Oki
Posts: 8
Joined: Tue Jan 31, 2017 10:36 am

Raspberry PI 3 Bluetooth Declaration costs

Tue Jan 31, 2017 10:49 am

How many people are aware that creating a device intended for commercial use that incorporates a Raspberry PI 3 means you are supposed to pay the $8,000 declaration fee to the Bluetooth SIG?

https://www.bluetooth.com/develop-with- ... my-product
https://www.bluetooth.com/develop-with- ... ur-product
https://www.bluetooth.com/develop-with- ... sting-fees

I expect for most small commercial uses of the PI this will kill a project.

Does anyone know if this declaration fee can be avoided on commercial devices that don't and won't actually use the Bluetooth functionality of the Raspberry PI 3?

Heater
Posts: 16846
Joined: Tue Jul 17, 2012 3:02 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Jan 31, 2017 11:22 am

I don't think that is true. From the first link you gave:

"Note: If you are a retailer or supplier simply selling or distributing another company’s Bluetooth product and not branding or representing the product as your own, you do not need to qualify or declare the product."

Presumably no one is rebranding or representing the Pi as their own product.

There are thousands of products out there that incorporate Bluetooth modules, I'm sure none of those are coughing up 8000 dollars nor need to.

Example: https://www.kickstarter.com/projects/gf ... oth-beacon
Memory in C++ is a leaky abstraction .

Oki
Posts: 8
Joined: Tue Jan 31, 2017 10:36 am

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Jan 31, 2017 3:42 pm

If a product incorporates a Raspberry Pi inside but on the outside enclosure is branding or representing the product as the company's own product then the wording looks like you do need to 'cough up $8,000'. :o Similar to the fact that for EU compliance purposes a company's product incorporating the Raspberry Pi needs to be tested against the applicable directives - "If you intend on incorporating the Pi into a product, then the whole product or system must undergo CE compliance testing as a functional unit." viewtopic.php?f=63&t=99532

Why is the Bluetooth declaration fee not applicable to the Puck.js? It incorporates a Nordic Bluetooth chipset/module and is branded as a Puck.js. Thus it is "branding or representing the product as your own" and so therefore is liable, no?

EULERPI
Posts: 51
Joined: Sun May 15, 2016 2:44 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Jan 31, 2017 6:00 pm

Hi,

Any commercial lawyers out there willing to give a free opinion on this topics problem?.

If a commercial product* is incorporated into another product in a way the original manufacturer would reasonably expect does the technical branding of that product (eg the Bluetooth logo) by default extend to the product incorporated into, subject to reasonable technical testing/simulation of the full product by the second manufacturer?.

* I'm assuming the original product did not work on its own (except perhaps to a very limited extent) and only fully works when incorporated into a system - that it would reasonably be regarded as a component and was sold as such.

Regards

Nik

User avatar
alexeames
Forum Moderator
Forum Moderator
Posts: 2870
Joined: Sat Mar 03, 2012 11:57 am
Location: UK
Contact: Website

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Jan 31, 2017 6:20 pm

EULERPI wrote:Any commercial lawyers out there willing to give a free opinion on this topics problem?.
Good luck with that. :lol:

Free advice is often worth exactly what you pay for it - sometimes a lot less. :lol:
Alex Eames RasPi.TV, RasP.iO

gsh
Raspberry Pi Engineer & Forum Moderator
Raspberry Pi Engineer & Forum Moderator
Posts: 1608
Joined: Sat Sep 10, 2011 11:43 am

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Jan 31, 2017 6:42 pm

The other solution is to use a Pi 2 rev1.2 which is basically a 900MHz Pi 3 without the BT / WiFi.
--
Gordon Hollingworth PhD
Raspberry Pi - Director of Software Engineering

Heater
Posts: 16846
Joined: Tue Jul 17, 2012 3:02 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Jan 31, 2017 7:06 pm

EULERPI,

I'm very sure you won't find a lawyer that is into patent/trademark/copyright law willing to advise for free.

Further, even if you did the advice would be worthless. If someone wants to go after you for patent/trademark/copyright violation they will. Then you need to start paying a lawyer.
If a commercial product* is incorporated into another product in a way the original manufacturer would reasonably expect does the technical branding of that product (eg the Bluetooth logo) by default extend to the product incorporated into,
Well there is the thing. Branding, logos, etc. For example I do not see a Bluetooth logo on the puck.js web site. I don't recall seeing one in connection to the Pi either.

These things use a component that does bluetooth. That components licence terms are paid for by the device manufacturer. Same like the transistors, resistors, capacitors, LEDs it uses.

