[sdiy] Advice for selling gear: FCC part 15 certification?

[metasonix at earthlink.net]

Grant Richter wrote:
> The analog modules fail the definition of a digital device, therefore part
> 15 is not applicable.

Same here. I'm assured that since the TM modules don't contain
microprocessors or digital clocks, Part 15 doesn't apply to them.
And TMs are put in massive cast-aluminum enclosures. I fail to
see how any RFI could come out of them. The TM-3 with MIDI is
shipped requiring some minor (trivial) assembly, so we can call it a kit.
I don't see enough of them selling to justify $5k for testing anyway.
They're so well shielded that I can't detect ANY RF coming out of one--
and I tried, using a borrowed spectrum analyzer and antenna.

> It would be interesting to see a lawyer prove an op-amp is digital.

Are you willing to pay for a defense attorney to see it happen? I'm not...

According to a local lawyer whom I talked to about this (he has written
several of the Nolo Press books), if some bastard in the US really wanted to
make my life miserable, he could sue on the basis of all kinds of product
liabilities. They need not even be provable or valid--I'd have to
retain an attorney, who'd demand $20k or more just to defend me against
baseless accusations. But I really don't have much to worry about, not
with such specialized equipment in such a small market. So the professional
opinion is, "don't worry about it, and don't waste your scarce money on
liability insurance. You're not worth pursuing."

This is how our corrupt system works. And this is why 95% of
mass-market music equipment is now digital, made outside the US,
and uses wall warts for power. And why you can't walk into
the average music store and play with a modular synth.

You HAVE to be small, and slightly mercenary, to make modular stuff today.
(I don't think Roger Arrick counts as a "big" manufacturer,  he does modulars
as a sideline, like a hobby.) So I doubt very much that electrical safety or
EMC regulations really matter in this area. Modulars are not intended for
use by the average consumer.

No "smart" investor would give money to a US manufacturing company
to make modulars. He'd research into the market, and say:
"less than $2 million per year in gross sales? Roland and Korg
are the competition?? And 95% of musicians don't know how to use
them? Sorry, I'd rather give my money to WorldCom or Enron,
they have PROFESSIONAL managers, and they are in SERIOUS businesses..."
or they used to be.....

I saw that with Svetlana. The owners of Svetlana USA tried very hard to
get $2 million of outside investment capital for the Svetlana tube factory.
They were LAUGHED at. "You're crazy, nobody wants TUBES!! We're putting
all our money into the FUTURE!! Dot-coms!!" And those "smart investors"
lost every penny....meanwhile, the demand for audio and transmitting
tubes just keeps growing, slowly albeit.

I read recently that the stock-market decline that started in early 2000
made something like $6 TRILLION in inflated stock valuations simply
disappear. Rambus stock peaked at $400 a share, and now it's like $1
per share.....But guys like me, Paul Schreiber or Grant Richter have to
run up our personal credit cards to buy parts to make music equipment.

> To my knowledge, none of the 6500 Moog modules or 15,000 Serge modules has
> generated an RF interference complaint.

Apparently a lawyer in the electronics industry would look at a modular
synth and say, "This thing is like a kit. Some technical knowledge is
required. Drop your complaint. The FCC is overextended and underfunded
anyway...."