Criminal Tracking Device Technologies and Effectiveness

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Outline

The current development of the new technological landscape has changed the way criminals are tracked. The innovations in electronics mean that there is virtually nothing today’s police officers cannot hear, see, or follow. Parabolic microphones, sonic wave detectors, digital audio bugs, and “bionic cars” allow officers to listen to conversations just about anywhere (Arslan & Yarkan, 2009). Even wiretaps have become much more sophisticated: they can now intercept conversations occurring over cell phones, satellite phones, and between computers (Groot, 2009). Security officers are also able to monitor to see what is going on in most places as the result of night vision technology, thermal infrared imaging, New HD Standard for Network Cameras, helicopter surveillance with forward-looking infrared (FLIR) devices, and tiny video cameras that can be hidden in such things as eye-glasses and smoke detectors (Arslan & Yarkan, 2009; Groot, 2009). There is also the emergence of mobile phone tracking that is expected to boost security search. This paper discusses some of the competing technology in criminal tracking devices and their effectiveness.

Introduction

One perennial challenge has been for the law enforcers, business people, and the public to stay current with the changes in technological advancements (Arslan & Yarkan, 2009). In the past, law enforcers would react towards a new problem that often involved loss or injury to some few people such as the new threat, and often, because the threat of harm was proven beyond a reasonable doubt, public support for law enforcement intervention would be of utmost importance (Groot, 2009). Business people on the other hand would want to make the most of technology to protect their business assets. Currently, however, the landscape has changed, especially on the line of technological advancements with the rapidly changing environment for security situations coupled with new technologies, altering the way criminals are tracked (Groot, 2009). The innovations in electronics mean that there is virtually nothing today’s police officers cannot hear, see, or follow. Parabolic microphones, sonic wave detectors, digital audio bugs, and “bionic cars” allow officers to listen to conversations just about anywhere (p.13). Even wiretaps have become much more sophisticated: they can now intercept conversations occurring over cell phones, satellite phones, and between computers (Groot, 2009). Bangert (2009) observes that security officers are also able to monitor to see what is going on in most places as a result of night vision technology, thermal infrared imaging, and helicopter surveillance with forward-looking infrared (FLIR) devices, and tiny video cameras that can be hidden in such things as eye-glasses and smoke detectors. Many businesses have also adopted High-Definition TV (HDTV) standards for the customer market to have clearer and sharper images of people visiting their premises (Nilsson, 2009). This paper discusses the competing new technologies in the field of tracking devices for criminals such as the ones highlighted above, critically analyzing their merits and demerits, to come up with the best option for criminal tracking purposes.

Material Sources and Search Terms

The study focused on the search for materials from specific databases which have latest information on technological advancement, narrowed down to criminal tracking devices. The UVU library database provided access to other databases in the line of technology like Lexisnexis academics, NetLibrary e-books, Directory of open access journals, e-Journal of Surface Science and Nanotechnology, and EURASIP Journal on Wireless Communications and Networking databases.

In the search, terms used were: “criminal tracking devices”, “tracking devices technology”, “wireless communication”, “electronic monitoring” and “science of tracking criminals”. Even though there were hundreds of results generated in the search, it was narrowed down to articles, e-books and journals written in English, specifically publications in the last 5-years. This was to ensure that innovations that have been overtaken by events were ignored for the purpose of staying current. However, one e-book was found to be very relevant despite being published in 2000, hence was included as a reliable source.

Research Justification

The recent development and belief that it should be easy to find anyone, anywhere, at any time with just a few pushes of buttons has led to the development of many criminal tracking devices based on GPS and other technology. To successfully manage a business, technology has become very important aspect especially due to the increased security scares. Wolfe & Johnson, cited in Colin (2009) say that “one of the most crucial parts of succeeding in today’s business is keeping track of the employees, products, and the equipments” (p.17). The advent of the new technologies and the GPS tracking device has in essence lessened the difficulty of keeping track. Before, keeping track of such meant that one had to make frequent phone calls or just rely on other people for appropriate information, and even “some late night dealing with the changing time zones to follow up on deliveries throughout the world” (Colin, 2009, p.21).

