100 Hikvision Partners Ask US FCC Not To Ban Hikvision

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John Scanlan
•Published Aug 31, 2021 13:46 PM
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100 Hikvision partners have submitted comments to the US government, urging the FCC not to ban the PRC China government-controlled manufacturer.

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This comes shortly after Hikvision mass emailed partners urging them to submit comments to the FCC defending the company.

Inside this report, we share every submission in full, examining the key themes offered.

Below is a list of the 100 companies, with a link to their website, their location, and number of employees, per LinkedIn:

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Hikvision Calls For Partner Comments

Hikvision has been petitioning its partners to submit comments to the FCC for the past few weeks. IPVM obtained the petition and the following is the request of Hikvision to partners:

WHY YOU SHOULD COMMENT

You have a rich experience in the industry and commenting will allow you to share how the FCC proposal will affect you, your family, your business, and your customers, to help the FCC in their decision-making process. You can respond to these questions to help you formulate a comment:

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  • Have you ever had any issues or concerns with the security of Hikvision cameras?
  • How will the FCC proposal impact your business?
  • How will the FCC proposal affect your family or livelihood?
  • How will the FCC proposal impact your customers’ safety, security, and livelihood?
  • How will the FCC proposal impact the safety and security of surveillance system networks?

Many of the FCC submissions follow this 5-point pattern, often literally question by question.

Moreover, Hikvision has an instructions page that includes a countdown clock urging partners to comment:

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Hikvision Employee Jerry De Francisco submission:

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I have dealt with Hikvision products for over 5 years. After declaring it one of the most Cyber Secure CCTV companies out there, what basis are you using to say these same products are now unfit to be used in the US?

Prior to joining Hikvison this year, De Francisco worked at an integrator that used Hikvision.

Badger Networking, 1 employee, owner Russell Chernak submission:IPVM Image

Have you ever had any issues or concerns with the security of Hikvision cameras? No. I also have not seen any additional upload traffic from any cameras I have installed. How will the FCC proposal impact your business? I will likely lose business because I'll have to purchase more expensive cameras in place of Hikvision cameras and that will be cost-prohibitive for many of my clients. I also suspect I'll be installing fewer cameras on the contracts I do get, just to keep costs down. How will the FCC proposal affect your family or livelihood? I started my own business in 2018 and I install Hikvision cameras almost exclusively. If the Hikvision cameras are banned it will jeopardize the company I've started. How will the FCC proposal impact your customers’ safety, security, and livelihood? By having to purchase more expensive camera's my customers' will not be able to afford as many cameras and many areas of their businesses may go unmonitored. How will the FCC proposal impact the safety and security of surveillance system networks? The biggest change will be cost. There aren't any good low-cost alternatives on the market so every camera system will be double the cost.

ABF Security, 47 Employees, owner Joe Polizzi submission:IPVM Image

My name is Joe Polizzi and I am a security system integrator located in St. Louis, Missouri. Over the years we have provided service on Hikvision camera systems and have found the product to be on the leading edge of camera technology. If Hikvision we to be removed from the US market a huge, unfillable, gap would be created in the security market. Costs and lead times would skyrocket leaving our customers less secure.

Patriot Fire & Security, president John Prindle submission:IPVM Image

I would like to express some concerns with what appears to be a bias regulation. I understand security is of upmost importance but that falls on the installer and installation methods used. Whil I somewhat agree with this ban in government building I do not agree with it nation wide. We are not forced to hand over smart devices while entering these establishments while most parts of not all are produced overseas as well. Furthermore being an owner of a small business company that installs such systems you will be cutting a lot of small businesses off from affordable systems. Most comparable systems run almost double the costs meaning less cameras less coverage and more crime in my opinion. I believe from what I have read hikvision has been very straight forward and open while trying to work this out. It is my hope we can look at this from other aspects. Thank you for your time

Homeland Surveillance, Investigations & Installations, Corp., 11 employees, president Yisrael Gold submission:

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Dear Federal Communications Commission: Thank you for allowing public comment and thank you for taking the time to consider our comments. My name is Yisrael Gold. I am the president of Homeland Surveillance, Investigations & Installations, Corp. Our company incorporated in December of 2011 as a NY State licensed security and fire alarm installation company. To date we have installed and maintain +60,000 cameras in NYC and the surrounding areas. We have tried to install many different camera manufacturers models, some built in Korea, some in the USA and some in China. We were completely against using Hikvision products and we did everything that we could to stay away from them as they represented inferior quality, bad warranties and the lower end of the professional spectrum of CCTV hardware. However, without getting technical, we continued to have problems with the other camera manufacturers, images did not display true colors, cameras rated for harsh conditions did not last in harsh conditions, camera image quality was reduced after the installation and the cameras did not transmit true images 1 year later. We also experienced dry-rot, a condition that the camera lenses dry and crack, among other issues. With no choice we experimented with the Hikvision products and we were truly surprised to find the following when using Hikvision professional grade products. 1. The camera images are crisp and clean 2. The camera images show true color on all images 3. The lenses do not dry-rot after being exposed to sunlight 4. The harsh environment rated cameras truly withstand temperature, water and elements 5. The warranty is a full 3 years to professional installers 6. The cameras software's are constantly updated to work seamlessly with all recording software 7. As a professional we receive special pricing that allows us to stay competitive and deliver a great value to America's end users, similar products from other manufacturers would result in higher costs to consumers and would either derail security upgrade projects or minimize security upgrades. Security: All camera systems are secured by a closed network, in order to get inside the network and intruder would need 1) The IP Address 2) The port Number 3) The user ID and 4) The password. We have secured many schools, residential and office complexes. These include embassy buildings and buildings that house court systems and government buildings. We have never been notified about a security breach in any of our more than 1,000 systems deployed. As we not only install, but also maintain these systems, we would be the 1st ones notified of such an occurrence. Business and familial effects of this proposal: One of the effects of this proposal would be to lower the amount of security that Americans get and should have. The quantity of new security hardware installed will be significantly lower as the rising cost of security hardware will make new installations unaffordable to many homeowners, businesses and organizations. Those that can afford will deploy less cameras as they will need to determine camera locations by security budget as opposed to by security need. Schools, hospitals, community organizations and residential properties will receive less video coverage. This will result in more crimes perpetrated and a decrease in public safety. This may well result in less security work for our firm and firms such as hours, causing less hiring of new employees into the workforce, less hours for existing employees and less revenue to be able to increase employee wages and offer employee incentives. My life, my employees lives and thousands of other security installers and technicians will be severely impacted by disallowing us access to the worlds largest and most professional provider of security hardware. There will be no increase in safety and security to most American consumers, organizations, businesses and government facilities by using an alternate camera or security hardware to replace the Hikvision product line. Please include the security installation companies, installers and technicians in your final ruling and please allow the end user to decide for themselves if they wish to use Hikvision or a competing manufacturer for their security project. Sincerely, Yisrael Gold

