I agree it does costs money to be in business but you have to be reasonable...
You laugh at my post but figure this.. even if you sold less than 500 units the recurring costs for you would still be $30,0000/500 and that would still be $60.00, plus the costs of the parts say $80.00 (conservative) and then the $50-100 labor costs and it would still be less than $250.00! Why is it costing close to $1000.00?
I'm sure you've sold over 500 units Keith.
A good example of the costs is the Talking House transmitter... it's not selling for $1000.00 is it? It's selling for $150-200 range and it's also certified isn't it? Why aren't they selling the unit close to yours in cost?
The example I posted in my previous post stands true whether you believe me or not... surely someone has worked in the engineering division where they had to price the per unit cost after engineering, tooling, planning, and delivery of the items...
Right now it costs an average of $15 million to develop a video game for Xbox, Playstation, or Nintendo but the costs at the store including shipping that game is less than $50.00, WHY because of the dividing the cost over so many units whether the game is sold or not at the store... This is nothing new in the industry...
I'm not attacking you Keith, I think you're an excellent person to deal with just as Phil of SSTRAN and I do know that for a fact!
Radiopilot
There really are posting guidelines here, and these guidelines are based on the rules of logic and debate. Poisoning the well is specifically forbidden and everyone needs to stop that.
Admin rant over
Experimental broadcasting for a better tomorrow!
Hello again radiopilot, I didn’t mean I was laughing at you (you are tough) I just chuckle to myself at the concept of selling 100,000 units.
I seem to always be on the defense here. Your numbers are just wrong, I never get $1000 for the units, I get $500-$900 depending on who it is and the quantity. I’m sure you understand the retail wholesale pricing system.
Your parts costs are way off, The unit uses the some very expensive parts. Have you ever seen the box the unit comes in? Made in Germany, fiberglass with a ¼” thick wall. But like I said before already, I am on a shoestring. And like I said already I sell the unit as cheaply as I can.
The talking house (Infomax), I cut this right of their brochure:
Technical Services
With every InfoMAX, ISS provides an illustrated instruction manual, frequency selection and
telephone installation assistance.
Installation
The antenna and tuning unit are installed outside, generally on a roof. The InfoMAX
transmitter and other components are typically installed inside.
Budget
The InfoMAX costs $899 (including freight) with many added options possible (see below).
Rental runs $195 per month.
The talking sign is approx $600 (Hey you’ve got me advertising my competitors!) It can be found by googling talking sign.
As far as manufacturing that is what I do! I am a consultant for Analog devices, Raytheon, ect.
Mostly the low cost we see for some of these products is because of overseas production which is a whole other subject I tend to have a bug in my craw about. We had an ipod accessory recently we developed for a local company, we took it to China to make just 1K units. I had spec’ed a battery holder that the Chinese could have gotten in the UK. Because of the Chinese tariff system it was cheaper for the Chinese factory to tool up a plastic mold and mold 1000 battery holders there in China, then it was just to buy the holders form the UK! Apparently the Chinese discourage imports but export with little or no tariffs. At least in that case. I just don’t get it.
Radiopilot, seriously, if you have other issues that you want to grill, oops, ask me about you can e-mail me directly, I will respond. I don’t want to tie up the board with a tit for tat useless information exchange.
Keith,
The ISS website you quote does not make or produce the Part15 AM transmitters anymore for a long time... here is the website:
http://www.theradiosource.com/products.htm
Second you can buy the Talking House AM transmitter new for $99.00 brand new from Ebay and less if you don't need the box and instructions, etc. and perhaps used:
http://search.ebay.com/search/search.dll?from=R40&satitle=talking+house+transmitter&category0=
Keith I have nothing to hash with you.. the truth speaks itself and if you do need to speak to anyone it's your competitors.
I'll leave it at that as I have no vested interest in SSTRAN, just a user of their fine product, and the Range master itself is a fine product.
