Hytera: Leading Supplier of Open Standard Digital Mobile Radio Technology

1. Presentation By Hytera at Public Meeting in Docket 2019-009 July 19.2019 2019/7/9 Hytera America, Inc.

2. Who is Hytera Hytera Communications Corporation Limited is a privately held corporation organized under the laws of China, and listed on the Shenzhen Stock Exchange. Hytera, and its subsidiaries, manufacture and supply land mobile radios (LMR) systems and solutions to customers in 120 countries throughout the world including the United States, in a range of sectors including government, public utilities, transportation, hospitality, and education. Hytera and It’s Subsidiaries are the worlds leading supplier of open standard Digital mobile radio Technology and supply over 40% of the Western European Public safety radios (UK, Germany Netherlands etc). Open Standards allow radios to work with competitors radios, ensuring choice and competitive pricing for the customers, this provides benefit to all customers.

3. Hytera’s US Products Digital 2-way Mobile Radio-DMR, focused on Commercial sector Open digital radio standard Combines voice, data, features and applications. Open Standard-Hytera DMR radios work with competitors’ radios

4. Hytera’s US products Not sold to U.S. carriers to provide telecommunications systems Hytera does not supply 5G components Hytera does not supply fixed video surveillance equipment

5. Hytera’s Federal Customers National Gallery of Art National Archives National Zoo Holocaust Museum These federal entities do not play a role in national security and the Hytera systems do not connect to any critical systems. However, the lack of clarity in the implementation of the NDAA has a significant impact on Federal, state and commercial clients, impacting competition and choice.

6. Hytera’s Non-federal customers that may receive federal funding School Systems Hospitals Removal of Hytera from these will provide a lack of choice, competition and will result in higher prices for non-federal and Non-critical infrastructure. Utilities Oil and gas While these can be considered to have critical infrastructure, the systems and products that Hytera provide do not connect to these critical infrastructure.

7. 2019 NDAA Department of Homeland Security has authorized PowerTrunk, a U.S. subsidiary of Hytera, to continue to sell to DOD customers and transportation systems in N.J. and N.Y. In part because Hytera implements the highest level of cybersecurity protections for its equipment. This Authorization was provided at the same time that the NDAA was being finalized. Hytera has never been informed by any U.S. government entity that its equipment posed a national security risk and as such has not been given the opportunity to respond to any concerns. The result of Section 889 is the creation and circulation of misinformation in the marketplace. Part of the Group

8. Proposed Rules and Regulation As the act relates to Telecommunications, and the FCC is the agency responsible for Telecommunications, the rules should explicitly use the FCC definition of Telecommunications. Must clearly define standard for designating an entity a national security concern. Must clearly define type of equipment that poses a national security concern. Must include a due process mechanism that allow challenges to designation of entities or equipment.

9. Proposed Rules and Regulations Should exempt federal agencies that do not include a national security component For example, US Forest service and similar Should exclude equipment that is not used by a carrier to provide telecommunication services under Communications Act Must include coordination with cognizant agencies including DHS, FCC and DOD Exclude equipment not interconnected with the public network, such as private networks private land mobile radios