One of the main reasons to use tracking devices is for security and safety. As traveling has become part of business, it is eminent that one can be exposed to any form of danger hence the need to keep up with trail. To successfully keep up with trail, the tools used must be up-to-date to get the highest accuracy in the trail business. Secondly, tracking a stolen property like vehicles has been made easy with the GPS. For example, in most cases, the success of tracing stolen vehicle and the criminals will depend on the installed criminal tracking device, since the police and other criminal authorities are able to obtain crucial links to the criminals, with the ability to recover the stolen property (Colin, 2005).

Technological Trend

Wireless Communication

Over the past decade, there has been unprecedented rise in use of wireless communication, and still it is expected to continue growing in a more explosive manner, considering the continuous demand (Arslan & Yarkan, 2009). Arslan & Yarkan (2009) state that the most important feature of the adaptive radio and the cognitive radio concept is its “ability to measure, sense, learn about, and be aware of parameters related to the radio channel characteristics, availability of spectrum and power, interference and noise temperature, operational environment of radio, user requirements and applications, available networks and infrastructures, local policies, and other operating restrictions” (par.1).

The current generations of mobile radio systems aims to provide higher rates of data together with a wide application of ranges of data like video, data and positioning to the user while at the same time providing a wide range of customers as much as it can. These services are particularly crucial to the tracking companies, law enforcers and security agents who would need any detailed information about a criminal for tracking purposes against all odds. However, the constant challenge for achieving this noble goal has been the limited available resources such as spectrum and power and the underutilization of the radio spectrum (Arslan & Yarkan, 2009). Considering the fact that spectrum costs are high, the systems are expected to provide the highest performance capacity through a better exploitation of resources at disposal (Arslan & Yarkan, 2009). It is their reliability and efficiency that adaptive and cognitive radios have become so popular with the security agencies that it is considered the ultimate choice in the tracking of criminal offenders. Traditional designers are now resorting to the integrating the technology with mobile phones to increase the efficiency and reliability (Arslan & Yarkan, 2009).

Wireless radio communication systems entail the process of information being transmitted to the receiver through a radio propagation environment (Arslan & Yarkan, 2009). Once the signals are transmitted, they are reflected, refracted and subsequently scattered to an extent that by the time it arrives at the receiver, it followed multiple paths coupled with delays at different amplitude and phases (Arslan & Yarkan, 2009). The many paths followed automatically affect the signals, i.e. corrupting the signals and subsequently limiting the communication efficiency by interfering with the system performance (Arslan & Yarkan, 2009). Furthermore, this transmission is dependent on the symbol duration or bandwidth together with environmental condition where the communication process occurs. Again when the relative delays are small as compared to the period of symbol transmission, different images of the same symbol may arrive at ago, either creating destructive or constructive impact on the quality of message (Arslan & Yarkan, 2009). Arslan & Yarkan (2009) state, “the overall effect is a random fading channel response”, adding that “whenever the relative path delays are on the order of symbol period or more, then the images of different symbols arrive at the same time causing intersymbol interference” (par.6).

Wireless radio systems dependence on the transmitter, receiver, and scattering objects within the propagating environment is considered a challenge for security agencies. This is because the receiver and the transmitter are both mobile, hence can cause rapid change in response to the environmental change thus leading to spectral broadening (Arslan & Yarkan, 2009). That is, as the transmission bandwidth increases, the relative broadening of the channel within the transmission of symbol will be negligible because wider transmission bandwidths mean shorter duration (Arslan & Yarkan, 2009).

Even though the dimensions of time, frequency, and angle are well known and understood it is possible that there are other dimensions that could be considered as part of channel selectivity e.g. polarization, power, interference, and coding, which are actually part of the signal space rather than being real channel space (Arslan & Yarkan, 2009). However, researchers need to consider these probable aspects even though the possible dimensions may not be directly linked to the wireless communication.

New HD Standard for Network Cameras

To effectively manage businesses, the invention of new HD standard for network cameras has been hailed as the masterpiece for monitoring consumer market. This is because the device is considered to improve resolution in clearer and sharper images in the process of tracking moving objects (Nilsson, 2009). Nilsson (2009) states that “while some may argue that megapixel network cameras are already providing this level of clarity; the high resolution often comes at the expense of frame rate because bandwidth requirements are so high” (p.64). Thus the most recent network cameras that have been identified to comply with the specifications of HDTV tend to guarantee many aspect of picture quality like higher resolution, frame rate, color fidelity, and ensuring the transmission of quality video with the help of the most recent standard compression technologies (Nilsson, 2009).