Regards,
Radiopilot
WDCX AM1610 Part 15
John
Owner-Operator-Chief Engineer-Program Manager
Hamilton is correct in stating that this market is not as large as it appears. I would guess that the largest quantity of units sold would be the SSTRAN units because of their affordable price - perfect for hobbyists with construction skills. Others who do not have the skills, but love the attractive low price get someone else to build it for them. Great idea, but unfortunately, not legal according to the FCC rules.
With the higher priced certified units, I would guess that sales would be a few dozen to maybe 1 or 2 hundred in a year if you are lucky. Because of the nature of AM transmitters and the technical/performance issues such as range etc., a large amount of support is required that uses up tons of time (time = money). Therefore, this specialized item does command a higher cost when ready-built with mandatory certification, although this is not obvious to a potential buyer. Also, how much is "ready-built" + "certified" worth to an individual? A good analogy is: materials to finish your basement = $2,000. Getting someone to do it for you $20,000. The difference is labour and knowledge required. We seem to have no issues with this though.
In comparison, items like DVD players that are built in thousands to be sold at Wal-Mart for $30 have a vastly greater demand than a low range AM transmitter. So coming up with a large development cost at the front end is a no-brainer because costs are spread over thousands of units which will be sold with very little support required. The unit either works or is doesn't.
As mentioned in a previous thread, I was considering offering a kit for a new transmitter, but after reading many of the posts, I have decided to produce a certified unit. I have agonized over what to charge considering the products that exist at present: my goal is to offer the very best possible unit with the most desired features for a reasonable price. BTW, the 2nd prototype boards are out being manufactured now with feature feedback gained from this forum. I will keep you posted as to the progress.
Very interesting posts - keep it up!
Gerry
Gerry,
Please remember my offer to test one of your prototypes. I can compare its performance against a SSTRAN with the base-loaded antenna. I get pretty good performance with the SSTRAN. It would be very interesting to see how your unit compares under the same conditions. From what you have posted so far, I would think your transmitter should perform better. I would also be willing to write a review for posting here, if you wish.
If you would like to discuss this further, email me at [email protected]. That address is a throwaway account that I use, so I don't check it too often. When I get your email, I will send you my real email address.
I can tell you that for 1 offs, that NEMA box Keith puts the tx in is about 75 bucks alone. The boards he uses are really good heavy duty stuff, and the components aren't the cheapo crap you get from Hsing Mae's China Bistro and Electronics Lab. Last I checked, including testing fees and licensing fees it was 15,000.00 USD to certify a unit. Then, if you make a change to the design, it's time to re-cert.
15MM for a video game is not the average. That's for the big titles with a ton of work in them. The stuff like Sponge Bob's Bikini Adventure is more of a 700K investment. Some indies do it for about 10K. Then you have hundreds of thousands of people buying the games. 200,000 people paying 50.00 for a 700K investment is a pretty darn good return. If it's super popular (World of Warcraft) - costs usualy do range in the millions, but you have 8 million people playing it @ 15.00/mo and a 50.00 initial outlay of cash.. wow (no pun intended). Take a look at our radio station list - even if there were 10x that, is that enough of a market for Hamilton, Talking House, SSTran, Antique Radio, Georges Emporium of Toutbait and Radio Transmitters, and the 50 million other people making a kit?
The FCC has just published a FORFEITURE ORDER that is related to the NAL that is the subject of this thread:
http://www.fcc.gov/eb/Orders/2007/DA-07-4716A1.html
At the same time, they have published an NAL that was issued to another person who was assembling SSTRAN kits, and selling the assembled kits:
http://www.fcc.gov/eb/Orders/2007/DA-07-4570A1.html
The penalty in both cases is the same, $7000.
The assembler of SSTRAN kits for resale has appealed the Forfeiture Order for $7000, and, moreover, continues to construct SSTRAN kits for resale. This time, he is leaving some trivial assembly tasks for the customers, petending that he is selling kits. The new Order can be found on:
http://www.fcc.gov/eb/Orders/2008/DA-08-968A1.html
The assembler of SSTRAN kits for resale has appealed the Forfeiture Order for $7000, and, moreover, continues to construct SSTRAN kits for resale. This time, he is leaving some trivial assembly tasks for the customers, petending that he is selling kits. The new Order can be found on:
http://www.fcc.gov/eb/Orders/2008/DA-08-968A1.html
Well, I'm not sure how one can conclude that he is "pretending". After being hit for selling completed kits, he apparently went to offering partially completed ones. That could be an honest attempt to comply, and not knowing him personally or his motives, I wouldn't care to comment as to whether he intentionally is attempting a pretense.
