Internet DRAFT - draft-gogic-geopriv-concepts

draft-gogic-geopriv-concepts



Network Working Group                                         A. Gogic
Internet Draft: IMAP ANNOTATE Extension                  QUALCOMM, Inc.
Document: draft-gogic-geopriv-concepts-00.txt                June 2002

                Location Information and Privacy Concepts

Status of this Memo

     This document is an Internet-Draft and is in full conformance with
     all provisions of Section 10 of RFC2026.  Internet-Drafts are
     working documents of the Internet Engineering Task Force (IETF), its
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     The list of current Internet-Drafts can be accessed at
     http://www.ietf.org/ietf/1id-abstracts.txt.  The list of Internet-
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     http://www.ietf.org/shadow.html.


Copyright Notice

      Copyright (C) The Internet Society 2002. All Rights Reserved.

1 Abstract

     This paper defines and explains some geographic location concepts of
     interest to GeoPriv.  Many of these are of particular interest in
     mobile wireless systems and Internet applications involving those
     systems and devices.  The interaction between location service
     architecture elements is briefly described.  Methods of protecting
     privacy by controlling the precision with which location information
     is disclosed are elaborated.

                            Table of Contents
      1  Abstract  . . . . . . . . . . . . . . . . . . . . . . . . . .  1
      2  Introduction . . . . . . . . . . . . . . . . . . . . . . . .   2
      3  Architecture Elements . . . . . . . . . . . . . . . . . . . .  3
        3.1  Location Computation and Distribution Processes  . . . .   3
          3.1.1  Location Computation  . . . . . . . . . . . . . . . .  3
          3.1.2  Location Distribution  . . . . . . . . . . . . . . .   4
        3.2  Target Object . . . . . . . . . . . . . . . . . . . . . .  4
        3.3  Target Object Privacy Profile  . . . . . . . . . . . . .   4
        3.4  Mobile Station  . . . . . . . . . . . . . . . . . . . . .  4
        3.5  Base Station . . . . . . . . . . . . . . . . . . . . . .   5
        3.6  Location Computation Server . . . . . . . . . . . . . . .  5
        3.7  Location Distribution Server and Policy Engine . . . . .   5
        3.8  Location Client . . . . . . . . . . . . . . . . . . . . .  6
      4  Definitions and Abbreviations  . . . . . . . . . . . . . . .   6
      5  Location Information Content  . . . . . . . . . . . . . . . .  7


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      6  Location Information Distribution  . . . . . . . . . . . . .   8
        6.1  Request/Requestor Authorization . . . . . . . . . . . . .  8
        6.2  Location Precision Classes . . . . . . . . . . . . . . .   8
        6.3  Rounding to Desired Location Precision and Return Data  .  9
        6.4  Speed Category and Precision Classes . . . . . . . . . .  11
        6.5  Encryption  . . . . . . . . . . . . . . . . . . . . . . . 11
      7  Location Data Confidence . . . . . . . . . . . . . . . . . .  11
      8  Security Considerations   . . . . . . . . . . . . . . . . . . 12
      9  References   . . . . . . . . . . . . . . . . . . . . . . . .  12
     10  Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . 12
     11  Author's Address . . . . . . . . . . . . . . . . . . . . . .  13
     12  Full Copyright Statement  . . . . . . . . . . . . . . . . . . 13


2 Introduction

     The primary motivating factor for the development of location
     services in wireless system has been the implementation of emergency
     services encompassed in the United States by the Federal
     Communications Commission (FCC) mandate for the so-called "Enhanced
     911" (E911) capability (see Ref. [2]).  These services were
     initially defined to supply location information to a public safety
     operator in conjunction with an emergency call.  Re-using the same
     technology for services unrelated to voice calls in general and
     emergency calls in particular, is viewed as a desirable development,
     particularly if accomplished in the Internet environment, with the
     potential of rapid development of a variety of commercially
     desirable applications.

     There are many examples of TCP/IP-based location applications that
     are not related to emergency assistance.  Many believe that these
     applications are uniquely mobile, so-called "killer apps".  A
     prominent class of applications is TCP/IP-based tracking and
     navigation/routing assistance.  For example, a user might want to
     obtain his or her own location and get route directions using
     interactive maps.  An application or a person might want to locate
     someone else, e.g., family members or "buddies" in a closed user
     group.  Another example is geo-fencing, allowing users to define a
     permitted location perimeter and causing an automatic notification
     if a mobile moves outside of this perimeter.