Computer Visionaries Inc, 14 employees, business development manager Ron D'Eliseo submission:

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Stopping sales to the US of HIKVISION products will severely impact our security business. 98% of our Video Surveillance sale utilize Hikvision products and we have been using Hikvision for over 7 years. We are a small business of 20 employees and this potential decision to cut Hikvision may have an impact on our employee's & their families lively hood. I also believe Hikvision has very good products and provide security and safety to business and residences throughout the United States, including my own home. We have over 700 system installs and have no network/security concerns either. Thank you.

Accurate Home Audio, president Michael Milhauser submission:

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I have never had a concern about security with HikVision products. If the FCC blocks HikVision products this will cause a significant loss of business for our company. If we have to switch to another company's cameras we will have to spend time and money on training for new products. I have sold 3 other security camera brands in the past and all 3 of those companies had large scale cyber attacks that affected our customers. HikVision has protected our clients over the past 5 plus years with zero cyber attacks.

[Note: LinkedIn does not have a profile for Accurate Home Audio, though Milhauser has a personal LinkedIn profile.]

Global Network Security, 10 employees, account manager Danny Chang submission:

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My comments are in support of Hikvision, specifically, and is based on my current understanding of the situation and 7 years experience of Hikvision products. We have sold hundreds of thousands of Hikvision products since 2014. Our normal project environments range from residences to large companies. In the thousands of projects completed with our involvement, we have not had one cybersecurity administrator note a security breach caused by our systems. Our US owned, small business has experienced significant growth since we have started using Hikvision, to the point where we have doubled our employment and opened other warehouse locations. We, along with our partners, have given peace of mind and protection to many citizens, business, and other entities in our country. The product delivers the highest quality per dollar spent in our industry, and as a result, allows a common user to get the same level of protection as a manufacturer charging double/triple/quadruple the price. Critics have noted the potential cyber security issue in dealing with a company whose largest shareholder is the Chinese Government. I can understand this point, but given the current public information available, we have no reason to believe the Chinese government has embedded malicious hardware/software into these products. As the largest camera manufacturer in the world, it would seem reasonable to assume Hikvision would also be the largest and most consistent target for breaching. And though they have had a couple breaches in the past, they updated their procedures and have not been any significant ones within the last 3-4 years. NDAA approved Verkada (made in Taiwan, according to their website) had a major breach six months ago, but we aren't having the same debate about them today. So it would seem this argument is not as strong as others have claimed, nor is it being treated fairly across the industry. Due to the potential negative outcome of this ruling, our company has thoroughly examined other manufacturers that would adhere to the proposed trade regulations. Our conclusion is, given the current availability, we will have to provide a significantly inferior product to provide a solution of similar pricing. This means a negative FCC ruling will certainly result in the consumer suffering, either by spending double/triple for the same quality or by accepting a lower quality product. Its an easy point to overlook, but it must be noted a seemingly minute difference in the quality of video often makes a significant difference when trying to identify the details of a situation. In conclusion, I can understand restricting the use of Federal Funds on these products given the political climate and Hikvision's ties to the Chinese Government. This would provide a significant amount of federal projects to our government's preferred manufacturers, and it provides a stronger actual/perceived safety net in protecting our critical government infrastructure. But the reasoning behind potentially restricting this to the entire market does not make sense from a risk/reward perspective; it would unnecessarily hurt the businesses like ours, and ultimately, it will hurt the common people who are looking to protect themselves with a quality system at a reasonable price.

i-comm, Inc, president Brian Stowers submission:

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We have been in the electronic private security business since 2005. We rely heavily on HikVision products to secure our customer facilities at a fair price and using a very feature rich platform. HikVision products perform better than most other US based brands at a far better price. They actually are more secure and require more password and security measures to enable them than their US branded counterparts. We provide systems to government agencies and hotels and now we are scrambling looking for a viable alternative product line. We have to re-train staff and increase inventory costs to switch brands. This is harming our business immensely.

[Note: LinkedIn does not have a profile for i-comm though Stowers has a personal LinkedIn profile.]

