first mention of twins

ill try keep this nice.

i think the whole hype about Rpi being the big bad educational tool was nothing more than a pr stunt to get it selling quick, and that is just what happened. i also remember hearing somthing about this being developed by employees of broadcom, when it was first released the soc data sheet required a nondisclosure agreement, so right out of the gate there were problems calling it open source.

i'm sorry if i dont get the idea about teaching computer science with an embeded linux board. don't comp sci cources use full-blown computers already? and if you really want to learn about how computers work, it is much better to start with an 8051 or 8088 and assembly.

but now it seems the more i read, the more i can't suggest the pi for any use other than a media center.

anyways thats my two bits on the the pi.

sheldon bailey wrote:

 

but now it seems the more i read, the more i can't suggest the pi for any use other than a media center.

Professionals who are aware of the relevant  FCC regulations shouldn't be suggesting the Pi for use in any residential application in FCC jurisdiction anyway, since the device does not have FCC certification for residential use.  That would be a Class B certification, and it doesn't have one at the present date.

I doubt that anyone would deny that media centres constitute an overwhelmingly residential or domestic use of a digital device.  It's probably as close to being a poster child for residential use as one could find anywhere.

coder27 wrote:

 

for the record, I have tried to locate the first professional to credit for raising

the issue of Class B testing.  Does anyone have any earlier reference than

https://twitter.com/abishurp/status/188635726030708736

Was that posted in April of this year, or 2012?

For our part here on Element14, all the credit clearly has to go to yourself for nailing this issue near the beginning of Pi time and persevering with it until today.  It was only extremely recently that I finally picked up on your FCC links in detail, and was amazed by what I read there.

If Element14 had paid attention to your postings on the subject last year, they wouldn't be in this risky situation they are in today.

Was that posted in April of this year, or 2012?

It was 7 April 2012.

perhaps the problems with certification was engineered into the Rpi to prevent it from being used as an OEM part of a finished comercial product. keeping it in the educational or maker spaces.

probably not the case.

a really slick lawyer might claim that the Pi is just a populated motherboard and is thus exempt

The UK's BIS has already ruled that it was a finished product.

The E14 FAQ says:

http://www.element14.com/community/docs/DOC-43262/l/updated-15-march-frequently-asked-questions-about-raspberry-pi

HOT OFF THE PRESS UPDATE FROM EBEN UPTON OF RASPBERRY PI EARLIER TODAY:

“We have spoken with BIS this morning, and have been told that, given the volumes involved and the demographic mix of likely users, the development board exemption is not applicable to us; as a result, even the first uncased developer units of Raspberry Pi will require a CE mark prior to distribution in the EU...... ....we are working with RS Components and element14/Premier Farnell to bring Raspberry Pi into a compliant state as soon as is humanly possible.”

and

Over the past weeks, it is clear that customers who have pre-ordered are going to use the Raspberry Pi as a finished product and not just an engineering development board.  We see it as the most responsible approach to ensure that all Pi’s meet the required standards for finished products in their respective country. We are prioritizing the compliance testing process by working closely with the Raspberry Pi foundation and RS Components to make sure there are no more delays.  We take our commitment and responsibility in this area very seriously and believe that while this is a frustrating short-term delay, it’s worth it to ensure our customers receive a fully compliant product.

It would be quite startling to see their position change to it being a finished product in the UK but not in the US.

There are plenty of published articles and interviews describing the RPi as a computer intended for children's bedrooms.

http://blog.ted.com/2013/06/14/wherefore-raspberry-pi-eben-upton-at-tedglobal-2013/

What is a Raspberry Pi?

It’s a credit-card sized computer ...

...

“Our idea was to build something cheap, powerful and available for children’s bedrooms so they could have the same experience we had.”

The prosecution rests. For now.

is there a thread or source why it failed compliance, and what standards were used to determine?

i would like to look into this a little more.

