Bluetooth SIG question

Connectivity BLE // NFC
1

Hello,

If I distribute a product using a Particle.io module, but I do NOT use the BLE firmware features, do I have to register it with the Bluetooth SIG and pay the $11,040 USD registration fee?

My concern is that while I am not going to use the Bluetooth functionality, the Particle bootloader does use the Bluetooth functionality and as far as I know it cannot be disabled.

Thanks.

  • Chris
2

You do not need to obtain a Bluetooth SIG registration even if you use BLE. Particle has obtained this already, and simply using the Particle device or customizing user-level firmware does not require registration again.

3

Hi Rickkas7,

Thanks for the quick reply. But are you sure this is correct? According the Bluetooth SIG:

ALL Bluetooth® Products Must Be Qualified

  • Your supplier or other member companies cannot qualify your products on your behalf, you must complete the Bluetooth Qualification Process for your product yourself
  • You can only qualify your products under your member company’s account and only by completing the Bluetooth Qualification Process
  • You will be charged a Product Qualification Fee for the first product submission that includes a specific design. Subsequent products you submit that include the same design will not be charged a fee. Please see our Schedule of Dues and Fees for more information

Does Particle.io have any documentation demonstrating an agreemebt with the Bluetooth folks?

Thanks.

  • Chris
4

I believe you should not need BLE re-qualification because you are including the whole Particle module, which is a qualified product in their qualification database.

However, this is not legal advice, so you may still want to investigate this further.

5

Hi Rickkas7,

Thanks again for the quick reply.

I understand you cannot give legal advice. But I presume Particle.io knows what is generally required for products to use their modules. Having to register the product with the Bluetooth SIG and pay the $11,040 USD registration fee seems like an important thing to know.

Is there someone I can contact at Particle.io to clarify if the SIG registration is required for products using a Particle.io module with Bluetooth?

  • Chris
6

BLE defaults to disabled on cellular devices. As long as you never enter listening mode or provisioning mode, BLE won't be enabled and there are of course no BLE advertisements as the radio will be off. It's not present in the bootloader.

7

Hi again,

So would it be possible to disable the ability to put the Particle.io device into listening mode or provisioning mode? My feeling is that if it is possible to enter listening or provisioning mode in a shipped product, that product will be required to be qualified with the Bluetooth SIG and the $11,040 payment made.

Is there someone at Particle who can better answer my question? I would assume there must be a Bluetooth expert on staff.

Thanks.

  • Chris
8

Provisioning mode will only be enabled if you explicitly enable it in your firmware using BLE.provisioningMode so you don't have to worry about that.

You can disable listening mode so you can't even get into it using the mode button press using System.disableFeature to disable it.

9

Thank you. That is helpful.

Also, is there someone at Particle who can best answer my Bluetooth SIG requirements question? I am unable to find anywhere in your documentation that describes if the end product must be qualified with the SIG.

  • Chris
10

Hey Chris,
Did you get an answer to your question, regarding registration and licencing?

This is a common question that gets asked across the globe as it is part of an ongoing discussion about FRAND licensing, (Fair, Reasonable, and Non-Discriminatory) is a set of principles for licensing Standard Essential Patents (SEPs), which forms the backbone of virtually every internal standard. These include BLE, WiFi, 2G,3G,4,5G, LORAWAN, etc...

11

Hello @BillyBobJoe,

So I never got a clear answer. Everyone I spoke too (including the Bluetooth SIG) pretty much said the same thing. "We cannot give legal advice".

If you read the Bluetooth Patent and License Agreement, it makes mention of a "Compliant Portion". (https://www.bluetooth.com/wp-content/uploads/2019/03/PCLA-ESign-Version-Version-11.pdf This seems to indicate that so long as you do not change the radio components and stack of a pre-qualified Bluetooth module, you would be permitted to "make, have made, use, import, offer to sell, sell and otherwise distribute and dispose of
Compliant Portions".

Of course you do have to join the Bluetooth SIG to access that license agreement. Joining the SIG comes with other obligations around branding styles and using the Bluetooth trademark.

So I do not know what the correct answer is. But I can tell you from personal experience that if you use the terms "Bluetooth", "BLE", "Bluetooth LE", etc in your marketing, the Bluetooth SIG folks might come knocking on your door. In my case it was the use of "BLE" which caught their attention.

  • Chris