CIX Security, 1 employee, CEO Shane Nevins submission:

IPVM ImageI've owned and operated my security company for 20+ years. Since 2014, Hikvision has been our sole provider of networked surveillance hardware, and AXIS Communications before that. Because security is always top of mind, and the potential for threat from bad actors is ever present, we've always been diligent in segmenting our networks so that our cameras never have direct access to the internet. Of course we provide a remote connection to our clients, but always through an intermediate interface. A couple years ago industry publications claimed that Hikvision cameras were by default communicating with Chinese servers, but this ended up only being the case if domestic DNS parameters were not set, and that's only relevant if the camera has direct access to the internet in the first place. Beyond that, we've never experienced any issues with Hikvision hardware first-hand. As previously mentioned, we switched to Hikvision from AXIS in 2014. This decision was based both on performance and cost. We felt that our AXIS cameras were not holding up to the elements as well as they should given the price, and we'd lost quite a bit of business to other lower cost competitors. Hikvision gave us a means to be priced competitively as well as offer a solid product that performs just as well as higher cost options. As an example, I recently bid a project with both Hikvision and AXIS camera hardware. For the most part, the systems were apples to apples, though the resolution on the proposed Hikvision cameras was considerably higher in a few instances, yet the AXIS bid was roughly 70% more than the Hikvision. Should the government decide to ban these products, I fully expect to experience the same cost-related downturn as previous. We've installed thousands of Hikvision cameras for our clients, and to all the sudden raise prices because the hardware they're familiar with is no longer available is unfair and will likely result in them searching for lower rates. Given that the economic climate is already taxed by inflation and regulation, I expect yet another curve-ball to be representative of yet another nail in the coffin of so many small businesses. Further, that sort of negative impact on small businesses will most certainly trickle to the families that rely on them. Circling back, security is and should be at the top of mind for all security companies. Networked surveillance hardware is still reasonably young in the grand scheme of the industry at large. I agree that networked hardware isn't without flaws, and there are vulnerabilities with nearly any networked component (ie - cameras, computers, smart light bulbs, etc). I also agree that those who install said equipment should be educated as to where the potential threats are, but I think it's both unfair and highly detrimental to businesses like mine whose customers rely on security systems they can actually afford. I hope you'll reverse course on this decision. I feel my business and so many others will suffer greatly because of it.

Guardian Safe & Lock, 10 Employees, founder/CEO Uriah Ortiz & Sylvia Ortiz submission:

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08/28/21 In Regards to ET Docket No. 21-232 To whom it may concern, My name is Uriah Ortiz, and I am the Founder and CEO of Guardian Safe & Lock LLC in Tomball, Texas. My wife and I are writing you this letter to express our deepest concerns about the possibility of losing access to Hikvision’s products/future products, services, relationships/support, or even the whole company itself. Hikvision is our Greatest Partner in the CCTV Camera Industry, and make up 98% of all camera systems we install or have installed. Hikvision’s products and services are critical to the future growth of my business and hundreds of thousands of other small to large Security, CCTV, Access Control, and Locksmith Businesses like mine across the USA. We also have thousands of existing customers that have Hikvision products and systems that we installed that need support, service, and warranty or new product replacement going forward. Over the last few years Hikvision's sales representatives and support team have become an extension of our family of vendors that we trust and do business with. They have helped us grow over the years and now we employee 10 full timers including me and my wife. I have personally installed thousands of Hikvision products and systems as an installer, manager, owner, and now CEO of Guardian Safe & Lock LLC. Hikvision is critical to the success of not only our company but hundreds of thousands of other American companies all over the country. Over the last 15 years, I have never had even one complaint or mention of a security issue when using one of the Hikvision products that we have installed. The cameras and digital recording devices that are used by Hikvision are just like any other hardware coming from any other country, they are only as secure as the network they are on. There has never been one instance that I can recall over the last 15 years I’ve been in this industry, in regards to a security or privacy issue with a Hikvision product. This FCC proposal will destroy and cripple small to large businesses like mine all over the United States. It will affect my lively hood, all of my employees and their families, and families and companies across the nation. I have always considered Hikvision to be a great partner that we can count on and trust, and I feel like they are being unfairly targeted. We also have thousands of customers that really on Hikvision for security and support, and this ban against Hikvision will put all our customers and any other company’s customers security at risk. I’m a patriotic American that would never allow or support any foreign or domestic company that intends to do harm or damage to the United States. Thank you for giving me the opportunity and time to voice our opinion. Respectfully, Uriah & Sylvia Ortiz Guardian Safe & Lock LLC

Champion Systems, CEO/founder John Yeung submission:

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Hikvision makes great product. It is a group of smart ppl with strong surveillance experience.

[Note: LinkedIn does not have a profile for Champion Systems though Yeung has a personal LinkedIn profile.]

Mammoth Security Inc., 2 employees, employees Jason Walsh & Marian Bassalious submission:

We have been in the video security business for over 20 years. I always have great experience working with Dahua and Hikvision. I've monitored the route of their data and never seen any outstanding outcoming video or critical information to China. This proceeding is pure political with ugly faces of politicans hiding behind it. They are great companies who dedicated to lower the cost of video security technology and empower every taxpayers of our Country to enjoy it, don't ruin it for the American people.

Address of posters matches Mammoth Security Inc.