Initially, establishment of a frame rate generated much debate because the stability of the electrical supply affected the stability of the images, thereby making some countries to prefer either 25/50 fps while some preferred 30/60fps (Nilsson, 2009). It is however known that both rates are in accordance to the HDTV standards as well as meeting the full requirement of the frame rate of the video surveillance (Nilsson, 2009). This is better than the non-HDTV compliant megapixel cameras which have limited frame rates of only between 10 and 20 fps (Nilsson, 2009).

This new HDTV enabled camera has the ability to give true color and images of objects no matter the speed of the object, hence making the gadget more viable for surveillance operations that require more detailed images (Nilsson, 2009). This is why it is highly demanded by the retail stores, airports, immigration stations where passports are controlled, casinos as well as highways (Nilson, 2009).

Electronic Supervision of Offenders

In the United States, various technological devices have been produced to assist the law enforcement officers with the supervision of offenders in the community. Electronic supervision of offenders has expanded significantly in the last decade, leading to the emergence a variety of tools (DeMichele & Payne, 2009). Many agencies now have the option of adopting kiosk reporting, more secure remote alcohol detection, GPS, voice verification, and currently in the UK, there is a major push for closed-circuit television systems that can be integrated with facial recognition software to locate suspected individuals (DeMichele & Payne, 2009). According to National Institute of Justice supports the National Law Enforcement and Corrections Technology Center, within the electronic supervision, the possibility of this form of technology can be said to be limitless since radio frequency identification chips design are in a way that they can easily fit just under the skin as well as similarly read as a bar code at the grocery stores (DeMichele & Payne, 2009).

However, there has been an equally emerging concern over the application of these electronic supervision technologies. DeMichele & Payne (2009) observe that even though electronic supervision tools have the ability to bring changes in the community supervision, there should be more critical look at the impact of these technologies in line with their fitness to the needs of the field: they have the possibility of enhancing community supervision as well as breaking it. That is, they can breakdown leading to failure in reporting the violations, increase tracking officers’ stress and burnout, and may even lead to other more potential negative impacts on the society (DeMichele & Payne, 2009).

DeMichele & Payne (2009) further highlight that before this technology is implemented, a lot of consideration should be in place to check on the effect it would have on the everyday job of the tracking officer, arguing that effective community correction is built through human relationships; hence ethical issues should be keenly looked at.

Nanotechnology for tracking copper wire theft

The incidences of copper wire theft have caused a great damage to many power companies as well as general power failure in many regions in the United States. For example, in one major incidence, copper wire theft led to a failure of 138-kv switch and the destruction of a transformer control department, prompting the owner company, Oncor to invest close to $200,000 to get back the facility in Dallas (Jackson, 2009).

To curb this problem, Oncor has employed a variety of strategies like forming copper theft task force, burying the copper wires deeper on the ground and replacing the wires with some more hard-to-cut wires like the copper-coated steel ground wire (Jackson, 2009). However, these are protective measure which may not help with getting back what have been stolen or arresting offenders. The company has therefore supplied the task force with digital cameras to capture photos of wire thieves and track that may have been stolen from Oncor substations (Jackson, 2009).

However, the most eye-catching technology that Oncor has resorted to is the nanotechnology. This technology can be used by tracking officers and law enforcers to track anything from stolen car to stolen copper wiring. To use this technology, Oncor sprays microscopic dots on copper wiring and equipment, where each dot has utility stores of up to 28 alpha-numeric characters (Jackson, 2009). Even though the information generated on the dots may not be visible to the naked eye, it can be read and interpreted by the use of magnifying glass and a black light, thus enables the company security team and police officers to identify exactly where the copper originated, and the scrap yard dealers can pinpoint the actual person selling the wire (Jackson, 2009).

Thermal imaging, wiretaps and binoculars

The Thermal Imaging Forward-looking infrared devices (FLIRs) are usually mounted under aircraft in gimbaled housings and are used to detect heat sources, being commonly applied in the night time high-speed pursuits (DeMichele & Payne, 2009). Police have used this device when they suspect that marijuana is being grown inside a home, business, or other structure (DeMichele & Payne, 2009). Even though this technology’s use is restricted since its lacking in the public view to investigate a private home, previously unfamiliar without physical intrusion, considering that such a surveillance would be a Fourth Amendment “search” and therefore presumably unjustified with no warrant (Groot, 2009).

