Rotary Un-Smartphone Update: Moving Goalpost

[Justine Haupt]

I usually try to keep updates concise, but in this case, if you're 
already a customer, please read:

The hardware all works! Everything's fixed, more or less, and I can 
produce phones.

Oh wait, what's that, universe? Not good enough? The major US network 
providers started requiring separate independent lab testing 
certification before they let my IMEI numbers on their networks, even 
though the radio hardware I'm using is already approved on those networks?

I'm pretty sure the phone is done. Kits can be put together, and used, 
functional, etc. I have the production process in place and many 
hundreds (and in a few cases many thousands) of parts on hand ready to 
go. Thank goodness, finally, I did it. I can make good on my promise and 
send these out to my long-term pre-order customers, some of you have now 
been waiting just over 2 years. OK so why is this email so long? That 
seems like a bad sign right?

Bring Your Own Device (BYOD) SIM cards have been working fine to date. 
The chip I use to handle the cellular radio functions (called the 
LARA-R6 from uBlox) has already been certified by most carriers, with 
others pending. For the past two years I've been working on this 
project, every time I order a SIM card from a network provider, they ask 
for the phone's IMEI number, I put it in, it comes up as valid (because 
uBlox already went through this process), and they send me the SIM and 
it works. I've been depending on this being the end of the story. And it 
has been.

Except now that seems to have changed.

Verizon is now requiring separate certification from the product 
manufacturers (i.e. me), so if I try ordering a SIM card from them, they 
won't send it unless I (Sky's Edge) have uploaded all the product IMEIs 
to their system, and they won't let me do that until I have independent 
laboratory RF testing called PTCRB Certification, and apparently I can't 
do THAT until I have FCC Part 15 certification. This is new. This was 
not the case before.

AT&T Just started requiring the same kind of thing. I don't know about 
Canadian, European, and other carriers yet. They may be fine, they may not.

I mean, I get it. With current technology trends, there are /so many/ 
small cell-connected devices coming on the market, and carriers need to 
protect their infrastructure from interference and bad actors. And I've 
been circumventing the FCC licensing requirement because I'm selling 
this as a kit, and hey, uBlox had already done all the hard work of 
getting the FCC and carrier compliance out of the way.

But no more, apparently, at least in the US. Manufacturers, however big 
or small, whether it's me or Apple, now have to go through a couple 
layers of additional independent lab testing to be allowed on their 
networks. #@&!

I don't know what to do now. This such a gut punch. The goalpost keeps 
moving. I have you guys, customers, some of your waiting 2 years now, 
and now... what? How long is it going to take me to get the regulatory 
compliance out of the way before the phones work reliably on the 
networks? 6 months? More? I was expecting to send the first batch out 
this past Wednesday and I've been balled up in a corner since I realized 
the new SIM cards I just got won't register to either AT&T or Verizon. I 
tried Consumer Cellular but that's actually T-Mobile and that 
verification is still pending anyway.

uBlox gave me the following advice:

 1. For a T-Mobile or ATT device, you can use a previously activated
    public SIM and at least attempt connecting.
 2. You can use a Out-of-country Carrier Sim (Orange, Vodaphone, etc.) –
    Most likely you’ll connect to Att or T-Mobile (But it might connect
    to Verizon)
 3. You can use a “Non-carrier” sim, such as Sierra, TruPhone, ibasis,
    or any prepaid data sim.

I did try a previously activated SIM but it didn't work any better for me.

*The bottom line is this:**
**
**I can send phone kits out in batches, roughly according to the 
previous timeline I sent (offset by a week or so now), but I can't 
guarantee network connectivity in the US until the certifications are 
out of the way. This email has been US-centric because I honestly don't 
know how all the other networks around the world will behave until 
phones get activated in those regions.**
*
My stress has more or less surpassed critical-mass, so now I'm just 
numb. This is kind of the worst outcome I could have imagined. Part of 
me wishes I could just refund everyone and go back to robotics etc. This 
wasn't supposed to be a 2+ year project. But, I will keep going and 
trust the process. I'm looking into getting the regulatory approvals I 
need, and the silver lining will be that I'll also be able to legally 
sell fully-complete phones when that's done (i.e. not just kits). I'm 
seriously entertaining approaching this from a new direction by finding 
a local business partner and possibly exploring VC funding so I can 
build up my manufacturing facility outside of a residential basement 
with the aim of also doing complete kit assembly. Just an idea right now.

For now, here, these are the options I've come up with:

*A:* Anyone who wants a kit (any region) regardless of the regulatory 
concerns I expressed above, I can go ahead and send it to you. This may 
require a higher degree of tech savvy to find a provider/SIM card that 
will let the phone register on your local network, and in this sense I 
would consider these to be a true "beta test", which I had originally 
envisioned a couple years ago. I'd also expect you to be OK doing 
firmware updates using the Arduino IDE, which isn't hard in and of 
itself. I'll have instructions for that.

*B:* For those who ordered a kit but didn't really want a kit, I offer 
to send fully assembled phones as a "free, consolatory upgrade" AFTER 
the regulatory compliance is taken care of, but I can't even begin to 
guess at the timeline for that yet.

*C:* For those that ordered a kit and definitely want a kit, maybe I 
would offer a partial refund?

*D:* For those that want a full refund, that's the other option of 
course and if everyone picks this, I will make it my life's work to 
honor them. But if everyone picks this option I'll have to pace the 
refunds out over quite some time (as in, until I can get some kind of 
bridge funding, or until the proceeds from another product can finance 
them). Preorder money has been going to parts, tooling, equipment, etc, 
so my liquidity is quite low.

As of now I've removed the order link on the website and added a note 
about what's going on. Once I've gotten all the kits on the roster out 
to those who want to experiment with non-approved SIM cards and such, 
I'll re-activate the link but with a suitable "beta test" note, and 
return it to "normal" only after the regulatory certifications are sorted.

~Sorry. Justine.

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