     Availability of simple and reliable location-based services might
     open up an entirely new market for un-manned devices, such as fleet
     management, dispatch optimization, law enforcement, even livestock
     and wildlife management.

     Location may be combined with other wireless telecommunication
     services to provide enhanced services, such as location-based
     commerce, service tiers, etc.

     With some notable exceptions (such as livestock and wildlife
     management), privacy of location objects is one of the key


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     requirements in most of these location applications.


3 Architecture Elements

     This section introduces some basic architecture elements for
     location services that are applicable in the wireless domain,
     illustrated in Figure 1.
                             BS-2
                            *  |
                       d2 *    |
             d1         *      |
     BS-1 * * * * *  MS        |
       |              *        |
       |               *       |    _________
       |             d3 *      |   |         |
       |                 *     |   |   AAA   |
       |                  *    |   |_________|
       |                BS-3   |        |
       |                  |    |     ___|___     ________     ________
       |                  |    +----|       |   | LDS &  |   |  Loc.  |
       |                  +---------+  LCS  +---+  PE    +---+ Client |
       +----------------------------|_______|   |________|   |________|
                 Figure 1: Location Services Architecture

     Legend:
         BS          Base Station
         MS          Mobile Station
         LCS         Location Computation Server
         PE          Policy Engine
         LDS         Location Distribution Server
         Loc. Client Client requesting MS location
         * * * *     Wireless mobile connections between the MS and BSs
         ----- & |   Fixed line connections between BSs and core
                     network elements, and among those network elements
         d1, d2, d3  Distances from the MS to BS 1, 2, and 3 respectively


3.1 Location Computation and Distribution Processes

     One can conceptually think of location services as consisting of two
     distinct processes:  Location computation, and location
     distribution.  Each is controlled by a separate logical entity shown
     in figure 1 as Location Computation Server (LCS), and Location
     Distribution Server (LDS).  In practical implementations, these
     servers may be combined in a single physical entity.  This may be
     desirable because there are close security trust considerations
     among the two.


3.1.1 Location Computation



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     Location computation is the process of computing the location of the
     target.  It consists of initiation of location measurements, and
     their conversion into a meaningful set of location information, such
     as latitude, longitude and altitude.

     There are a number of location computation technologies available
     today.  Each contains specific location computation procedures.  In
     this document, the intent is not to elaborate on any of these
     specific techniques, however, in the text below, some of the
     techniques have been alluded to, primarily as background
     information.  In general, it can be stated that the GeoPriv task
     does not depend on the vagaries of these techniques.

3.1.2 Location Distribution

     Location distribution is the process of proving a target's location
     to a requesting client, and consists of several sub-processes:
     *   Receiving location requests from the location client;
     *   Checking if the requester is authorized to receive location data
         (e.g. verifying subscription status);
     *   Performing location client authentication, if required;
     *   Applying the privacy profile of the user to the raw unfiltered
         location information, to convert it into a form that is allowed
         for disclosure (for example by rounding to the time zone, or to
         within the city boundary where the object is located)
     *   Transmitting filtered location data to the location client, with
         encryption, if required.


3.2 Target Object

     The target object is the object whose location information is
     sought.  The ability to control privacy for the target object is
     required.  In some cases, the user can authorize each individual
     location client request for the object's location information.


3.3 Target Object Privacy Profile

     The profile detailing the location privacy information (policy) for
     the object (e.g., authorization class, location client exception
     list, level of location precision disclosure for a given location
     service client, etc.)


3.4 Mobile Station

     A mobile station (MS) is a peripheral device, such as a wireless
     telephone handset or a PDA, which is typically the location target.
     The mobile station may contain a GPS (Globile Positioning System)
     receiver, or may be able to make location computations by
     triangulation from transmissions from three or more base stations.


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     By transmitting a radio signal that is received by multiple base
     stations, such triangulation may be possible by means of time of
     arrival information available at the base stations, or by means of
     round-trip delay involved in combining BS-MS and MS-BS transmission
     timing.  The mobile station may also play a location client role, as
     is the case where user wants to find out where he or she is located.