Binoculars and telescopes can function as either enhancement or acquisition devices, depending on their proximity to the target (DeMichele & Payne, 2009). For instance if they are used merely to enlarge or clarify something visible to the naked eye, they would be treated as enhancements.

Wire taps is another technology that has been used to get information when tracking a criminal offender or tracing a stolen property. It involves intercepting telephone conversations or the content of other electronic messages like emails to get trails of the offender, if she or he is communicating through any of these channels (Lukovsky, Long, Chung, & Seo, 2009).

Cell phone as a tracking device

A cell phone is a sophisticated two-way radio with a low power-transmitter that operates on a network of cell sites (Groot, 2009). “Cell” is the geographical region often illustrated as hexagons, resembling a bee’s honey comb; while a “cell site” is where the radio transceiver and base station controller are located (Groot, 2009). The cell phones communicate with the base stations and vice versa through a type of frequencies known as channel, and the two frequencies are paired to give channels, “one for transmitting while another for receiving” (Groot, 2009).

When a cell phone is switched on, it scans through the control channels list, i.e. “acting as a scanning radio that searches through a list of control channels for the strongest signal” (Bangert, 2009, p.16). After every seven seconds, the cell phone does the re-scanning when or if it detects that the strength of the signal has weakened, and whether a call is placed or not, it searches for a five-digit number known as the system identification code of the service providers (Bangert, 2009). Upon selection of a channel, the cell phone will identify itself through remittance of programmed codes, which consequently identify the cell phone, its owner, and the service provider (Groot, 2009). The indicated codes are composed of a 10-digit electronic serial number, derived from the phone’s number (Groot, 2009).

Today, the government may seek a court order that compels a cell phone company to disclose records of a customer’s cell phone usage data (Bangert, 2009). Such records include “cell site data” that is able to reveal the user’s physical location while the phone is turned on (Groot, 2009; Bangert, 2009).

While it is known that the idea of cell phone did not originally come as a tracking device, law enforcers converted it to criminal tracking device (Groot, 2009). In this usage, the process is usually unknown to the phone user and has been proved more effective in the tracking of the criminals who may not be otherwise traced by the use of other devices like wiretap surveillance (Bangert, 2009).

Electronic Monitoring

Electronic monitoring of offenders has been billed to be one of the most effective ways of keeping the criminal offenders in check. Criminal offenders who are being monitored wear devices that are able to send signals to a control office; the devices are placed on the offender’s ankles, wrists, or neck (Arslan & Yarkan, 2009). In this case two basic types of systems are always used: active and passive systems; active systems will constantly monitor offenders by continuously sending a signal to the central office (Arslan & Yarkan, 2009). In any case the offenders leave their homes at an unauthorized time, the signal is broken and the failure is consequently recorded (Arslan & Yarkan, 2009). In some other cases, the control officer is automatically notified electronically through a beeper (Arslan & Yarkan, 2009; Bangert, 2009).

However, electronic monitoring systems are now being developed by private industry. For instance, Omnilink System of Alpharetta, Georgia, has developed an EM system that employs a cellular technology to locate a tracking device even when it is indoors (Bangert, 2009). In addition, wireless tracking device is used to alert the potential victims when a monitored offender is in victim’s vicinity in violation of court restraint, thus can be done by linking the wireless device to the victim’s cell phone; if the offender comes close within a certain distance of the cell phone, the victim is notified via a phone and can seek safety until police arrive (Bangert, 2009).