I find it very hard to believe the Bluetooth MAFIA could demand $8000 from the likes of puck.js or people using a Pi in their products.

If that is even remotely possible we should fight it tooth and nail.
Memory in C++ is a leaky abstraction .

Oki
Posts: 8
Joined: Tue Jan 31, 2017 10:36 am

Re: Raspberry PI 3 Bluetooth Declaration costs

Thu Feb 02, 2017 1:16 pm

Although I want to keep this thread to the issue of using the RPi 3, I think a bit about the Bluetooth(R) word as a trademark as I see it:
Bluetooth is a trademark.
https://www.bluetooth.com/marketing-bra ... guidelines and
https://www.bluetooth.org/docman/handle ... oc_id=5827
"The Bluetooth SIG’s rights in the Bluetooth word mark encompass all upper and lower case, bold,
italicized or plain text schematics of the word “Bluetooth.”
...
"Only Bluetooth SIG member companies are licensed to use the Bluetooth word mark in
association with their products, as agreed to in the Bluetooth Trademark License Agreement
(BTLA)."

To become a Bluetooth SIG member, "All members are required to complete the Qualification and Declaration process." Thus back to that process which for a product invokes the $8000, or $4000 for small enterprises, fee as per my original post above.

Therefore that puck.js device allegedly appears to be using the Bluetooth trademark in its description on that website in violation of the trademark rules. Good luck to them but that is a big commercial risk of a liability there.

Back to the point in hand. Incorporating a Raspberry PI 3 in a commercial product would appear to require the fee to be paid to the Bluetooth SIG. Can this be avoided, however, if Bluetooth is not used, mentioned or even enabled in that device?

OK re the suggestion to use a Raspberry PI 2, but what if in the future a 'non Bluetooth' Raspberry PI model is unavailable? Also what if you want to use Wi-Fi but not Bluetooth without having an extra USB Wi-Fi dongle?

I think I will see if I can get a response from the Bluetooth SIG.

Thanks all for viewing/commenting on this thread.

Heater
Posts: 16846
Joined: Tue Jul 17, 2012 3:02 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Thu Feb 02, 2017 2:06 pm

I think King Harald Bluetooth might have something to say about the use of his name !

It would be nuts for Puck.js to have to pay up. Puck.js incorporates a Bluetooth radio made by Nordic Semiconductor. Presumably Nordic has already paid their dues.

What then if I buy Puck.js and build a product that uses it, should I then have to pay these guys? How many times do they want money for the same thing?
Memory in C++ is a leaky abstraction .

Oki
Posts: 8
Joined: Tue Jan 31, 2017 10:36 am

Re: Raspberry PI 3 Bluetooth Declaration costs

Thu Feb 02, 2017 5:09 pm

The question is why is it 'nuts' for puck.js to have to pay up in order to use the intellectual property/patents that the Bluetooth SIG own? The model adopted by the Bluetooth SIG appears to be that Bluetooth(R) is not licensed through use of any chipset/module, but by every use of the technology howsoever that is done.

So yes, if you incorporate a puck.js in your own branded product you also then owe the Bluetooth SIG their fees. :o

Which brings me back to the Raspberry PI 3. If you're not using Bluetooth as a feature of the product in which the RPI is incorporated, despite it being present on the board, then presumably no fee to the Bluetooth SIG is due. But this is presumably. No definite answer I can find on this.

hippy
Posts: 8549
Joined: Fri Sep 09, 2011 10:34 pm
Location: UK

Re: Raspberry PI 3 Bluetooth Declaration costs

Thu Feb 02, 2017 8:05 pm

Oki wrote:If you're not using Bluetooth as a feature of the product in which the RPI is incorporated, despite it being present on the board, then presumably no fee to the Bluetooth SIG is due.
That would be my interpretation of things, and providing there's no mention of Bluetooth® at all in any product literature or documentation.

I am intrigued as to what the situation would be if one had a commercial product and wanted to state "This product does not include Bluetooth® capability". By a strict reading of the licence you would have to pay a fee to say that :shock:

Heater
Posts: 16846
Joined: Tue Jul 17, 2012 3:02 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Thu Feb 02, 2017 10:45 pm

Oki,
The question is why is it 'nuts' for puck.js to have to pay up in order to use the intellectual property/patents that the Bluetooth SIG own?
One has to be clear about this "intellectual property" thing (A contradiction in terms if I ever saw one).

There are patents. There are trademarks. There are copyrights. There are non-disclosure agreements. These are all very different things and subject to different laws.

