Great Scott Gadgets Information

Great Scott Gadgets designs and manufactures Open Source Hardware (OSHW). The OSHW community includes a small but rapidly growing segment of the electronics industry that is committed to the ideals that end users have a right to fully control their own equipment and that anyone should be able to study, make, use, modify, and sell devices based on our published designs. OSHW makers recognize that, just as Open Source Software has resulted in great advances in the software industry, Open Source Hardware will enable future generations of hardware innovation. As an OSHW designer, I have often been troubled by the Commission's rules for SDR. Great Scott Gadgets manufactures and sells HackRF One, an open source SDR platform popular for research and education. HackRF One is sold as test equipment, making it exempt from equipment authorization. As Open Source Hardware, however, it is a design that may be modified and sold by anyone. If someone were to use HackRF One as the basis for more specialized open source radio equipment that is not subject to the test equipment exemption, this new equipment would require authorization and would be subject to software security requirements that are incompatible with the open source license. We cannot grant open source licenses to users while locking out those same users. This fundamental incompatibility with open source licensing greatly concerns me. The software security requirements, now that they will apply to non-SDR devices under the proposed rules, will adversely impact not just designers and users of Open Source Hardware but anyone making or using Open Source Software with any radio equipment. Today innovation is stifled by rules that make it difficult or impossible to sell OSHW SDR devices that are anything other than test equipment. Under the proposed rules, even more innovation will be curtailed. I urge you to eliminate the software security requirements for both SDR and non-SDR equipment. Additionally I am concerned about the proposal to grant automatic long-term confidentiality to certain types of exhibits. The Commission's Equipment Authorization database is a great public resource that is better protected by the existing rule that grants long-term confidentiality only upon request.