As to what degree of assembly is necessary before something is considered a "unit" as opposed to a "kit", so far as I am aware, that is not well defined. This particular action is interesting since it likely will result in at least some precedent being set on that matter.
Now with radios sold as 10 meter ham transceivers that can possibly be modified for use in the 11 meter CB band or whatever they currently call the space between those two bands, I have seen a precedent/rule quoted in the FCC field actions that's something about those being illegal if the unauthorized operation can be accomplished by something like setting a switch or soldering in a single wire. I don't recall the exact wording offhand, but I've seen it in a few of them over recent months.
In any case, there's a fairly clear guideline/precedent there. If this case results in a clear precedent of that nature for kits sold for part15 operation, I think that could be very good for the hobby.
Personally, on my "wish list" for things I wish the FCC would do regarding kits is that I'd like to see a precedent/rule requiring that kits be at least to some degree educational. That is, that the assembly manual would written have the person buying the kit complete and test the circuits in stages with some explanation of the theory as they complete the kit to make the finished unit. Especially whatever testing is necessary to ensure that the kit is operating in compliance with the appropriate part15 sections for its band/type of operation. Ideally, all such measurements/testing would require very affordable tools, like a multimeter and a standard BCB receiver.
That'd be enough with a part15 AM transmitter to check for correct power supplied to the final RF stage and to check and see if the transmitter was putting out spurs for any reasonable distance/power on at least the harmonic at 2*F.
Admittedly, not as simple for FM because compliance is measured differently, but one could at least test to ensure the transmitter built from a kit wasn't out of compliance to a ridiculous degree. Others are welcome to their own opinions, but I feel that if a kit delivers say 200 mw to the antenna terminal and explains how to make a dipole or groundplane cut to frequency, there is *no* way that the kit manufacturer/supplier can possibly think it would actually be in compliance if they have even some understanding of the rules and/or general electronics. Now there I would say the supplier is clearly "pretending" that the unit could be part15 compliant when they advertise it as such. That sort of kit would put out many thousands of times more power than is allowed. The only way I can think of that such a kit *might* be operated in a compliant fashion would be to maybe put the transmitter and antenna in a metal refrigerator and close the door before turning it on. I'm not sure if that'd work to bring the power it actually radiates down to 250 uV at 3 M, but it *might*. My point is that the people selling some of those kits are putting out kits that don't appear to be even remotely resembling something that might be intended for legal operation.
To be honest, for part15 FM, I've given it a lot of thought and asked a lot of questions and so far as I can tell there is simply no way a hobbyist can be certain that their kit or homebrew circuit is in compliance. But for AM it is quite possible to measure and do a few simple checks before putting it on the air regularly.
I personally feel that a large part of the reason that the FCC allows kits and homebrew is to encourage/foster learning and responsible experimentation. Which is excellent, and worth keeping as an objective in the part15 rules.
This case is very interesting, since it may result in a clear precedence/rule regarding what actually constitutes a kit for at least part15 AM. My interpretation of the statements in the FCC orders so far is that they want *more* building to be necessary by the end user than they would consider necessary for the Ham/CB transceivers need to qualify for the modification for outband operation to be considered as being already manufactured to operate in an illegal fashion.
To clarify, I would think that since the chips are critical components and the transmitter will not operate at all without them, it is more stringent if that doesn't qualify as "not fully assembled" when with the ham/cb radios are considered as being sold as an illegal "hybrid" if it takes a switch setting or a single wire soldered in place to enable illegal outband operation. From what I understand, those would be legal for sale if it took as much work by the end consumer as to have to install a component like a chip. It'd be considered that the modification had been done by the user and was not supplied as "ready to run" that way by the manufacturer.