1 Complete Solution, 1 employee, consultant William Bew submission:

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My Background: I have been a licensed Low Voltage (low energy) contractor since 1986. I have held licenses in 6 States. Presently I hold licenses for 3 companies in 4 states FL, Ga, Ca, and NV. My testimonies are examples of what would happen with my NV customers if the FCC proceeds with banning Hikvision products in the United States. The reason I highlighted my NV customers is that they are Casinos and they have the strictest parameters in any Industry. If Hikvision is barred from the US market this is what will happen to My NV Company and all of the 17 Casinos that I service. 1. How will the FCC proposal impact my business? My customers all have Hikvision DVR’s, NVR’, Cameras, video management software and other products. The Casino industry is regulated heavily. All of the surveillance products must be approved by the Nevada Gaming Control Board. The reason that I chose Hikvision was the price point, ability to exceed the Gaming specs, product features, and product quality (since downtime must be small). Gaming requires getting the system up within 1 day. I have used most of the competitors in my over 40 years in the industry none of the other products come close to all of my criteria. If Hikvision is banned from the US market all of my 17 casinos will have to replace all of the DVR/NVR’s when a defective DVR/NVR is unit needs to be replaced since the DVR/NVR’s entire are intertwined through the VMS software. No manufactures product work together. I could get a new vendor but all compatible Control board authorized products in my servicing area have limit dealerships (there are none available). The worst case happens: A DVR fails on one of my clients they have 15 DVRS/9 NVRS, Two work stations all working together. I can’t get a replacement for the defective DVR now I have to start from scratch (they would love to replace the total system). Yes another company DVR/NVR could be installed but the ability for different vendors surveillance product talking to each other is not existing. I would have to find a software that could interface with the new companies DVR/NVR and Hikvision. My replacement software will not allow the surveillance officer to do tracking, license plate recognition, facial recognition, camera reliability, firmware updates on cameras DVR?NVRs and a host of other action that are available on Hikvision software. This will compromise the ability of the surveillance operators to have a smooth interaction of the facilities. If what you are proposing I will shut down my company before this any major fault occurs at any of my customers facilities. I could not perform my duty to my casino customers to maintain the criteria required by the Nevada Gaming Control Board. I doubt any of the other Integrators that would replace my company could keep the Casinos in compliance. This will cause a big impact on safety and securityall Nevada Casinos that rely on Hikvision systems. 2. Have you ever had issues or concerns with security of Hikvision Cameras? I have never had any security breach with this product. In a Casino video is very sensitive and Hikvision has all the protocols to make sure we have no security breach. Most surveillance systems are subject to a data breach no matter what you could do to prevent access to the video data, but the robust security structure in the Hikvision products limits the chance of any data breach. In my early career I was introduced to data security while I worked as a civilian contractor for the US military. My job was designing aircraft simulators for the military which is highly sensitive. The Hikvision products have similar check points that I was introduced. I hope this is helpful on how having Hikvision banned from the US market will cause a domino effect on the US market. 1. Hikvision banned 2. I will shut down operations 3. Major component crashes. 4. Casino needs to find another integrator. 5. Casinos does not have an easy solution may have to spend $500,000 to facilitate a change to a new system. 6. Or Casinos put on a band aid to solve the problem with new software to integrate the new coponent. 7. Casino has an incident needs to recognize the suspect and follow suspect. 8. New software does not allow compatible tracking of suspect. 9. Worse case Casino customer is harmed from suspect because Security officer could not get to the area fast enough. 10. Or Casino may be shut down because defective DVR/NVR cannot be replaced in a timely fashion. 11. There are no good solution. Thank you for your time. William Bew Owner 1 Complete Solution 390 Freeport Blvd #6 Sparks, NV 89431

Safeguard Security Cameras, 2 employees, operations manager Aaron Shaner submission:

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Hikvision has proven to Safeguard Security Cameras to be the single greatest CCTV equipment manufacturer in the industry, with consideration of all elements that must be delivered for any professional integration company to provide excellence with every interaction. We have never once experienced any reason to question Hikvision USA’s commitment to protecting the US consumer market, and understand that Hikvision USA has fully cooperated with the US Government throughout the entire GSA/NDAA restructure. We believe so highly in Hikvision’s quality of products, support, and integrity, that we continued to support Hikvision as an exclusive product line, despite no longer having the opportunity to bid on Federal CCTV project requests since August 2018. I consider myself a Patriot and remain a believer in our Country’s core beliefs, established by our forefathers. And I do not wish to discredit any legitimate facts that support anything related to protecting our brothers and sisters from harm. However, through our own hands on experience of authentic Hikvision USA products and all communication we’ve received from our varying Hikvision relationships throughout these trying times, we feel this has become a wrongful guilty by association situation. I ask that you please do not pass 21-232 without honest facts that justify such an action, and please reconsider your decision specific to Hikvision (the largest CCTV equipment manufacturer in the world and statistically one of the top responders to Cybersecurity concerns). If there is any doubt in this cases facts and how they relate to Hikvision USA whatsoever, I implore all decision makers involved within this proceeding to pause and be sure you have thought deeply on all the ramifications that millions of innocent citizens will be faced with, should you execute. Thank you for allowing the time to review all comments, as well as being open to each comments message that is received.

Sheppard Security & Communication Inc. submission, 6 employees:

IPVM ImageWe are a Small Family owned Security Business that provides and services our customers with Hikvision Camera Systems. We heard about the FCC public meeting on June 17th that proposed prohibiting certain equipment on the Covered List that the Commission maintains and the proposed ruling would prevent Hikvision products from being available in the United States. I’m very concerned about the implications this would pose on our business, employees and our customers. We have used Hikvision products since 2015 and they are our best and only camera system we provide. We have thousands of customers with Hikvision product in their home and business. This proposal would be detrimental to our business and customers. Without the product we cannot service our customers with systems already in use. Customers would have a useless system that they have paid thousands of dollars to have installed and maintained. Hikvision is an excellent product by far as compared to other companies. We have invested time and money in learning and training our employees on Hikvision. With prohibiting Hikvision to be available in the United States we would have many unsatisfied customers.

Holmes Security Systems, 24 employees, programming and IT manager Michael Bolton submission:

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I am a network engineer and my company sells and installs Hikviison cameras for our customers. As a network engineer, I am very careful to monitor and secure any devices on our network as well as customer's network. We have never had any cyber security issues with Hikvision products and they have passed many 3rd party security audits. They have also been very transpartent and even setup a source code transparency center to allow government agencies to review Hikvision's source code. I have not seen another surveillance company offer that type of access. Hikvions products have proven to be a robust and feature rich products at a very cost effective price. This pricing has allowed many people to enjoy the benifits of a much higher end systems. This wouldn't be possible without Hikvision. Banning Hikvision products will be catastrophic for many businesses that are selling and installing thier product. There isn't another manufactor that exsist that can replace Hikvision's product line. It will also be catastrophic for the individuals that have systems now or need an affordable system to protect the safety. I ustrongly urge you to reconsider banning Hikvision.

