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esn-fcc.txt
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1994-12-01
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:: Quote ::
PUBLIC NOTICE
FEDERAL COMMUNICATIONS COMMISSION
COMMON CARRIER PUBLIC MOBILE SERVICES INFORMATION
October 2, 1991
Report No. CL-92-3
CHANGING ELECTRONIC SERIAL NUMBERS ON CELLULAR
PHONES IS A VIOLATION OF THE COMMISSION'S RULES
It has come to the attention of the Mobile Services
Division that individuals and companies may be altering
the Electronic Serial Number ( ESN) on cellular phones.
Paragraph 2.3.2 in OST Bulletin No. 53 (Cellular System
Mobile Station - Land Station Compatibility Specification,
July, 1983) states that "[a]ttempts to change the serial
number circuitry should render the mobile station
inoperative." The 1981 edition of these compatibility
specifications (which contains the same wording) was
included as Appendix D in CC Docket 79-318 and
is incorporated into Section 22.915 of the Commission's
rules.
Phones with altered ESNs do not comply with the
Commission's rules and any individual or company operating
such phones or performing such alterations is in violation
of Section 22.915 of the Commission's rules and could be
subject to appropriate enforcement action.
Questions concerning this Public Notice should be addressed
to Steve Markendorff at 202-653-5560 or Andrew Nachby at
202-632-6450.
:: End Quote ::
The staff has informally opined (although the Commission has not yet
formally ruled) that the foregoing prohibits, in addition to the direct
cloning and/or manipulation of the ESN, many of the other schemes to get
around it by "intercepting" and "translating" the ESN. They have proposed
the following rule which will likely be formally adopted sometime in 1994:
:: Quote ::
22.919 Electronic serial numbers.
The Electronic Serial Number (ESN) is a 32 bit binary
number that uniquely identifies a cellular mobile
transmitter to any cellular system. Each mobile
transmitter must have a unique ESN and must comply
with the following specifications.
(a) The ESN must be factory set and must not be
alterable, transferable, removable or otherwise able
to be manipulated in the field.
(b) The ESN host component must be permanently attached to
a main circuit board of the mobile transmitter and the
integrity of the unit's operating software must not be
alterable. The ESN must be isolated from fraudulent
contact and tampering. If the ESN host component does
not contain other information, that component must not
be removable, and its electrical connections must not be
accessible. If the ESN host component contains other
information, the ESN must be encoded using one or more
of the following techniques:
(1) multiplication or division by a polynomial;
(2) cyclic coding;
(3) the spreading of ESN bits over various
non-sequential memory locations.
(c) Cellular mobile equipment must be designed such that
any attempt to remove, tamper with, or change the ESN
chip, its logic system, or firmware originally programmed
by the manufacturer will render the mobile transmitter
inoperative.
:: End Quote ::
As far as staff is concerned, the proposed rule merely clarifies what is
already the law, but they feel that the clarification in necessary because
many in the industry are coming up with so many novel ways to accomplish
the same result in clever ways.
This is not something to be taken lightly for two reasons:
(1) the FCC has gotten rather aggressive in recent years in the number
and size of forfeitures (read "fines") imposed for (even relatively
minor) rules violations, and
(2) doing something like this when your carrier does not authorizes
subjects you to the risk that your cellular unit will be negatively
listed (and therefore rejected as a fraudulent unit).
Note, however, that the staff does _not_ consider it to be a violation for
the cellular carrier to offer this capability by doing some programming at
the cellular switch that associates a single phone number with two or more
_different_ ESN's. Apparently some carriers are starting to do this.
--
Bob Keller Robert J. Keller, P.C. Internet: rjk@telcomlaw.com
---------- Federal Telecommunications Law Telephone: +1 301.229.5208
KY3R 4200 Wisconsin Ave NW #106-261 Facsimile: +1 301.229.6875
Washington, DC 20016-2143 USA CompuServe UID: 76100.3333
Archived as a public service by Phoenix Rising Communications.