3.5 Base Station

     Base stations (BS) are relay points of communication between the
     mobile station and the rest of the telecommunication system.  Base
     stations play an important role in location determination process.
     In GPS-based technologies, base stations can be used as reference
     locations in order to relay assistance information to the GPS
     receiver in the mobile station, including satellite constellation
     data, and Doppler shift due to satellite velocity relative to the
     mobile station.  Such assistance accelerates the GPS receiver's
     ability to perform a location fix.  Base station locations are known
     by the system, and may be conveyed to the mobile station as well.
     Using that knowledge, the mobile station location can be computed by
     triangulation methods.  In practical implementations, some of these
     techniques can be combined to increase confidence, or to choose the
     one that is most appropriate, e.g., depending on satellite
     visibility in the mobile stations locale, or complexities of
     multipath radio signal propagation, which may obscure actual
     location.

     Reference [1] can be used as an example of radio link signaling used
     in location determination.


3.6 Location Computation Server

     The location computation server (LCS) collects raw measurement data
     related to location determination and computes the target's
     location.  Raw data may include latitude, longitude, and elevation
     from the fix performed in the GPS based system, as well as the
     number of satellites visible by the GPS receiver in the mobile
     station, allowing it to ascertain measurement confidence.  In
     triangulation methods, the LCS uses known base station locations,
     and any calibration information, such as base station transmission
     timing offsets, or mobile station receive-transmit timing offset, to
     make location computations.


3.7 Location Distribution Server and Policy Engine

     The location distribution server (LDS) performs tasks listed in
     section 3.1.2

     The LDS acts as the proxy for location distribution.  Requests for
     location from Internet-based clients can be referred to the LDS


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     first.  The LDS can perform client authentication, and with the
     assistance from the Policy Engine (PE) determine what privacy
     policies are applicable, whether or not a new fix is required, etc.
     It may then decide to order a new fix.  In a typical implementation,
     the LDS may use encrypted transmissions of location data either on
     the wireless link, the Internet link, or both.  The LDS also
     communicates with an AAA server to verify authorization, convey
     accounting data, and retrieve authentication information, such as
     authentication and encryption keys.

     LDS/PE and LCS are often incorporated in a single entity.

3.8 Location Client

     A location client is an entity that interacts with the location
     object or its proxy to obtain location information.  The interaction
     may be constrained by a set of specified parameters, such as
     attributes of location precision.  The location client may have to
     subscribe first, before being allowed access to location
     information.  The location client is often responsible for
     formatting and presenting data and managing the user interface.  The
     LCS Client may also reside in the target object.


4 Definitions and Abbreviations

     In addition to the entities and concepts related to system
     architecture defined in the previous section, we provide herein some
     useful definitions and abbreviations.

     Altitude
         The geodetic location of the target object expressed as distance
         above World Geodetic System 1984 (WGS-84) reference ellipsoid.

     Confidence
         Probability estimate that the location of a target object is
         within the defined geographic shape (perimeter).

     Last Known Location
         The time stamped location estimate stored for the target object.

     Location Client Personalization
         A collection of attributes related parameters assigned to a
         location client.

     Location Estimate
         The geographic location of a target expressed in the reference
         World Geodetic System 1984 (WGS-84).

     Location Precision
         A set of attributes associated with a request for the geographic
         location of a target.  The attributes include the required


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         horizontal accuracy, vertical accuracy, response time, and
         maximum age of the target location estimate.

     WGS-84
         World Geodetic System -- 1984.

     WGS-84 Ellipsoid
         Worldwide reference system defining the surface of the Earth.


5 Location Information Content

     Some examples of location information content types include:
     *   Geographic location (latitude, longitude, altitude, elevation)
     *   Time zone in which target is located
     *   Horizontal and vertical speed
     *   Heading
     *   Resolution and associated confidence level for each relevant
         datum
     *   Address (Country, province or state, region, city, area such as
         postal code, street, number, label)
     *   Time Stamp for relevant datum or a data set

     In addition to the above descriptors, other location data types are
     possible, but may be left out from the first release of GeoPriv work
     in the interest of simplicity.  An example is azimuth, which is
     related, but distinct from heading, since it conveys the object's
     orientation, not necessarily direction of travel.