Wire Audio, owner Ciprian Pasare submission:

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To whom it may concern, I run a small IT company in the state of Illinois and for years we have been selling, installing, and maintaining HikVision products. We have started using this brand because it has been stable and reliable versus other brands (some of which were more expensive). In all these years, we have never had any report of security breach and all IT, cyber-security, and PCI Compliance tests and audits have passed. The decision to eliminate HikVision from the US market will have a huge impact on our small business as it will be difficult to start all over again with training, testing and investing in other products on the market. Please reconsider this proceeding.

[Note: LinkedIn does not have a profile for Wire Audio though Pasare has a personal LinkedIn profile.]

M&P Security Solutions, LLC, 9 employees, owner Patrick Presto submission:

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M&P Security Solutions LLC is a Veteran-Owned Small Business that specializes in commercial security system integrations. We have been selling and installing Hikvision equipment since 2013 and were even invited to tour Hikvisions facilities in China in 2019. We have never had any security-related issues with Hikvision equipment, specifically regarding hacking or any other cyber security threats. Through the years, Hikvision has made firmware updates easier than ever to apply and has won many cybersecurity-related accolades and awards for their levels of encryption. If this FCC proposal passes, we will likely need to find an immediate substitute product offering to fill this void. More importantly, we have many customers with large deployments of Hikvision equipment and software that would be potentially without support. This would create a very large problem for these customers with large deployments. As a Veteran Owned company, we fully agree with putting pressure on certain foreign country's when it is warranted, including China. However, this specific FCC proposal seems more directly targeted at certain companies (including Hikvision) without a justifiable cause. We fully support Hikvision being able to continue operations as normal assuming that they continue to uphold the same cyber security standards that they have been. Best regards, - Patrick T Presto, Owner/CEO, M&P Security Solutions LLC

Computer Geeks, president Parker Ledbetter submission:

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HikVision Comment - Small Security Business in NC. We have been using HikVision technology for a few years and my team has been trained on the systems. Our business would be impacted to switch to another vendor and have to support two different systems.

[Note: LinkedIn does not have a profile for Computer Geeks though Ledbetter has a personal LinkedIn profile.]

Redwood Systems Group, 13 employees, project manager Ben Brooks submission:

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We have used Hikvision cameras successfully at hundreds of properties around the country. They work great and come in at a price point that allows us to be competitive in the bidding process. Beyond that, it would be close to impossible for China to somehow sneak in a piece of software or hardware that allows them to remotely access the devices. Even less likely would be them somehow able to access a video stream or get still images from storage. The data in our video management systems is encrypted at several stages, including encryption at rest. We also never have a CCTV system directly connected to the internet, that would be stupid. They would have to get through our firewall, sometimes 2 firewalls, and somehow hide the exfiltration of an HD video stream or a still image without us seeing it. This is not something that can be done through normal means. It would require multiple failures at various levels for this to be the case, and frankly, we are all better at this than that. Any images or video streams they would access would also be encrypted. Please punish China some other way. We like Hikvision. They provide a lot of American jobs.

Business Communications Solutions, LLC., 15 employees, owner Jason Buchanan submission:

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We have been a Hikvision dealer for years and have never seen any security issues. Hikvision has always been an innovator with state of the art products at a very affordable cost. This has been huge in the School Security market where money is tight and Safety is the concern. If Hikvision goes away thousands and thousands of Schools will be left with no support and huge costs to replace the systems they have and even possibly risk their security levels. Not the mention to damage to small business that install these systems and will be left with no support.

Raven Electric Inc, 21 employees, IT administrator Ed Grantier submission:

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We have been using Hikvision products, and we have been a Gold Dealer Partner with them. If installed correctly and all firmware updates are applied there are no security issues with these cameras or NVRs. They are very user friendly, and tech saavy. They have established a solid business here in the USA. I love their support. They don't do shared screens but very helpful in solving issues Their cameras are excellent.

Communications Electronics Inc., owner Ronald W. Best submission:

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Since 2010, we have used HikVision products in the most sophisticated networks for schools, government, industrial and Commercial applications. These professional Cisco and other networks would detect any threats or strikes going out of their networks. Common sense says our US IT people are capable of assessing a threat. If we are not permitted to sell HikVision products we will not be able to support the existing 3 year warranties for product sold. We will be forced to research a new product line, train all of our technical personnel, during Covid, with nothing but online classes. Our customers, which includes many schools, will be forced to abandon their investment in HikVision, reinstall another platform on countless machines for access. Schools are overwhelmed right now and don't need to back up and punt on their security.

[Note: LinkedIn does not have a profile for Communications Electronics Inc., though Best has a personal LinkedIn profile.]

Barrier Protection Systems Inc. submission, 6 employees:

As a professional security company, we are always striving to find an affordable and reliable product for our customers. Over the past 5/6 years that we have been installing Hikvision products, they have continued to provide a reliable and secure product. We have noticed zero instances of security risk and have only had pleasant experiences with all of their products. I personally have installed exclusively Hikvision products at my home, as well as all of my business locations. I am confident in their security on my networks and fully support their products. My security business as well as countless other small security companies will suffer extreme loss from this FCC proposal. I can appreciate the FCC investigation as well as understand the need for verifying security measures. However, banning Hikvision products will buckle small security businesses across the country.

TLC Technologies, owner Timothy L Smith submission:

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I have been selling Hikvision products for 3 years now and love the product and will be very, very displeased if I can no longer purchase this product. They have quality products which are extremely easy to setup and get on line. They have excellent tech support as well as good software for PC and Apps for smart phone. Also there is very little waiting time to get the product if something is backordered.

[Note: LinkedIn does not have a profile for TLC Technologies, though Smith has a personal LinkedIn profile.]