But perhaps I'm missing the logic involved or the FCC's inent on this matter and it may become more clear as the case progresses.
To be fair, I'm not 100% sure I understand Richard Mann's logic either. It appears to me that he may be trying to determine what degree of assembly he *can* do and have the item still considered a kit for the end user. Or it might be more correct to say he has attempted less assembly on his part and that too has been judged by the FCC as unacceptable.
On a side note, anyone have any thoughts on what sort of impact the "Plain Language in Government Communications Act" might have on FCC regulations if it becomes law?
Daniel
Well, I'm not sure how one can conclude that he is "pretending". After being hit for selling completed kits, he apparently went to offering partially completed ones. That could be an honest attempt to comply, and not knowing him personally or his motives, I wouldn't care to comment as to whether he intentionally is attempting a pretense.
As to what degree of assembly is necessary before something is considered a "unit" as opposed to a "kit", so far as I am aware, that is not well defined. This particular action is interesting since it likely will result in at least some precedent being set on that matter.
Now with radios sold as 10 meter ham transceivers that can possibly be modified for use in the 11 meter CB band or whatever they currently call the space between those two bands, I have seen a precedent/rule quoted in the FCC field actions that's something about those being illegal if the unauthorized operation can be accomplished by something like setting a switch or soldering in a single wire. I don't recall the exact wording offhand, but I've seen it in a few of them over recent months.
In any case, there's a fairly clear guideline/precedent there. If this case results in a clear precedent of that nature for kits sold for part15 operation, I think that could be very good for the hobby.
Personally, on my "wish list" for things I wish the FCC would do regarding kits is that I'd like to see a precedent/rule requiring that kits be at least to some degree educational. That is, that the assembly manual would written have the person buying the kit complete and test the circuits in stages with some explanation of the theory as they complete the kit to make the finished unit. Especially whatever testing is necessary to ensure that the kit is operating in compliance with the appropriate part15 sections for its band/type of operation. Ideally, all such measurements/testing would require very affordable tools, like a multimeter and a standard BCB receiver.
That'd be enough with a part15 AM transmitter to check for correct power supplied to the final RF stage and to check and see if the transmitter was putting out spurs for any reasonable distance/power on at least the harmonic at 2*F.
Admittedly, not as simple for FM because compliance is measured differently, but one could at least test to ensure the transmitter built from a kit wasn't out of compliance to a ridiculous degree. Others are welcome to their own opinions, but I feel that if a kit delivers say 200 mw to the antenna terminal and explains how to make a dipole or groundplane cut to frequency, there is *no* way that the kit manufacturer/supplier can possibly think it would actually be in compliance if they have even some understanding of the rules and/or general electronics. Now there I would say the supplier is clearly "pretending" that the unit could be part15 compliant when they advertise it as such. That sort of kit would put out many thousands of times more power than is allowed. The only way I can think of that such a kit *might* be operated in a compliant fashion would be to maybe put the transmitter and antenna in a metal refrigerator and close the door before turning it on. I'm not sure if that'd work to bring the power it actually radiates down to 250 uV at 3 M, but it *might*. My point is that the people selling some of those kits are putting out kits that don't appear to be even remotely resembling something that might be intended for legal operation.
To be honest, for part15 FM, I've given it a lot of thought and asked a lot of questions and so far as I can tell there is simply no way a hobbyist can be certain that their kit or homebrew circuit is in compliance. But for AM it is quite possible to measure and do a few simple checks before putting it on the air regularly.
I personally feel that a large part of the reason that the FCC allows kits and homebrew is to encourage/foster learning and responsible experimentation. Which is excellent, and worth keeping as an objective in the part15 rules.
This case is very interesting, since it may result in a clear precedence/rule regarding what actually constitutes a kit for at least part15 AM. My interpretation of the statements in the FCC orders so far is that they want *more* building to be necessary by the end user than they would consider necessary for the Ham/CB transceivers need to qualify for the modification for outband operation to be considered as being already manufactured to operate in an illegal fashion.