     Latitude and longitude are expressed in degrees, minutes, and
     seconds from the Equator and Greenwich reference meridian
     respectively.  Altitude is expressed in meters above WGS-84
     ellipsoid (mean sea level).  Elevation is height of terrain above
     mean sea level, also expressed in meters.  Height above ground can
     be computed by subtracting elevation from altitude.

     Time zone is expressed as a number of hours and minutes relative to
     the Greenwich Mean Time (Universal Coordinated Time or UTC).  This
     may also be accompanied with a descriptive reference, for example
     Pacific Time Zone (GMT -8 hrs, Tijuana)

     Horizontal and vertical velocity is expressed in meters per second.
     Increasing altitude results in positive vertical velocity.

     Heading is deviation from the True North of the tangential vector
     along the trajectory of travel.  Azimuth is the orientation of an
     object relative to True North.  Azimuth of a stationary object can
     be defined.  Azimuth may deviate from heading.  For example, due to
     wind direction relative to flight path, heading of a flying airplane
     may deviate from its azimuth.




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     Address of an object is the descriptive form of that object's
     location.  It is the description of location of the nearest
     addressable object from a map database.

     Time Stamp may be associated for each location datum or a set of
     data.  Time stamp is expressed in local time and an offset from the
     local time to UTC.

     Some of the described location information types are quite advanced,
     and may not be incorporated in products or services in the first go.
     To keep things simple, Geopriv should initially keep to a relatively
     simple subset of these location objects.


6 Location Information Distribution

     Controlling distribution of location information is one of the
     pillars of privacy.  Some of the issues associated with distribution
     control involve authorization/authentication of location clients
     (requestors) by the location target or its proxy, precision control
     of the disclosed location data as a function of authorization class
     and possibly application, and encryption of location data to protect
     it against inadvertent disclosure (e.g., protection against
     eavesdropping).

     In the following sections we examine each of these distribution
     issues in some detail.


6.1 Request/Requestor Authorization

     The applicable policy should specify how a request for location
     information is to be handled.  Determination can be based on the
     identity of the requestor, the use to which the information is to be
     put, the time of day, and other factors.  The result may be to
     reject the request, approve it, or prompt the user.  If approved,
     the policy may limit the precision of the information.  When
     prompted, the user may approve or reject the request.  Some
     implementations may also allow the user to indicate how future
     requests from the same source are to be handled (for example,
     "reject current and all future requests from this source").


6.2 Location Precision Classes

     In addition to authorization, the primary method for privacy control
     in location services is the user's ability to allow disclosure to a
     certain degree of precision.

     For each authorization class a precision level attribute may be
     defined.  Levels of precision can exist for position (e.g., location
     of a stationary object, or momentary location of a moving object),


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     as well as for velocity and orientation of the object.  These
     classes are listed in the two tables below.

     The user or user agent must have the capability to control the
     precision (resolution) with which the location information is
     conveyed to a location client.  The precision category should be
     indicated to the client.  The following table outlines precision
     categories associated with object's momentary location:

     Location                Precision    Precision   Precision
     Class     Descriptive   (meters)     (LAT)       (LON)

     A         Very Fine      1           not bound   not bound
     B         Fine           10          0.3"        0.3/cos(lat)
     C         Street Block   100         3.2"        3.2/cos(lat) sec
     D         City Quarter   1,000       32"         32/cos(lat) sec
     E         City           10,000      5' 24"      5' 24''/cos(lat)
     F         Province/State 100,000     54"         54/cos(lat) min
     G         Country        1,000,000   9 deg       9/cos(lat) deg
     H         Continent      10,000,000  90 deg      90 deg
     I         Time Zone      N/A         N/A         ~15 deg
     J         Deg Latitude   N/A         1 deg       N/A
     K         Deg Longitude  N/A         N/A         1 deg
     L - Y     ...            reserved    reserved    reserved
     Z         Barred         N/A         None        None
                   Table 1: Location Precision Classes

     Precision specifications provide the order of magnitude, and do not
     indicate certifiable accuracy.

     Average WGS-84 ellipsoid distance from the center of the Earth is R
     = 6,367,445 meters.  This figure can be used to compute latitude and
     longitude arc measurements corresponding to the target precision for
     each location precision class.  While conversion from distance to
     latitude arc is straightforward (lat_arc = d/R * 180/pi [deg]), for
     distances along parallels, this conversion varies.  It is inversely
     proportional to cosine of latitude, with singularities at the North
     and South Pole.

