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Purifi 1ET400A with linear PSU tested to comply with FTC rule

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So that's your interpretation of the regulation. 2 tests at the extremes?

Don’t even try to rationally engage with the specifics of what he writes. It’s just a tantrum and he’ll change the details and keep banging on about how @amirm is a “fool,” without ever acknowledging that he changed the details.
 
This discussion is pathetic.

Test at the frequency extremes, 20Hz and 20kHz. Nobody cares about 1kHz, it was always a cop out frequency. The fact Amir continues to rank amplifiers on a 1kHz SINAD number only makes him look like a fool.

Any frequency across the rated bandwidth. Measure the harmonics. Extend your measurement bandwidth.

Can your amplifier deliver its rated power across the audible bandwidth with a distortion less than or equal to its headline number?
With all due respect: why can't you just take part of the discussion without being so impolite?
 
No, you start with the "letter of the regulation " whether this regulation is logical is not relevant until it's challenged. Welcome to the US legal system.
It will be challenged, don't worry. It is not the US legal system who may decide if something is logical or not - it is the playground for the Formal Logic only. But someone may use the formal logic to challenge the applicability of some rule in the (US) court. Welcome to the world of logic!
I wrote that FTC requirements for "all frequencies" is not logical. It is you who are trying to defend that "all frequencies" nonsense.
 
Again, you are talking legal nonsense! It is impossible to test infinite number of something - per your literal interpretation. That is not "engineering perspective" but legal and logical one.
You will lose big time in the court if you try to accuse some amplifier manufacturer for testing only at several frequencies (including 20 Hz and 20 kHz) and not at infinite number of frequencies (while marketing their amplifier as FTC compliant). Wanna bet?
Who is “you”? The clarity of any piece of writing is the sole responsibility of the author, which in the case of this rule is the FTC. Any ambiguity redounds to the interpreter.

The only party that can bring action based on this rule is the FTC, because near as I can tell it is only a trade dress rule. If a company lied about their tests and claimed something without having tested it (or falsified test results), then a customer can sue them in state civil courts for misrepresentation (fraud). If the claim is made across state lines, that can be extended to mail fraud, which is criminal at the federal level though with a higher burden of proof. But if the company does not claim to conduct an FTC-compliant test because doing so makes no sense to them, the FTC will have to bring that action because there is no fraud or misrepresentation.

It seems to me if the FTC fined a company for not reporting FTC power and the company refused to pay the fine, the FTC would have to sue them for it. Then, all this would get argued in court and experts would be called to testify on both sides. (I doubt it would make it past discovery and interrogatories.) The likelihood of justice isn’t high in the scenarios, based on my observation. But lawyers would earn a lot of money and manufacturers and consumers would not.

The difference between an engineering principle and a logical one assumes that engineers are illogical and would have no meaning in court. Engineers are only illogical when they design products that do not meet the needs of users (which happens often). A failed design is not a matter of logic, but rather engineering process and technical competence. In the end, as soon as the court (i.e. judge) or jury reaches enough technical understanding (in their minds) to form a conclusion, additional explanation will be unlikely to alter the outcome. The side that starts and sticks with plain language has the advantage, whether or not they should. The side that makes the other side seem ambiguous and hard to understand also has the advantage, and that is almost always the manufacturer.

An industry standard created by the consensus of an expert working group makes sooo much more sense for consumers.

Rick “served time as an expert witness on subjects that matter more than amplifier power” Denney
 
From a legal perspective you need to read the regulation as is, it isn't open to my or your "interpretation " as some here want to make it. Testing 4 frequencies may be more than enough to comply to your interpretation but it no way meets the requirements. Whether the regulation of 20hz-20khz makes sense from an engineering perspective will only come into play if the regulation is challenged or the FTC makes a clarification.
Of course there's my crystal ball interpretation which is the FTC isn't going to put much effort, if any, into enforcement of it.

Read it carefully. The regulation sets performance goals. It states "shall be obtainable". No where does it require testing at all frequencies and power levels. It also does not say it needs to be able to pass the tests at all frequencies and all power levels simultaneously.