To clarify, I would think that since the chips are critical components and the transmitter will not operate at all without them, it is more stringent if that doesn't qualify as "not fully assembled" when with the ham/cb radios are considered as being sold as an illegal "hybrid" if it takes a switch setting or a single wire soldered in place to enable illegal outband operation. From what I understand, those would be legal for sale if it took as much work by the end consumer as to have to install a component like a chip. It'd be considered that the modification had been done by the user and was not supplied as "ready to run" that way by the manufacturer.
But perhaps I'm missing the logic involved or the FCC's inent on this matter and it may become more clear as the case progresses.
To be fair, I'm not 100% sure I understand Richard Mann's logic either. It appears to me that he may be trying to determine what degree of assembly he *can* do and have the item still considered a kit for the end user. Or it might be more correct to say he has attempted less assembly on his part and that too has been judged by the FCC as unacceptable.
On a side note, anyone have any thoughts on what sort of impact the "Plain Language in Government Communications Act" might have on FCC regulations if it becomes law?
Daniel
Rattan,
Thank you for pointing out my error. Maybe I was overly influenced by how the FCC characterized this gentleman's actions. Who knows, perhaps this matter will be litigated further. I will try to be more circumspect as I coment on this matter some more:
Part 15 does not address the legality of kits directly. It looks like the FCC accepts kits as home-built devices, and Part 15 allows each person make up to five such devices for personal use. The kit builder (or home-brewer) is responsible for the proper technical performance of the devices. I note that SSTRAN provides the service of installing a surface-mount IC for their customers for a small fee. This is not enough to disqualify the SSTRAN as a kit in the view of the FCC.
It may have been an error on the part of the the kit assembler to advertise on his web site how easy the final steps left to the customer are, and that no tools are required. The FCC seems to have characterized the kit assembler's representations as a "sham."
About 30 years ago, it was common to see classified advertisements in the backs of popular technical magazines offering certificates of ordination for a small fee. These certificates were from entities representing themselves as churches. This allowed the recipient of the holy orders to transfer his assets to his own church, and shield his income from taxation. The IRS ruled that such arrangements were transparent attempsts to avoid paying taxes, and many of the new clergymen got into trouble. I know of one particular case where a fairly large business was transferred to such a church, and the penalties and interest assessed by the IRS forced the pastor/businessman to sell out to another company.
I think that if someoneone is trying to do something like the kit assembler did, even before seeing a lawyer, one should consider for himself if the arrangement appears to be reasonable. To put it another way, does the scheme pass the "smell test?"
Rattan,
Thank you for pointing out my error. Maybe I was overly influenced by how the FCC characterized this gentleman's actions. Who knows, perhaps this matter will be litigated further. I will try to be more circumspect as I coment on this matter some more:
Part 15 does not address the legality of kits directly. It looks like the FCC accepts kits as home-built devices, and Part 15 allows each person make up to five such devices for personal use. The kit builder (or home-brewer) is responsible for the proper technical performance of the devices. I note that SSTRAN provides the service of installing a surface-mount IC for their customers for a small fee. This is not enough to disqualify the SSTRAN as a kit in the view of the FCC.
It may have been an error on the part of the the kit assembler to advertise on his web site how easy the final steps left to the customer are, and that no tools are required. The FCC seems to have characterized the kit assembler's representations as a "sham."
About 30 years ago, it was common to see classified advertisements in the backs of popular technical magazines offering certificates of ordination for a small fee. These certificates were from entities representing themselves as churches. This allowed the recipient of the holy orders to transfer his assets to his own church, and shield his income from taxation. The IRS ruled that such arrangements were transparent attempsts to avoid paying taxes, and many of the new clergymen got into trouble. I know of one particular case where a fairly large business was transferred to such a church, and the penalties and interest assessed by the IRS forced the pastor/businessman to sell out to another company.
I think that if someoneone is trying to do something like the kit assembler did, even before seeing a lawyer, one should consider for himself if the arrangement appears to be reasonable. To put it another way, does the scheme pass the "smell test?"