was to be able to detect the signal at negative 116 dBm for six megahertz channel. Microsoft wanted 114 dBm. In the field test, they took out the prototype A, i.e. the Microsoft device, at a lab to homes. And this is one of the reasons why working for the FCC might be a cool thing. You get the latest stuff and you can take it home and play with it, I don't know. They took the Microsoft device at a lab to like homes and played around with it in a real world environment to see, you know, kick the tires on it. Now the results for prototype A, Microsoft, for the bench test, FCC deemed it reliable to connect, to detect digital TV signals at 95 dBm. Remember, the spec is 116, it detects at negative 95 and kind of sucks. But more importantly on this, and this is one of the things that I'll get into a little bit later, but it took 27 seconds per channel and around 13 minutes for a 31 channel range just to go scan through all the spectrum to figure out what's wrong. You know, 30, you know, 13 minutes to boot up and figure out what's out there. You know, it seems to be, you know, it's, yeah, forget it. In the field test, in other words, when they took this thing home, it said 20% of the time, only 20% of the time when the NT, when there is analog TV in use, the device tagged the channels is available. Now that's kind of a bullshit result, frankly, because NTSC is going away, and I, you know, more importantly, is that 45 to 75% time with an average about, oh, 58%, this thing labeled TV channels is free when there's actually a digital TV channel going. So basically, you know, it's sucked. And I found that there are empty channels that were really empty on average of 85% of the time, which is not good. Well, it's okay, you know, but again, if you're only finding empty spaces, there's an extra 15% there that you're calling used, but it's empty. Prototype B was delivered by Phillips and Phillips did not issue press release. Phillips did not go through a lot of bullshit about, oh, yes, this is wonderful, this is great. Phillips just basically went to the FCC, hey, we have this prototype, you know, we do hardware, you know, we do hardware if this is what we got on breadboard or whatever. The bench test, the Phillips device was able to reliably detect digital TV signals in negative 115 dBm, exactly what the FCC wants in their new specs. So this is very promising. It took about eight seconds for them to scan a channel in about four minutes for the device to go through the full range of channels to figure out what kind of open spectrum was available. And then Phillips specifically said, and again, I give them props for this, they said, look, don't take this out of the lab. This is not suitable for field testing. Don't do field tests on it. Then the FCC also runs some tests to see if this could sense wireless, either device could sense wireless microphones. Prototype A couldn't reliably find wireless microphones. It incorrectly labeled them as DTTV channels. In addition to that, when they started doing broadcast testing, it turns out that the transceiver interfered with wireless mics. Prototype B had mixed results. So I call up the White Space Coalition people. They sent out a short press release. They're happy that one device, Phillips, was able to meet the 116 dBm specs so they feel like the glass is not half empty, it's half full. And they also want to talk to FCC about the procedures it used to test the two prototype devices as well as some other matters. Speculation with Prototype A, in other words, a Microsoft device. According to some of the sources I talked to, both devices that were submitted first got third party independent testing conducted beforehand. So either the Microsoft device had a wireless or something, or B, the Microsoft submission was not as mature as the developers thought. Pick between A and B. Which solution do you think? Microsoft? Now what's expected to be finalized in 2007? FCC testing protocols will be finalized. There's going to be more discussion on this to make sure everybody's happy. And there's supposed to be a final report and order issued for the use of unlicensed TV white spaces in 2007. Real-world implementations on this. Well, how's this going to happen? The consumer electronics vendors are hot to go on this. Obviously, Phillips got a prototype or breadboard device on this, so they're smelling the money. God knows, Intel and Phillips always need to sell more chips and devices. I know that everybody's been reading, well, since I have a US-centric view of the world, we see a lot of Intel, Phillips and the rest of the world. They got a lot of market share and they got a lot of market share that they need to continue to grow. Well, Google wants yet another way to get around the man, in this case, telcos and cables, and Google obviously wants to look at both, is pursuing obviously a multi-prong strategy of both looking at unlicensed broadcast space for such as in a Wi-Fi type of network, as well as licensed 700 megahertz frequency. And then the software's relatively straightforward, although I'm kind of eating my words on that. I think Microsoft basically did their prototype with one engineer in IE, so hopefully we'll see devices maybe by late 2008 or early 2009 if we don't get into standards. Good. Any questions? And kind of raise your hand. Yes, sir. Where are you from? I think the answer to all that's yes. I mean, once... He's asking if there's a nexus or there's some synergies between what's being done with mesh networks and broadcasting of mesh networks and that sort of thing. And the answer is yes. If we break this down into like how am I saying that? Kick's rusty. Break this down into networking type of stuff. Applications layer, stuff like mesh networks and things like that. You can do whatever you want with a spectrum. So there's going to be a lot... So take a step back. I expect people to use a spectrum for things like mesh networking, especially with unlicensed use because as you go out into Podunk, well not Podunk, but as you go out into rural America, but on the other hand, well, if you've got a mesh that... The short answer is yes. It's just a matter of thinking through the permutations on. Which gives it a political layer, which is beyond applications layer, which is... I can see where you're going with this. People are going to look at a lot of different models for this. Other questions? Yes, sir. Are you over there? I think there's going to be a subject of negotiation as to how the device handles it. There may be... If you've got a wireless mic on a channel, on a channel, it just may be something where you tell a device, stay away from... step up or step down from causing interference to avoid it. But again, I'm not sure... do you do that? Do you tinker with power? I mean, there's... The FCC's wonks are going to talk to the white space wonks and see what's the best solution there. Okay. Let me spin that. When you say guard channel, guard channel is probably an inappropriate term, but a channel that says... The initial concept for guard channel was you'd have an FM transmitter with an energy graphic region broadcasting out to a device going, okay, here are... here are the devices in this region. Here are the chunks of spectrum in this region that are in use. Avoid being on those chunks of spectrum. Exactly. The answer to that is... How many minutes have I got? Let me finish answering him and then we can do QA. Okay. Oh, he reminds me. And then I got to get into QA. The... It's a nice concept and principle. Okay. Great concept and principle, but you got to go find somebody to run the FM station and set it up in each geographic region. Okay. There's some cost added on there. You got to go build in that extra code or add in that extra chip or that extra part or parts to look for that guard band device. Okay. All of a sudden, okay, who pays for the FM broadcast guard channel per region? You start going into who covers all these costs and the business model starts to get a little bit complex because you go, who pays the bills for this? Because the FCC doesn't want to run guard channel stations. They don't want to do that. And then from the manufacturer standpoint, they want to crank out millions of these devices so that we can buy them for $150 to $200 a pop rather or lower, hopefully lower than, you know, they throw in another chip and that's another five bucks there and maybe five bucks to the guy who's got to run the FM station. They want to stick to the KISS principle and I kind of see where they're coming from. Okay. My friend Lagoon has told me that we're going to move the discussion to Track 1 Q&A over there to shut down Mr. Computer and I'm going to take questions over there. I'll see you guys over there shortly.