     For example, the latitude precision for the class E (d=10,000 meters
     -- "City") is d/R = 1.57 mili-radians, or 5 minutes and 24 seconds
     of arc.  The longitude precision depends on latitude.  At latitude
     of 42 degrees exactly, for class E case as above, the latitude
     precision is 7 minutes and 16 seconds of arc.


6.3 Rounding to Desired Location Precision and Return Data

     To implement precision control, the location information is rounded
     before being returned to the location client.  Values rounded to the
     desired precision should be returned, accompanied by an indication
     of the precision class.  In principle, rounded data should have full


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     integrity, i.e., provision of deceitful or misleading information
     should be discouraged.

     The same holds true for the case when a descriptive value is
     returned to the location client.  For example, for a location target
     object located in Miami, willing to disclose its location only to
     the precision level F (100,000 meters, or Province/State), rather
     than returning deliberately wrong information, e.g., "Fort
     Lauderdale", it would return "Florida".

     When fine level of precision for location data is required, the most
     universal method would be to return a latitude, longitude, altitude
     triplet.  Another possibility would be to return a descriptive
     location of an object, such as a street address.  In fact, street
     address is the method used for emergency services ("911" in the
     United States) when dialed from a fixed line phone.  The emergency
     service infrastructure looks up the database from the fixed line
     phone number, which returns the address where the line is
     terminated.

     Descriptive value can also be returned as a response to a location
     request to a mobile communication device.  Once the lat/lon location
     is known by the LCS, it performs a geographic database search to
     find the description of the nearest addressable object, and returns
     it to the requesting location client, assuming that no rounding is
     required.  Returning a descriptive value can be more meaningful to a
     location application than the latitude longitude pair would be.

     This becomes interesting when rounding is required before returning
     descriptive location information.  Probably the easiest way that
     this can be accomplished is to display a map segment where the
     target is located, and draw a perimeter corresponding to the
     required precision.

     It is also possible to return a rounded descriptive location without
     having to return a graphic map segment.  The precision figure for
     the classes listed in Table 1 should be used as an order of
     magnitude, not in any rigid fashion.  For example, if class D (City
     Quarter) is required, the return for a target located in New York
     City might be "Manhattan", i.e., a locale that is bigger than the
     1,000 meters order of magnitude for the precision class.

     An opposite problem of having a number of small cities located
     within a radius of 10,000 meters for Class E can be solved by
     returning "In one of several cities", followed by a list of cities.

     Another interesting example is precision class H (Continent).
     Location rounding to 10,000,000 meters yields a large section of the
     globe.  If a descriptive location is desired, the response might be
     "Africa", or "South Pacific Ocean", and need not strictly adhere to
     segments of the globe given by the geodetic return option.  E.g., a
     target located in Morocco may round to a geodetic area that is in


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     Europe.  Yet, the descriptive form of the return will still be
     correct -- "Africa", since the LDE knows the actual location, and
     will return the correct descriptive answer, still preserving the
     level of vagueness implied by the precision class H.


6.4 Speed Category and Precision Classes

     The user must have the capability to control the precision
     (resolution) with which the speed information is conveyed to a
     location client.  The speed precision category should be indicated
     to the client.  The following table outlines speed precision
     categories:

     Speed                      Precision    Value Range
     Class   Descriptive        (km/h)       (km/h)

     VA      Fine                1           Any
     VB      Approximate         10  km/h    Any
     VC      Surface transport   100 km/hr   <100, 100-200, >200
     VD      Airborne transport  1,000       <500, 500-1000, >1,000
     VE - VY ...                 reserved    reserved
     VZ      Barred              None        None
             Table 2: Speed Precision Categories and Classes

     Table 2 lists both speed precision categories and classes of speed
     by magnitude or range of values.  The location client requests the
     desired class depending on the nature of its interest.  If it wants
     the precise speed of the target, it requests VA, or for the
     approximate speed of the target, VB.  In order to find out if the
     target is likely in a surface transport vehicle and class of vehicle
     (slow car, fast car, bullet train, etc.) -- it would request VC, and
     so on.


