June 23, 1997

Mr. Robert J. Ungar
Arter & Hadden, Attorneys for EDAP Technomed
1801 K Street, N.W. / Suite 400K
Washington, DC 20006-1301

Dear Mr. Ungar:

As you are aware the Jupiter Space Station is a radio astronomy research facility which conducts solar and lunar experiments at the 1296 MHz frequency, which is in conflict with the harmful interference produced by your new Prostatron being marketed on the Internet.

This letter is a follow-up to your two letters of May 5 and June 9, 1997. Between these two letters we responded with a proposal to EDAP Technomed to cooperate in a manner so as to share the 1296 MHz frequency with EDAP.

Your response of June 9. 1997 indicates that both you and EDAP Technomed are confused as to our position on our 1296 MHz objection to the FCC. We wish to now restate our position and clear up some of your confusion.
 

1. You stated in your letter of May 5 that "we (sic The Jupiter Space Station, JSS) intend to use the frequency 1.296 MHz to bounce radio signals off the moon..." and later "FAA radars operating around the 1.296 MHz band..."

Please understand that our frequency is either 1296 MHz or 1.296 GHz, not the above listed frequency... let us be sure that the basics are clear.
 

 2. You stated that JSS had a "perceived problem with the potential interference..."

Based on the initial report of FCC testing results for the Prostatron there does not exist a "perceived" problem... the Prostatron generates radio frequency interference (RFI) or FCC defined harmful interference in excess of FCC allowable limits. This is not a perception on our part, Mr. Ungar, this is a published fact in the public domain. Since EDAP is not yet a shared user of the 1296 MHz FCC frequency allocation, we would appreciate that you refer to the Prostatron emissions as either "RFI" or FCC defined "harmful interference."
 

3. You stated twice that "any significant threat of interference to you comes not from a Prostatron device, but from U. S. Government operated radar."

Our research frequency is in a band where the FAA is the primary user and we in the Amateur Service are secondary users. We understand that the FAA signal may be received by our antennas; however our site surveys have yet to see any FAA radar signal. In any case, if we did have any FAA radar signal, the signal is clean, precise, well documented, and transmitted in a pulsed mode which we can easily identify and null out of our research data by using transfer functions in digital signal processing (DSP). The RFI generated by Prostatron can not be easily detected and requires a full bandspread analysis to isolate it, and yes, with extremely expensive equipment. The JSS does not own or employ spectrum analyzers because we by cooperating with our primary user, the FAA, have developed compatible microwave systems in their signal nature and operation. EDAP Technomed in its best light has created a 1296 Band interference emission source, Prostatron.
 
 

Mr. Robert J. Ungar
June 23, 1997
Page 2
 
 

4. You have conjured up the idea that Mr. Manning and your letter have persuaded JSS that the threat of interference from the Prostatron is "not as dire as we feared."

In our phone conversation Mr. Manning seemed baffled by the fact that the CW radio power level of the Prostatron (60 watts) could be sent by our Link Station in Tulsa to the moon, bounced back to Earth (a 500,000 mile round trip), and detected by our Link Station in Pendleton, SC. Obviously no one wants any of this Prostatron RFI radiation in their noise floor from a moon bounce, much less from the same section of the country. The Jupiter Space Station is not assuaged by your technical arguments.
 

5. You stated that "JSS is concerned with other radio sources as well."

JSS is not concerned with PCS signals entering our microwave system; we are most concerned with hitting one of Bill Gates' proposed 800 "Birds" with our signal.  And this is one of the reasons why the FAA respects us: because we show operational prudence and shielded/filtered microwave equipment design so as to be a good partner on 1296 MHz, unlike EDAP Technomed.

In rank order priority, here is our position on your FCC waiver request:

We have been more than considerate in offering you an alternate solution to these problems created by your device; please go back to the drawing boards to reconsider how you want to be a responsible partner with the legal users of 1296 MHz.
 

Respectfully Submitted,
 
 

John D. Bernard, JSS Project Director

cc: Dr. Michal J. Marcus,                                    FCC
      Steven Butcher,                                            NTIA
      American Radio Relay League
      Eric Poincelet,                                              EDAP Technomed
      Thomas N. McCausland,                                Siemens AG - Siemens Medical Systems
      Nippon Eurotech
      US Senator Strom Thurmond (SC)
      US Senator Fritz Hollings (SC)

note: This response can also be viewed on the Internet at: http://members.carol.net/~saser