Odyssey Technologies, Inc. submission:

Odyssey Technologies, Inc. is a small minority-owned Maryland Corporation that has enjoyed a very productive technology partnership with Hikvision for over 10 years. The proposed action to ban Hikvision from the US market would be devastating to our business and to the US citizens we employ in Maryland, Ohio, and Georgia. We have sold thousands of Hikvision products to our customers worldwide with zero complaints about security issues related to the Hikvision products. We strongly urge the FCC to reconsider their position on banning Hikvision from the US market.

[Note: LinkedIn does not have a profile for Odyssey Technologies, Inc.]

Blue Sky Technologies, LLC, 23 employees, business development manager Tim Bufford submission:

Bufford sent this letter in support of Hikvision to the FCC:

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Hawkeye Security Systems Inc., employee Philip Todd submission:

As a professional, commercial video surveillance technician, the proposed exclusion of future HikVision products from the general marketplace is very concerning to me, my customers, and the company that I work for. HikVision manufactures the bulk of the cameras that are sold either with their branding, or with third party branding (such as LTS, truVision, etc.). The accelerated pace of the proposed prohibition is quite concerning to us for the following reasons: 1: we have had excellent results with the HikVision product, and no concerns have come up regarding the security of the HikVision equipment. 2: in the professional video surveillance market, more than 50% of the hardware is of Chinese origin - eliminating the Chinese manufacturers from the US market will hand the market over to manufacturers who will not be able to keep up with demand, and will ultimately cause my company to lose market to the cheap (and Chinese made, yet exempt from this matter) Amazon (and other) do it yourself types of equipment.

[Note: LinkedIn does not have a profile for Hawk Security Systems Inc., though owner Amy Weller has a personal LinkedIn profile.]

Gen Net, Inc., employee Douglas Alan Haynes submission:

Douglas Haynes sent this letter in support of Hikvision to the FCC:

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[Note: LinkedIn does not have a profile for Gen Net, Inc.]

Nodac Technology, president Oscar Cortes submission:

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Not allowing the sale of Hikvision products in the United States will directly impact the 24 families that depend on our company, as it is our primary line of products. In addition, it will directly impact our clients who have trusted in the quality, the correct price and the excellent customer service that they have. In addition, it will affect the entire network of systems that we have provided to our clients for more than 10 years.

[Note: LinkedIn does not have a profile for Nodac Technology, though Cortes has a personal LinkedIn profile.]

Allied Home Security, 7 employees, executive Michael Pittman submission:

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We have used Hikvision Products for many years, The security of Hikvision is very high. Over the years they have taken great lengths to increase security measures. I personally have Hikvision security products in my home and business and feel very comfortable with them. We have installed their products for many customers and never once had any complaints on security concerns. The FCC proposal will hurt the small security businesses the most- We are only able to thrive because of companies like Hikvision because of good quality and a good price. The companies that will benefit from this will take advantage of the market and push the smaller companies like us out. The FCC investigation was needed; however requiring Hikvision to make changes seems like the more appropriate approach rather than banning their products. Hikvision also employs thousands of American jobs here in the US from Direct employees to the many jobs they create with their products.

Citizens Fiber, 12 employees, sales engineer Bob Ray submission:

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As a concerned reseller/certified installer our business would drastically be impacted by not being able to secure and install Hikvision security product in the US because of the large existing customer base that we maintain and support. It could be detrimental to our business if we had to "fork-lift" our customers to a different platform. We have thousands of camera systems in the field and have had no security threats to date with any of our customers. Our business model is heavily built around the sales, installation and support of Hikvision products and I would encourage the FCC to allow Hikvision to be available in the US market. Thank you.

Heritage Technology Solutions, 14 employees, technology consultant Ron Valdez submission:

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My company is an IT management company that also installs HikVision cameras for our customers. We have customers ranging from Financial institution, to municipal governments as well as healthcare organizations. We have never had a cyber security issue with HikVision products, and they have also passed 3rd party IT security audits. The FCC proposals threatens both my companies and my own lively hood. Security cameras make up 40% of our business, and 50% of my personal income. The HikVision products are attractive to our customers because of thier unmatched value. 95% of my customers use HikVision. I fear that potential customers will choose to forego installing a camera system if they can't get the value the HikVision products provide. If they do not buy a system, then mine and my companies income will fall to half. If customers are forced to uninstall thier current system and reinstall another manufacturer, that will be costly to thier business or organization. It may also put thier business at risk if they cannot afford a new system. I strongly urge the FCC to discontinue any actions that would result in the banning of any HikVision products in the U.S. The results would be catastrophic for many Businesses and individuals that rely on this product for thier safety and livelyhood.

Heritage Technology Solutions, 14 employees, employee Dan Uelman submission:

We are an IT company and have never experienced any breaches or issues. Tech support has also always been top notch. Hikvision also keeps up with security patches and information pertaining to any issues. Hikvision is also popular due to the cost - many companies that use hikvision purchase due to the cost differences. Needing to protect their properties, hikvision offers this soultion while not breaking the bank.

Address of poster matches Heritage Technology Solutions.

FoxCrest Security, 1 employee, owner Chris Danzberger submission:

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I am a small security business owner. I firmly believe that Hikvision can be used in commercial and residential settings and at the same time be banned in government buildings. Denying thousands of consumers the choice to use Hikvision's products would be extremely detrimental to my business. I offer only Hikvision cameras to my customer base because they are simply the best value to consumers. It comes down to opportunity cost. I gave up my ability to do business with the federal government since we install Hikvision cameras. Looking back I think it was the right decision to ban the cameras from government buildings, it was the right opportunity cost. The opportunity cost in prohibiting Hikvision from commercial and residential markets is too great, it will be more detrimental than what it might gain.