6.5 Encryption
     Privacy protection generally requires encryption.  This guards
     against inadvertent disclosure of information, as well as
     eavesdropping.  The target may regard its location as very valuable
     information, and may require that any location disclosure be sent
     suitably encrypted.  Encryption usually involves trusted entities
     due to the necessity of exchanging encryption keys, or
     computationaly expensive key exchange techniques.


7 Location Data Confidence

     Location information is an estimate obtained by measurements, which
     is subject to errors and deterioration of accuracy for a moving
     object, e.g., due to age of available data.  Confidence is an
     attribute of location information that attempts to assess the
     probability that the information provided is accurate within a


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     specified perimeter.  The confidence attribute can be affixed to any
     location datum (for example velocity), however, it is most
     meaningful for the point on or near the geodetic ellipsoid surface
     as a descriptor of location, which we will call location datum.  One
     can think of the location datum as the place at which the confidence
     reaches its peak.  To convey location information uncertainty, the
     location information may be provided to the client accompanied by
     the degree of confidence.  The perimeter for evaluation of
     confidence is usually a circle with the center in the location
     datum, but in principle, it can be any shape.  For example, it may
     be of interest to assess confidence that the object is within a city
     block or within an irregularly shaped sports venue.

     Two questions arise:

     *    What is the confidence that the object is within a given
     perimeter?
     *   What is the perimeter within which location datum is provided
         with a given degree of confidence?

     The first requires that the client specifies the perimeter, and the
     target returns the confidence.  The other requires that the client
     specifies the desired confidence, while the target returns the
     perimeter, which may or may not be a circle.


8 Security Considerations

     This document addresses manipulation and transport of the geographic
     location of a target object.  The target object may be closely
     associated with a person, such is the case for a portable cellular
     handset, or for a sensitive object.  Inadvertent disclosure of
     location information, particularly if the information is accurate,
     can be damaging to the person's privacy, and possibly dangerous.
     Security aspects are discussed in some detail throughout this
     document.


9 References

     [1] 3GPP2 C.S0022-0-1 (a.k.a.  TIA/EIA/IS-801) Position
     Determination Service Standard for Dual Mode Spread Spectrum
     Systems, February 2001

     [2] TIA/EIA/J-STD-036-A Enhanced Wireless 9-1-1 Phase 2, August 2000
     (Rev.  A March 2002)

     [3] 3GPP TS 22.071V5.1.1, Location Services (LCS) Service
     Description, Stage 1, March 2002





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10 Acknowledgments

     The author would like to thank the following people who contributed
     to the text and provided many ideas for this draft, as well as
     participated in reviewing it.  All are affiliated with QUALCOMM,
     Incorporated.
     *   Suzanne Arcens, sarcens@qualcomm.com
     *   Randall Gellens, rg+ietf@qualcomm.com
     *   John W Noerenberg II, jwn2@qualcomm.com
     *   Len Sheynblat: lens@qualcomm.com

     In addition, some of the topics discussed in this draft appear in
     documents [1], [2], and [3].


11 Author's Address

     Aleksandar M. Gogic
     QUALCOMM, Incorporated
     5775 Morehouse Drive
     San Diego, CA 92121-1714
     USA
     e-mail:  agogic@qualcomm.com


12 Full Copyright Statement


     Copyright (C) The Internet Society 2002.  All Rights Reserved.

     This document and translations of it may be copied and furnished to
     others, and derivative works that comment on or otherwise explain it
     or assist in its implementation may be prepared, copied, published
     and distributed, in whole or in part, without restriction of any
     kind, provided that the above copyright notice and this paragraph
     are included on all such copies and derivative works.  However, this
     document itself may not be modified in any way, such as by removing
     the copyright notice or references to the Internet Society or other
     Internet organizations, except as needed for the purpose of
     developing Internet standards in which case the procedures for
     copyrights defined in the Internet Standards process must be
     followed, or as required to translate it into languages other than
     English.

     The limited permissions granted above are perpetual and will not be
     revoked by the Internet Society or its successors or assigns.

     This document and the information contained herein is provided on an
     "AS IS" basis and THE INTERNET SOCIETY AND THE INTERNET ENGINEERING
     TASK FORCE DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING
     BUT NOT LIMITED TO ANY WARRANTY THAT THE USE OF THE INFORMATION
     HEREIN WILL NOT INFRINGE ANY RIGHTS OR ANY IMPLIED WARRANTIES OF


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     MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.





















































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