It's up to the FTC to prove the amp isn't in compliance with the regulation. This is almost the opposite of something like FCC 15B which requires manufacturers to submit testing results to prove compliance.

As an aside, the use of shall in the document should be replaced with must if it's a mandatory requirement. Supreme court has ruled shall can be interpreted as either must or may depending on context. Also the use of shall violates OPM guidelines after the 2010 plain language bill was passed.
 
Read it carefully. The regulation sets performance goals. It states "shall be obtainable". No where does it require testing at all frequencies and power levels. It also does not say it needs to be able to pass the tests at all frequencies and all power levels simultaneously.

It's up to the FTC to prove the amp isn't in compliance with the regulation. This is almost the opposite of something like FCC 15B which requires manufacturers to submit testing results to prove compliance.

As an aside, the use of shall in the document should be replaced with must if it's a mandatory requirement. Supreme court has ruled shall can be interpreted as either must or may depending on context. Also the use of shall violates OPM guidelines after the 2010 plain language bill was passed.
True, it doesn't even require to test at all.

From what I can gather even those who claim 20hz, 1hz, 20khz is a good enough "interpretation " don't perform them simultaneously but 5 minutes at each frequency.

On compliance, if the FTC has a question on a company's advertised power rating
I assume they would issue a Notices of Penalty Offenses to trigger their authority. I'm not sure they would need to prove the company isn't in compliance at that point but ask the company to show what tests they performed to meet the requirement. That might be the end of it if they're satisfied if not then they would need to prove why.

There is a petition to reopen before the FTC on the question of retroactively applying the regulation. Comments from companies have asked them to also address the vagueness of the testing. Hopefully they will take the opportunity to more clearly state their intention. I wouldn't hold my breath.
 
True, it doesn't even require to test at all.

From what I can gather even those who claim 20hz, 1hz, 20khz is a good enough "interpretation " don't perform them simultaneously but 5 minutes at each frequency.

On compliance, if the FTC has a question on a company's advertised power rating
I assume they would issue a Notices of Penalty Offenses to trigger their authority. I'm not sure they would need to prove the company isn't in compliance at that point but ask the company to show what tests they performed to meet the requirement. That might be the end of it if they're satisfied if not then they would need to prove why.

There is a petition to reopen before the FTC on the question of retroactively applying the regulation. Comments from companies have asked them to also address the vagueness of the testing. Hopefully they will take the opportunity to more clearly state their intention. I wouldn't hold my breath.

Without a doubt a poorly written rule and there's no way for them to retroactively enforce it. Once the information is out there it can't be retrieved, nor can a manufacturer guarantee that every supplier and distributor uses and distributes the latest info. I almost wonder if some manufacturer or trade group might just fight the rule now that Chevron has been overturned.
 
True, it doesn't even require to test at all.

As I read it, it requires to test if the manufacturer wants to specify the power output or distortion (which we didn't even touch upon until now).

Whenever any direct or indirect representation is made of the power output, power band or power frequency response, or distortion characteristics of sound power amplification equipment, the manufacturer's rated power output shall be disclosed subject to the following conditions:

(a) The rated power output is measured in compliance with the standard test conditions in § 432. 3;

As mentioned before, the whole problem is that the rule is open for interpretation.
 
Who is “you”? The clarity of any piece of writing is the sole responsibility of the author, which in the case of this rule is the FTC. Any ambiguity redounds to the interpreter.

The only party that can bring action based on this rule is the FTC, because...
"You" is FTC's lawyer (or someone acting as one - @JustJones , for example).
If amplifier manufacturer tested their amplifier with only 4 frequencies (20Hz, 1 kHz, 6.6 kHz and 20 kHz) for 5 minutes at each frequency and find these power output (at 8 ohm), for example:
100W@20Hz, 150W@1kHz, [email protected] and 80W @20kHz, with no more than 1% THD,
than they may freely advertise their amplifier to be FTC compliant, because they don't lie about those measured numbers.
But if FTC or @JustJones try to sue that manufacturer (requesting testing with "all frequencies in 20Hz-20kHz range"), they will fail spectacularly at the court - even the stupidest judge know that there is infinite number of frequencies at that range (or any range), so it will impossible for anyone to do that.
Of course, the easiest way is FTC to change the nonsense "all frequencies" with something logical.
 