Paradigm Electric Inc, project manager Mike Hall submission:

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I am writing to you today with concern as to the revocation and/or limitation of being able to procure security equipment (Cameras Etc.) from HIKVISION USA. The concern for me personally is that the equipment is not clear if the use is limited to just Government contracts and/or projects. With the political climate and the constant fact, in my opinion, that the Peoples Republic of China has for years been at odds with the west, by their nature to adapt what they create from others, the United States is not the only country to be a victim and continues to be a victim. However the Camera products from HIKVISION are not just produced for sale by them, but they are manufactured (software and hardware) for several other camera companies throughout the world. Is it the intent to exclude all of the other manufacturers that OEM from HIKVISION to these companies, both in software and hardware. I think the decision of the FCC potentially would have the impact financially and functionality if the term "USE" isn't defined could have ramification to our company as well as countless others. I hope that I understand and appreciate the dynamic of not having them capable on US Government project as a matter of national security. In my experience with HIKVISION they appear to have fairly open structure for allowing the security of the software and firmware access up to the individual, but I am not so completely blinded that there may be other pathways for them to potentially gain control and/or view camera systems through sub-routines. I would be more concerned about hackers either in our country or other countries that there is a will there is a way to gain access to these cameras, and would make sense to limit the US Government applications, but not general commercial use. I feel if this is passed that there will be a lot of harm done to smaller contractors and installers that could and will impact our economy and the jobs market. This decision is one that should be based on facts and not perception or politically motivated.

[Note: LinkedIn does not have a profile for Paradigm Electric Inc, though Hall has a personal LinkedIn profile.]

Electronics Supply Co., Inc. submission, 21 employees:

We have had no issues with the security of Hikvision cameras. If the FCC bans use or sale of Hikvision cameras it could decrease our security cameras business 30% and cause us to lose customers. Our customers are contractors and they could lose as much as 30% business from their customers as customers will not be able to fund replacement of their existing Hikvision cameras. The majority of our customers are non-government. These customers do not believe that Hikvision impacts their security on their network as long as the cameras are on a standalone (local) network. The FCC proposal should warn that cameras connected to a public network could pose a security risk without implementing proper security safeguards such as unique passwords and firewalls, but allow purchase of them.

Advanced Business Communications submission:

We have been buying and installing HikVision cameras and DVR/NVR's since 2014. We have 100's of systems installed at our customers sites and have never had any security issues with any of them during that time. We are an authorized buyer and only purchase from authorized distributors. Since 2014 we have only had a handful of warranty issues with the cameras or recorders. The cameras, recorders and software offer a cost effective solution with a great image in the US market. If this product is banned it has the potential to hurt our company both from a reputation standpoint and financially. This will affect the economy as a whole as countless customers are forced to either replace their existing systems, not to mention new systems sold to install will be higher as there are fewer choices in the market. Thank you for your time and consideration in this matter.

[Note: LinkedIn does not have a profile for Advanced Business Communications Inc.]

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Brooklyn Low Voltage Supply, 30 employees, owner David Pilchik submission:

this will negatively impact many existing products that are already installed and affect many livelihoods that rely on this technology to service and install the product

Automated Lifestyles LLC submission, 6 employees:

As a professional installer we've never had any issues with HikVision, both commercial and residential applications. If you want to ban HikVision for government installations, fine. But to take it to a nationwide banning hurts small businesses such as ourselves who rely on well-known cameras, spare parts for our current clients, ongoing support and upgrades. This would be detrimental to our business, and therefore our families.

[Note: LinkedIn does not have a profile for Patriot Fire & Security.]

Custom Wired, LLC, owner Aaron Oakley submission:

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I own a Security business with employees that have installed Hikvision products for over 6 years now. I would like to express that this ruling on this FCC proposal could greatly affect my business, employees and our families. Over 50% of our business is installing and maintaining Hikvision camera systems for central Ohio. For over 15 years the residents and businesses of our and surrounding counties have trusted us with their security needs and we have gone to great lengths to test and find products that meet our standards of security, in all that time we have never had one single instance of any security issues described in the proposal. I think I speak for many small businesses across the country when I say - Should this proposal pass, this would not only ruin the trust that we have build up over the years with our clientele but also the people we employ along with the families that depend on us.

[Note: LinkedIn does not have a profile for Custom Wired, LLC though Oakley has a personal LinkedIn profile.]

Alpine Communications Inc., president Douglas Scot Browning submission:

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Alpine Communications Inc. has been installing HIKVision security camera systems for many years and have had no issues with the products. The HIKVision products are far superior to much of the market and allow our customers to enjoy a quality product at an affordable price. Alpine has installed HIKVision products in homes-businesses and hospitals. All our customers are satisfied with the product and any limiting of HIKVision to continue to service their equipment will be a burden on all involved. Please consider my comments before ruling on these proceedings. Thank you Doug Browning

[Note: LinkedIn does not have a profile for Alpine Communications though Browning has a personal LinkedIn profile.]

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Intellitech Systems, Inc., 11 employees, CEO Frank Fritz submission:

We have had a positive experience with Hikvision, and we support worldwide free-market competition. Their U.S.-based support and staff are amazing, and the quality of the product is great.

State Security LLC submission, 21 employees:

HikVision plays an important roll with our client base. They have supplied us with good quality products and a great price point for many of our clients. We currently have several of their systems in place and banning them from selling in the United States will jeopardize our ability to support equipment installed. Security risks as not an issue as long as our clients are aware of the need to secure their networks, which is vital, no matter whose equipment is resting on them. The FCC need to consider the security companies and clients already invested in HikVision products. Also, they have proven over an over their commitment to web security. Much more than most of their competitors.

The address of the poster matches State Security LLC.

Custom Audio-Video Inc., 8 employees, president Curtis Maglinger submission:

I've never experienced any security issues with Hikvision.