See Pete Lomas's blog here:

we have some definite options for ripping 10db or more off the key gremlin frequencies. Before you ask, yes, this should be enough.

http://www.element14.com/community/people/PeteL/blog/2012/03/29/spikes-in-the-ether-emc-and-compliance

and my unanswered question:

Are you trying to meet the Class A industrial standard, or Class B residential?

http://www.element14.com/community/people/PeteL/blog/2012/03/29/spikes-in-the-ether-emc-and-compliance#comment-13097

Similarly:

http://www.element14.com/community/people/PeteL/blog/2012/04/07/certification-testing--update

Jonathan Garrish wrote:

 

The prosecution rests. For now.

I sure hope that the message Element14 received was not about prosecution but about preventing bad things from happening before they happen.  After all this analysis of the regulatory situation perhaps we can rest, but Element14 cannot.  They have an official group-wide Code of Ethics  to adhere to, so I'm sure they are taking the matter seriously now that they have been alerted to the problem.

Every single stakeholder  in the Pi ecosystem is at risk (in different ways) because of this certification error, from suppliers to importers, distributors, retailers, users operating unintentionally radiating devices without knowing it, and other people in the residential vicinity of those devices who could be affected by them.  There is a very good reason for requiring residential certification, it's not just a pointless burden on manufacturing.  It's to prevent bad things from happening, a part of engineering and social responsibility.

Alas, there is still no acknowledgement of this week's advice in Feedback & Support on this matter.

There are some bits here and there but nothing conclusive or detailed ...

This is one of the classic ones were we get but don't get some information ...

http://www.raspberrypi.org/archives/978

Pay attention that at that time they realize the even when  "at the Foundation call the computer a Raspberry Pi in conversation" "This thing’s called a Raspberry Pi, not a Raspberry Pi computer"

So we (they) call it a computer but is it not.... ohhh right now is a "linux box"

But first line on "About us" ...

"The idea behind a tiny and cheap computer for kids came in 2006"

So it is or it is not a computer ? ... perhaps Shakespeare can provide some light into this identity crisis.

On thing that they really missed big on the entire strategy and inspiration, is the context in the days of the BBC Micro and such.

-J

jamodio wrote:

 

There are some bits here and there but nothing conclusive or detailed ...

 

This is one of the classic ones were we get but don't get some information ...

 

http://www.raspberrypi.org/archives/978

 

Pay attention that at that time they realize the even when  "at the Foundation call the computer a Raspberry Pi in conversation" "This thing’s called a Raspberry Pi, not a Raspberry Pi computer"

 

So we (they) call it a computer but is it not.... ohhh right now is a "linux box"

 

But first line on "About us" ...

 

"The idea behind a tiny and cheap computer for kids came in 2006"

 

So it is or it is not a computer ? ... perhaps Shakespeare can provide some light into this identity crisis.

 

On thing that they really missed big on the entire strategy and inspiration, is the context in the days of the BBC Micro and such.

 

-J

Indeed - the road to a lucrative career in Law is paved with semantics.

Regarding Pete Lomas' blog - I see he's not even logged into his account here since October 2012.

Morgaine - obviously "getting the paperwork done right" is a given - especially considering the inordinate amount of time that the RPF have spent promoting their product Stateside. It all just makes no sense as there is absolutely nothing to be gained, but a lot to be lost by not getting the relevant certifications

jamodio wrote:

 

There are some bits here and there but nothing conclusive or detailed ...

 

This is one of the classic ones were we get but don't get some information ...

 

http://www.raspberrypi.org/archives/978

 

Pay attention that at that time they realize the even when  "at the Foundation call the computer a Raspberry Pi in conversation" "This thing’s called a Raspberry Pi, not a Raspberry Pi computer"

 

So we (they) call it a computer but is it not.... ohhh right now is a "linux box"

 

But first line on "About us" ...

 

"The idea behind a tiny and cheap computer for kids came in 2006"

 

So it is or it is not a computer ? ... perhaps Shakespeare can provide some light into this identity crisis.

 

On thing that they really missed big on the entire strategy and inspiration, is the context in the days of the BBC Micro and such.

 

-J

Indeed - the road to a lucrative career in Law is paved with semantics.