It's nuts for Puck.js to have to pay up for patents. Perhaps it uses patented technology in the Bluetooth module. But the dues on that will already have been paid by Nordic Semiconductor, the makers of the radio. Heck, even the LEDs on the board are subject to patents. That is a problem for the LED manufacturer not Puck.js.

I don't see how copyright is an issue here.

That leaves, trademark.

Well, I don't see how Puck.js is passing itself of as a maker of Bluetooth radios. So no problem there.
Memory in C++ is a leaky abstraction .

EULERPI
Posts: 51
Joined: Sun May 15, 2016 2:44 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Thu Feb 02, 2017 11:47 pm

Oki wrote:How many people are aware that creating a device intended for commercial use that incorporates a Raspberry PI 3 means you are supposed to pay the $8,000 declaration fee to the Bluetooth SIG?

https://www.bluetooth.com/develop-with- ... my-product
https://www.bluetooth.com/develop-with- ... ur-product
https://www.bluetooth.com/develop-with- ... sting-fees

I expect for most small commercial uses of the PI this will kill a project.

Does anyone know if this declaration fee can be avoided on commercial devices that don't and won't actually use the Bluetooth functionality of the Raspberry PI 3?
HI,

From the Bluetooth SIG website:

'Important: If you are creating a product using an already qualified Bluetooth design (module or stack)—and you aren't changing anything—or adding your logo to and selling another member’s qualified Bluetooth product, you will not need to go through the qualification process. You will need to obtain the QDID from your supplier to use in the Declaration process.'

So I think that means no fees to be paid, providing you can get the QDID from the supplier of the bluetooth module and don't add your logo to that module or claim it as your own. You might need to become a Adopter member of the SIG but that membership is free.

Perhaps EMC qualification of the completed product may still have to be done and if the product has complex functionality and doesn't have design features to minimise the time to do EMC tests the costs of that testing may be many times $8000 (not a problem caused by the Pi 3 just the general challenges of EMC testing complex electronics).

Regards

Nik

Oki
Posts: 8
Joined: Tue Jan 31, 2017 10:36 am

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 1:02 pm

EULERPI wrote: 'Important: If you are creating a product using an already qualified Bluetooth design (module or stack)—and you aren't changing anything—or adding your logo to and selling another member’s qualified Bluetooth product, you will not need to go through the qualification process. You will need to obtain the QDID from your supplier to use in the Declaration process.'

So I think that means no fees to be paid, providing you can get the QDID from the supplier of the bluetooth module and don't add your logo to that module or claim it as your own. You might need to become a Adopter member of the SIG but that membership is free.
I don't think this is correct to say no fees to be paid. You are right there are no qualification fees as you are using an existing Bluetooth(R) design, but there is the declaration fee, $8000, in that case as part of the declaration process. Adopter membership is free but the declaration process for a product is not.

Oki
Posts: 8
Joined: Tue Jan 31, 2017 10:36 am

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 1:14 pm

Heater wrote:Oki,
The question is why is it 'nuts' for puck.js to have to pay up in order to use the intellectual property/patents that the Bluetooth SIG own?
One has to be clear about this "intellectual property" thing (A contradiction in terms if I ever saw one).

There are patents. There are trademarks. There are copyrights. There are non-disclosure agreements. These are all very different things and subject to different laws.

It's nuts for Puck.js to have to pay up for patents. Perhaps it uses patented technology in the Bluetooth module. But the dues on that will already have been paid by Nordic Semiconductor, the makers of the radio. Heck, even the LEDs on the board are subject to patents. That is a problem for the LED manufacturer not Puck.js.

I don't see how copyright is an issue here.

That leaves, trademark.

Well, I don't see how Puck.js is passing itself of as a maker of Bluetooth radios. So no problem there.
It appears from the original links at the top of this thread that for Bluetooth(R) that the model is NOT that the chipset manufacturer pays for use of the patent but that ANY user of Bluetooth technology is required to do so.

Here is the stock answer from the Bluetooth SIG

The company that will be branding the product will want to complete the listing process:

Every company that builds or brands or represents ANY Bluetooth product(s) as their own must complete the Bluetooth Qualification and Declaration Process. Which pieces of the process depends upon how you are using the Bluetooth portion of your product. Let's break it down.

