FCC Wireless Interference Comment

CDT filed comments in response to the FCC’s rules regarding the certification of radio frequency equipment to request that the Commission consider either altering its proposed rules regarding a requirement to prevent the third-party modification of equipment such as wi-fi routers, or addressing the issue in a separate proceeding. CDT expressed concerns that the proposed rules, which are aimed at reducing radio frequency interference, might have unintended consequences such as limiting the ability of individuals to improve the adaptability and security of their router’s firmware. These rules easily could incentivize device manufacturers to use digital locks to secure all of the device’s firmware, rather than just the portion of the software that controls the radio parameters. Bypassing those locks, even to make legal changes to the firmware, could also lead to potential liability under the Digital Millennium Copyright Act.