Regarding Pete Lomas' blog - I see he's not even logged into his account here since October 2012.

Morgaine - obviously "getting the paperwork done right" is a given - especially considering the inordinate amount of time that the RPF have spent promoting their product Stateside. It all just makes no sense as there is absolutely nothing to be gained, but a lot to be lost by not getting the relevant certifications

Indeed - the road to a lucrative career in Law is paved with semantics.

So how many semantic issues do you detect in the opening line of

Eben's March 2013 pycon keynote speach:

[Eben]: Thankyou guys. So, my name is Eben Upton, I run a thing based in the UK called the Raspberry Pi Foundation. Ah, we make little computers for kids.

https://github.com/robotclass/pycon-us-2013-keynote-eben-upton/blob/master/keynote-eben-upton.textile

coder27 wrote:

 

Indeed - the road to a lucrative career in Law is paved with semantics.

 

So how many semantic issues do you detect in the opening line of

Eben's March 2013 pycon keynote speach:

[Eben]: Thankyou guys. So, my name is Eben Upton, I run a thing based in the UK called the Raspberry Pi Foundation. Ah, we make little computers for kids.

https://github.com/robotclass/pycon-us-2013-keynote-eben-upton/blob/master/keynote-eben-upton.textile

I'd say that in my opinion that opening sentence was explicit and not open to misinterpretation by any reasonable person.

#1) He's still leaning on the Foundation for promotional purposes, rather than on Raspberry Pi (Trading) Ltd - of which he is listed as a director.

#2) He's promoting his organisation's consumer product. Computers, if I'm not mistaken.

Have I missed anything?

Being a portable computer by the FCC definition  would automatically define Pi as a Class B device.

Note however that it's captured as a Class B device anyway, even without the above, because if falls foul of the FCC's three key questions that distinguish between devices of the two classes:

1. Is the marketing of the device restricted in such a manner that it is not sold to residential users?
2. Does the application for which the device is designed generally preclude operation in residential areas?
3. Is the price of the device high enough that there is little likelihood that it would be used in a residential environment, including a home business?

Since it fails to be excluded from the residential environment through restricted marketing and sales (point 1), and it cannot avail itself of the exemptions in points 2 and 3, by FCC rules it is a Class B device anyway, even if someone could retrospectively wish away the fact that it is clearly a portable computer.

A Class B device without Class B certification is uncertified for its expected use, and cannot be marketed or offered for sale to residential users.  If it has Class A certification then it can be marketed or offered for sale as a restricted commercial or industrial device, but that is not  how Pi has been marketed and offered for sale, as anyone can plainly see.

Have I missed anything?

So you would say "I run a thing based in the UK called the RPF, but not officially; we make little computers, but officially just motherboards; it's for kids, but not officially for kids in residential areas."

The 2013 Premier Farnell annual report shows the target audience as "engineers and hobbyists".

Raspberry Pi

The element14 Community played a key role in another very successful

product launch this year. The Raspberry Pi, the credit card sized computer

developed to put computer programming back at the heart of engineers,

launched to phenomenal interest from engineers and hobbyists alike. In the

first 15 minutes after launch our websites received over ½ million hits as

customers flocked to order from us and by January 2013, Premier Farnell

had sold 600,000 Raspberry Pi units.

http://www.premierfarnell.com/sites/default/files/reports/Premier-Farnell-Annual-Report-2012-13(2).pdf

The "educational focus" appears to have come at least in part, from David Braben.  Liz wrote:

David was one of the people Eben brought the original idea to, along with the other trustees and a few others who aren't trustees. He's helped us develop the educational focus behind it, ...

http://www.raspberrypi.org/phpBB3/viewtopic.php?f=63&t=319&start=20

coder27 quoted:

 

"not officially; we make little computers, but officially just motherboards; it's for kids, but not officially for kids in residential areas."

I'd rather not speculate what that meant, but it sounds like something that should have raised a big red flag to Element14 regulatory certification experts.