You need to Qualify AND Declare if you are:
• Using an unqualified Bluetooth portion (chip, module, stack or design)
• Buying a Bluetooth qualified design and modifying it for your product
• Using a design that was qualified as a "component" product type
• Have the rights or license to use another company's brand and want to sell those products with changes to the already qualified Bluetooth portion (chip, module, stack or design)

You do not need to qualify but still need to Declare if you are using:
• An unmodified Bluetooth qualified design (a chip, module, stack or design you are leaving as-is)
• A factory or supplier that already qualified the Bluetooth portion (chip, module, stack or design) of your product
• An already qualified design for a product you are developing

Is my Bluetooth enabled product Already Properly Qualified?

Step One: If your product has already been qualified, the manufacturer/supplier should have the QDID (Qualified Design ID) readily available.

Step Two: Once you have your QDID, you need to find your product type by using our "Listing Search Tool." In the "Search" box, type in the QDID and hit "Search." Look under "Product Type(s)" column. If your design/product includes one of the combinations below and you have not made ANY changes, you do not need to complete qualification because your product has already been qualified. You will, however, need to complete the "Declaration Process" and buy a Declaration ID.

Listing Combos:
• End Product only
• (End Product QDID + Profile Subsystem QDID) – multiple profiles may be added
• (Controller Subsystem QDID + Host Subsystem QDID)
• (Controller Subsystem QDID + Host Subsystem QDID + Profile Subsystem QDID) – multiple profiles may be added

Step Three: If you have a different combination of product types or a "Component" you will then need to complete a new "Qualification." Since the Qualification process involves testing and other technical elements, and you aren't sure you can do it on your own, you may want to hire a BQE (Bluetooth Qualification Expert) or BQTF (Bluetooth Qualification Testing Facility).
More information regarding the Declaration and Qualification process can be found in our "Start Guide."

Anyway hopefully an answer about the Raspberry PI 3 position will be forthcoming from them.

User avatar
PeterO
Posts: 5971
Joined: Sun Jul 22, 2012 4:14 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 1:21 pm

This seems pretty clear to me... Taken from https://www.bluetooth.com/develop-with- ... my-product
Do I need to declare or qualify my product?

To sell, brand or rebrand a product using any of the Bluetooth trademarks (including the word "Bluetooth"), you must complete the Bluetooth qualification and declaration process to demonstrate and declare your products satisfy the requirements of the Bluetooth license agreements.

This process is sometimes referred to as “Qualification," “Listing," “Bluetooth Certified," or “Declaration.” Only products completing both qualification and declaration may display, feature or be offered under the Bluetooth trademarks.

Note: If you are a retailer or supplier simply selling or distributing another company’s Bluetooth product and not branding or representing the product as your own, you do not need to qualify or declare the product.
My Emphasis.
PeterO
Discoverer of the PI2 XENON DEATH FLASH!
Interests: C,Python,PIC,Electronics,Ham Radio (G0DZB),1960s British Computers.
"The primary requirement (as we've always seen in your examples) is that the code is readable. " Dougie Lawson

Oki
Posts: 8
Joined: Tue Jan 31, 2017 10:36 am

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 4:31 pm

PeterO wrote:This seems pretty clear to me... Taken from https://www.bluetooth.com/develop-with- ... my-product
Do I need to declare or qualify my product?

To sell, brand or rebrand a product using any of the Bluetooth trademarks (including the word "Bluetooth"), you must complete the Bluetooth qualification and declaration process to demonstrate and declare your products satisfy the requirements of the Bluetooth license agreements.

This process is sometimes referred to as “Qualification," “Listing," “Bluetooth Certified," or “Declaration.” Only products completing both qualification and declaration may display, feature or be offered under the Bluetooth trademarks.

Note: If you are a retailer or supplier simply selling or distributing another company’s Bluetooth product and not branding or representing the product as your own, you do not need to qualify or declare the product.
My Emphasis.
PeterO
Yes, so if you take a Raspberry PI 3, incorporate it into your product, use the Bluetooth(R) functionality of the RPI3 within that product and brand that product as your own then you owe the Bluetooth SIG their fees as per the first paragraph. As I said at the beginning, that is something to look out for if you use a RPI3 and its Bluetooth function (or indeed anything Bluetooth) in a commercially available own branded product.

If you have a distributor who then sells that product, selling it still as your product, they do not have to pay the fees to Bluetooth SIG. If the distributor puts their label on that product then they also have to pay fees to the Bluetooth SIG.

If you take a Raspberry PI 3, incorporate it into your product, DO NOT use the Bluetooth(R) functionality of the RPI3 within that product and brand that product as your own then it would seem logical you DO NOT owe the Bluetooth SIG their fees even though there is a Bluetooth device present within the product. However, there is no definitive answer (yet) that this conclusion is correct.