Nelly's Security, 9 employees, owner Sean Nelson submission:

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Thank you for allowing me to comment on this proceeding. It is my understanding the the FCC plants to eliminate any future FCC authorizations for the Chinese companies Hikvision and Dahua. It is also my understanding that the FCC is possibly considering revoking prior authorizations for these Chinese companies as well. The possible revocation of previous authorizations is what I would like to comment on today and what kind of negative impact it could have on American businesses all along the supply chain. My first suggestion would be to simply avoid revoking any prior authorizations as this is the best possible solution to eliminate a "can of worms" scenario that could be very detrimental to all American Businesses and Consumers that have purchased and used these products in the past. Completely revoking all prior authorizations would leave a big question unanswered as to what to do with all of the millions of pieces of equipment that are installed in homes and businesses across the USA that were purchased and installed legally in the previous several months and years. Enforcing a "full replacement of equipment" scenario would not only be extremely difficult to enforce, it would also be a very costly endeavor for the affected businesses and consumers. Unlike government entitities, US businesses and consumers do not have the funds available to incur the replacement cost of an expensive item such as a surveillance system. If this scenario was enforced, this would guarantee that consumers and businesses would demand refund/returns of previously purchased equipment from their immediate suppliers, most of which will all be American Businesses or Installers. Such a large quantity of return request would surely put businesses in a bad financial situation and/or elimate them completely. Lawsuits would ensue, pitting American Business Vs. American Business and/or US Consumer VS. American Business. This will truly have damaging effects against American entities involved that used or purchase these products in the past. The 2nd question that comes into place is what to do with all of the exisiting unsold inventory that resides in American Suppliers and American Installers warehouses throughout the USA and what these American entities would do if they are not allowed reasonable time to legally sell these products at a fair and profitable price. There are millions of dollars worth (if not billions) of inventory residing in the USA inside American businesses. The worse case scenario is that a quick ruling would not give the American Businesses ample time to sell the products, leaving the businesses with devestating dollar amounts of unsellable inventory. This would surely also severaly damage US businesses involved and/or worse case, put them under completely. As said, my best suggestion would be to avoid revoking prior authorizations as this would completely avoid any confusion on what to do about the scenarios that I posted above. However, if the FCC does go ahead and decide to revoke prior authorizations, then the FCC needs to give special consideration to the American Businesses and Consumers that have purchased and used these previously "FCC authorized" products both in the present and in the past. Specifically, the FCC should give special consideration as to avoid devestating financial impact to these American Entities. My suggestion would be to allow for previsouly authorized products to continue to be installed on already existing installations. This would avoid a "rip and replace" scenario which simply would not be feasible on many levels. My next suggestion would be to allow American Suppliers and Installers ample time to legally sell down their current inventory (my suggestion would be atleast 1 full year) and allow those sold products to be installed and used at their customers locations without any fear of those customers having to replace them at some later date. I believe my suggestions are fair and take into consideration both the FCC's concerns as well as the concerns of American Businesses who currently and/or have dealt with these products in the past. I hope you take them into consideration. Feel free to reach out to me for further clarification.

DEPS Security Systems, 11 employees, IT manager Matthew Daughtry submission:

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This proposal presents a great threat to our business as it needlessly restricts equipment from a manufacturer that is peripheral to the villain of this discussion, Huawei. Our company has utilized Hikvision equipment for the past 6 years with no issues or concerns presented from the use of said manufactures equipment. Sales of surveillance equipment accounts for 60% of our total sales and Hikvision is the product we are trained in and trust for our customers. Our business and the employees it supports relies on the sales of Hikvision equipment in order to continue to survive in the difficult market we find ourselves in due to COVID19 and its variants. The future sales are dependent on FCC approval of Hikvision products, but in addition, the support and upgrades on the thousands of devices we have installed for customers that trust us with their safety depend on our ability to do business with Hikvision. Without that partnership, those customers are left with an investment in security that can no longer be supported by us or anyone else for that matter. In closing, the concern of the FCC regarding the CCP involvement in US affairs is understandable, but the proposal must be revised to no longer include manufacturers that have no malicious intent (Hikvision) and are relied upon for their quality products where they are needed most.

Hikvision USA strategic distribution accounts manager Michael Maslowski submission:

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There are many reasons that this proposed ruling will negatively affect both the industry as a whole, as well as countless American small businesses and employees. First of all, the demand for intelligent video security equipment is far outpacing supply. This is exacerbated by a severe shortage of critical electrical components, hindering many manufacturers to meet this demand. Hikvision is the largest manufacturer of video security equipment, and has a catalog that reaches many other needs and verticals in security. This proposed ruling could leave a massive hole to fill in a high demand sector that is already seeing a major supply issue. Hikvision is one of the few manufacturers large enough to satiate this demand, and has been delivering high quality products to the security marketplace for years. Second, there are a vast number of installers, integrators, and distributors that rely heavily on the Hikvision brand here in the United States. I have personally talked to several of these companies that stated this proposed rule could have a crippling effect on their business. Some of them could even have to make hard decisions to stay in business or let employees go if the branded products that they built their business on are taken away. Lastly, I would like to make a comment on the character of those who manage Hikvision USA. I have been with this company since 2017. Last year, in the midst of the COVID pandemic and shortly after the birth of my son, I was diagnosed with a severe illness that required immediate surgery as well as ongoing treatment and more surgeries afterwards. The upper management of this company have been extremely supportive of my health journey and have ensured that I maintain steady employment and health benefits. Not many companies would have stepped up and done this, especially in the uncertainty of the pandemic. This proposed rule could put American employees and our families at risk of losing income and health benefits. To summarize, I feel that this proposed rule may be misguided. The true victims from potentially eliminating certifications from Hikvision products will be the many American businesses, employees, and families that rely on the brand. Not only that, but the massive hole left in the video security industry in America may not be able to be filled for years to come, thereby sacrificing the ability to secure due to sentiment against a Chinese manufacturer - one who gainfully contributes to the economy through employing Americans and serving American businesses.

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