I'd rather not speculate what that meant, but it sounds like  something that should have raised a big red flag to Element14 regulatory certification experts.

That was my parsing of Eben's quote, not his original quote, just to be clear.

However, there is no doubt that E14's regulatory certification experts had plenty of

red flags.  They didn't need any more of mine.  They certainly knew it was intended

for residential use, and they certainlly acknowledged that it did not pass Class B.

They also acknowledged that BIS had determined that it was classed as a finished product.

How many more red flags does one need?

But it is also clear that there was lots of incentive not to incur any further delays

in a project that had the attention of E14's CEO.  They probably assumed, as Liz

claimed, that achieving Class B certification would be easily obtained. 

Happily, we’ve found it doesn’t need a shielded enclosure to reach Class B, although it will require a (very minimal) redesign.

http://www.raspberrypi.org/archives/978#comment-19273

@coder27: It would then seem that David Braben might be an important factor - if education was indeed the motivation for his involvement. I note that he is part of the Cambridge set though.

PC mag reported in 2011 that Braben was actually the creator of the Raspberry Pi and ran a feature:

http://www.pcmag.com/article2/0,2817,2385055,00.asp

It's this kind of shoddy tech "journalism" that is responsible for the current situation imo. As now, "education" is hinted at, but it's explicitly a hardware sales pitch.

Good work btw.

It would then seem that David Braben might be an important factor

Yes, I think so.  My impression is that Eben's goal is to shift lots of units,

regardless of where they are shifted to, and that fits with his position with the

RP Trading subsidiary.  I don't detect much enthusiasm from him with regard to

developing educational materials.

btw, Abishur credits Liz's legal work for the original determination that compliance

testing wasn't needed until later.

The issue was that originally the boards were going to be released as development boards and therefore didn’t need the CE stamp (Liz is a lawyer, she did her homework ), but due to how many boards there are being ordered and the fact that the first 10K will be released with the main bulk release the distribs decided they wanted them all CE marked.

http://www.raspberrypi.org/archives/852#comment-17096

It's this kind of shoddy tech "journalism" that is responsible for the current situation imo.

I think the "journalists" are only half responsible.  Eben likes to talk about how he was

the Director of Studies at St. John's College at Cambridge University prior to founding

the RPF in 2008, and how he and his Cambridge colleages were motivated by noticing

a decline from the mid 1990's to the mid 2000's in the number and quality of applicants.

So you might assume that Eben was Director of Studies from the mid 1990's to the mid

2000's.   But I believe he graduated from Cambridge with his CS PhD in 2005, and started

work at Broadcom in July 2006.

coder27 wrote:

 

 

But it is also clear that there was lots of incentive not to incur any further delays in a project that had the attention of E14's CEO.

I suppose it's possible that there is a long reporting chain from the regulatory certification people to the E14 CEO, and the red alert got lost somewhere on its trip to the top.  However, it seems unlikely that a CEO would ever countermand regulatory advice --- that would be career-limiting.  What's more, CEOs almost certainly have input to global policy statements  such as those we examined, since they have funding implications.  This makes it even less likely that the regulatory hiccup was at top level, it seems to me.

Unfortunately, arguing from the bottom up doesn't work either, because if you're the local FCC certification expert then you would keep poking at the problem until it gets resolved to your satisfaction (it's your job after all), and you'd be highly unlikely to allow yourself to be ignored.  What's more, you have the law on your side, as well as the company Code of Ethics.  Seriously, there is no way your advice could be sidelined in a serious company like this.

Of course, it could be human error, misreading of the FCC regulations.  The trouble with that is, Title 47 Part 15 is written pretty clearly for engineers and technical management to understand, containing very little convoluted legalese.  And the FCC even went to the trouble to publish the even more simplified OET Bulletin 62, expressly to achieve what it states in its title:  "UNDERSTANDING THE FCC REGULATIONS FOR COMPUTERS AND OTHER DIGITAL DEVICES".  It's not really conceivable that the language there can be misunderstood by someone charged with FCC certification duties.

So, I'm at a loss to understand how this could possibly have happened.