W. H. Heydt
Posts: 13616
Joined: Fri Mar 09, 2012 7:36 pm
Location: Vallejo, CA (US)

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 4:49 pm

Heater wrote:I think King Harald Bluetooth might have something to say about the use of his name !
IF you can get a quote from him, so pass it along...as well as how you got it.

W. H. Heydt
Posts: 13616
Joined: Fri Mar 09, 2012 7:36 pm
Location: Vallejo, CA (US)

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 4:50 pm

Heater wrote: There are patents. There are trademarks. There are copyrights. There are non-disclosure agreements. These are all very different things and subject to different laws.
Add to the list: trade secrets.

Heater
Posts: 16846
Joined: Tue Jul 17, 2012 3:02 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 6:11 pm

W. H. Heydt,

"Jeg har en frygtelig tandpine" - Harald Bluetooth.
Memory in C++ is a leaky abstraction .

User avatar
Douglas6
Posts: 4950
Joined: Sat Mar 16, 2013 5:34 am
Location: Chicago, IL

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 6:18 pm

Heater wrote:W. H. Heydt,

"Jeg har en frygtelig tandpine" - Harald Bluetooth.
:D

User avatar
PeterO
Posts: 5971
Joined: Sun Jul 22, 2012 4:14 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Fri Feb 03, 2017 6:44 pm

Oki wrote:
PeterO wrote:This seems pretty clear to me... Taken from https://www.bluetooth.com/develop-with- ... my-product
Do I need to declare or qualify my product?

To sell, brand or rebrand a product using any of the Bluetooth trademarks (including the word "Bluetooth"), you must complete the Bluetooth qualification and declaration process to demonstrate and declare your products satisfy the requirements of the Bluetooth license agreements.

This process is sometimes referred to as “Qualification," “Listing," “Bluetooth Certified," or “Declaration.” Only products completing both qualification and declaration may display, feature or be offered under the Bluetooth trademarks.

Note: If you are a retailer or supplier simply selling or distributing another company’s Bluetooth product and not branding or representing the product as your own, you do not need to qualify or declare the product.
My Emphasis.
PeterO
Yes, so if you take a Raspberry PI 3, incorporate it into your product, use the Bluetooth(R) functionality of the RPI3 within that product and brand that product as your own then you owe the Bluetooth SIG their fees as per the first paragraph.
I don't think so because you are not rebranding the PI, you are not claiming it as your own product. If you did, I think the PRF's lawers might also have a thing or two to say to you.

PeterO
Discoverer of the PI2 XENON DEATH FLASH!
Interests: C,Python,PIC,Electronics,Ham Radio (G0DZB),1960s British Computers.
"The primary requirement (as we've always seen in your examples) is that the code is readable. " Dougie Lawson

Oki
Posts: 8
Joined: Tue Jan 31, 2017 10:36 am

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Feb 21, 2017 9:52 am

After some discussion with the Bluetooth SIG via email I have had an answer to the original question about can the Bluetooth SIG declaration fee can be avoided on commercial devices that don't and won't actually use the Bluetooth(R) functionality of the Raspberry PI 3?

I'm awaiting permission to quote their answer on here but in summary yes no declaration nor fees due is the outcome. This is strictly provided the Bluetooth functionality is disabled with no straight-forward or 'software' option/method for typical end-users to enable it and there is no mention/use of the Bluetooth trademark (which includes the word itself).

For the product we are concerned about the Raspberry PI 3 is embedded within the enclosure with no easy end-user access to the micro SD card nor any 'front end' to the PI.

Heater
Posts: 16846
Joined: Tue Jul 17, 2012 3:02 pm

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Feb 21, 2017 10:07 am

Whilst you have their ear could you also ask about the situation of creating a device with an embedded Pi 3 where Bluetooth is available and expected to work?

It would be obscene if people creating gadgets out of the Pi 3 e.g. robots, 3D printers, portable computers, digital signage, etc, etc had to pay the Bluetooth mafia.
Memory in C++ is a leaky abstraction .

i486
Posts: 178
Joined: Sun Aug 28, 2016 3:41 pm
Location: BG

Re: Raspberry PI 3 Bluetooth Declaration costs

Tue Feb 21, 2017 12:50 pm

"a product using any of the Bluetooth trademarks (including the word "Bluetooth")" - you may need to pay $8000 if you have Bluetooth word or logo on product's box or advertisement. If you have RPi3 inside and don't write anything about Bluetooth - you don't have to pay $8000. I think it is clear. The fee is for trademark, and not for usage of bluetooth device. No Bluetooth word or logo - no fee.

Return to “General discussion”