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"You" is FTC's lawyer (or someone acting as one - @JustJones , for example).
If amplifier manufacturer tested their amplifier with only 4 frequencies (20Hz, 1 kHz, 6.6 kHz and 20 kHz) for 5 minutes at each frequency and find these power output (at 8 ohm), for example:
100W@20Hz, 150W@1kHz, [email protected] and 80W @20kHz, with no more than 1% THD,
than they may freely advertise their amplifier to be FTC compliant, because they don't lie about those measured numbers.
But if FTC or @JustJones try to sue that manufacturer (requesting testing with "all frequencies in 20Hz-20kHz range"), they will fail spectacularly at the court - even the stupidest judge know that there is infinite number of frequencies at that range (or any range), so it will impossible for anyone to do that.
Of course, the easiest way is FTC to change the nonsense "all frequencies" with something logical.

Good points - and I think it's worth making sure one key detail in what you've written does not get lost: "then they may freely advertise their amplifier to be FTC compliant."

It's a not-insignificant question to ask whether amp makers care about advertising FTC compliance in their power ratings.
 
Read it carefully. The regulation sets performance goals. It states "shall be obtainable". No where does it require testing at all frequencies and power levels. It also does not say it needs to be able to pass the tests at all frequencies and all power levels simultaneously.
Exactly. I was hoping someone would pick up on the specific wording: "shall be obtainable." It doesn't imply testing every frequency between 20 and 20,000 Hz.
 
Exactly. I was hoping someone would pick up on the specific wording: "shall be obtainable." It doesn't imply testing every frequency between 20 and 20,000 Hz.
Oh, then what does "all frequencies within the rated power band of 20 Hz to 20 kHz" imply ? Does it mean " shall be obtainable " at 1 frequency, 2 , 4, 6, 10 ? Can you give us a good alternative to "all frequencies " that doesn't mean all but some? That's the problem people keep taking snippets of the regulation and "interpreting" them to how it fits their notions. It doesn't say "test" at every frequency as you point out but the rated power has to be obtainable at "all frequencies". What tests show the rated power was obtained at all frequencies between 20hz-20khz?
(e)

Any power level from 250 mW to the rated power shall be obtainable at all frequencies within the rated power band of 20 Hz to 20 kHz without exceeding 1.0% of total harmonic distortion plus noise (THD+N) at an impedance of 8 ohms after input signals at said frequencies have been continuously applied at full rated power for not less than five (5) minutes at the amplifier's auxiliary input, or if not provided, at the phono input.
 
I definitely don't see it as trolling.

I suppose I'll be a vendor that jumps directly into this discussion and say the new rule is flawed and can easily be challenged if the FTC were to try to take action against a company.

A flawed policy is still flawed no matter its intention. And to think it will hold any weight in the current state of the US political and judicial system...now that's a joke.

So, sure, we can keep arguing back and forth what one considers a valid interpretation or what might constitute a reasonable persons interpretation of what the policy states but it is moot.

It has been funny to watch people outside the US champion this new rule since August as a reckoning of sorts for audio companies in the US only to come to the realization that the way things work in this country means no reckoning is actually coming.
Reminds of me a brief sketch in The Simpsons where a newspaper article simply reads "Old Man Shakes Fist at the Sky"
 
@Buckeye Amps , why do not you rather concentrate on better amplifier testing and understanding how to make a test system rather than spending time in pointless discussion? Learn and grow, and you would not face the Stereophile fiasco again.
 
@Buckeye Amps , why do not you rather concentrate on better amplifier testing and understanding how to make a test system rather than spending time in pointless discussion? Learn and grow, and you would not face the Stereophile fiasco again.
Hmm, you seem to think my implied (by you) lack of understanding on how to test an amplifier is what led to the bad Stereophile measurements?

Now that's funny.
 
Exactly. I was hoping someone would pick up on the specific wording: "shall be obtainable." It doesn't imply testing every frequency between 20 and 20,000 Hz.

How does one become compliant with "shall be obtainable at all frequencies" if not by actually obtaining, while testing? ;)


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