Global Positioning System

Global positioning system (GPS) technology has emerged as a very important aspect in the tracking of criminals. Well over 20 states in the United States are currently tracking criminals on probations with GPS technology (Groot, 2009). In this arrangement, criminals who are released from jail and put on probation are monitored by the use of a GPS tracking device that is fixed around the ankle bracelet, thus allowing the criminal offenders to be tracked 24hours to ensure that the rules set down for the probation period are followed to the latter (Groot, 2009). It is estimated that the number of criminal offenders being traced in the whole of United States has increased spontaneously over the years (Bangert, 2009). The rationale behind this program comes in when these criminals, who are considered the least violent offenders and ones with very short prison terms who would be the first to be released in case the prison budget is cut (Groot, 2009). In addition, the devices have been used to track juvenile offenders, to ensure that they continue going to school as well as work (Groot, 2009). The operators are also able to program the devices to inform the police if the offender is not in the right place at the right time. For instance, the GPS tracking device would alert the authorities if the student was not in the precinct of the school, say at 10.00 on Tuesday, automatically go off if the offender is not at work at 4.00 and later show in the evening if the offender is actually at home (Groot, 2009). At the same time, the probation officers are also able to guide and keep the juveniles away from interaction with the gangs, who are likely to lead them to further criminal activities (Bangert, 2009).

The working of the device is in two ways: first, they allow the police to continue to keep track of offender once they have served and completed their jail terms, thereby adding some measure of protection that ensures they don’t commit another crime Secondly, basic types of system are used; active and passive (Bangert, 2009). These devices have normally proved crucial in the monitoring of the domestic violence cases, where victims may not find it safe to stay in their own homes and instead flee to other shelters (Bangert, 2009; Groot, 2009).

However, this device has some limitations that have jeopardized its success. Since it is a line-of-sight-based system, it requires that transmitters are set up with proper angles that would give readings back from each of the sensors, hence limits some of the abilities to go inside of areas with just pure sensors in sight of the transmitters (Bangert, 2009). Again, it offers much lower accuracy in small volume with limited transmitters (Bangert, 2009).

Merits of Electronic monitoring

Technological advancements in electronic monitoring has the benefits of relatively low cost and high security, while at the same time helping the offenders avoid the pains of imprisonment in overcrowded, dangerous state facilities (Groot, 2009). Electronic monitoring is capital intensive rather than labor intensive, since offenders are monitored by computer, an initial investment in hardware rules out the need for hiring many more supervisory officers to handle large numbers of clients (Bangert, 2009).

Electronic Monitoring have shown some signs effectiveness when added to the galaxy of the intermediate sanctions, thereby providing the judiciary with an enhanced supervision tool (DeMichele & Payne, 2009). Again, it can be used as part of a pretrial diversionary program to enhance probation or as a post-incarceration security measures as study has shown that the offenders prefer electronic monitoring to incarceration (DeMichele & Payne, 2009). Such a program has been found to save money and save the users the cost of constructions costs without widening the net of social control (Bangert, 2009).

Electronic Monitoring Evaluation: Legal perspective

The evaluation of the effectiveness of the Electronic Monitoring programs to reduce recidivism has however yielded mixed results in the past. Some evaluation results indicate that offenders monitored on EM misunderstood its purpose and as likely to recidivate as those released without such supervision (Bangert, 2009). However, other evaluations have received much better results: in one of such extensive study, Kathy Padgett evaluated data on more than 75,000 offenders placed on home confinement in Florida from 1998 to 2002, and the findings indicated that EM significantly reduced the likelihood of technical violation, re-offending and absconding (Bangert, 2009). Probationers who have been placed on home confinement with electronic monitoring had been previously involved in significantly more serious crimes than those placed on home confinement without Electronic Monitoring, indicating that the procedure is being used with the appropriate offender population- that is, the most serious probation population (Bangert, 2009; DeMichele & Payne, 2009). It is therefore indicating that there was little “net widening” produced by the Electronic Monitoring program (Groot, 2009, p.5).

An administrative search is a routine search or inspections of homes or businesses to determine the compliance with codes and licensing provisions that deals with fire, safety, housing, etc. even though administrative searches are not yet directed toward convicting a person of a crime, that they still subject to the warrant requirement of Fourth Amendment (DeMichele & Payne, 2009). Despite this, the probable cause standard for administrative search warrant is less stringent than the standard for criminal searches (Arslan & Yarkan, 2009). However, if an administrative search takes on the characteristic of a criminal search, the traditional probable cause standard applies (Arslan & Yarkan, 2009). Exceptions to the administrative search warrant requirement are similar to the exceptions for a criminal search warrant with less stringent standards, and still, warrantless searches are allowed for certain licensed as well as closely regulated enterprises (Arslan & Yarkan, 2009).

An exception to the warrant and probable cause requirements of the Fourth Amendment exist where “special needs” of government, beyond the normal need for law enforcement, make the warrant and probable cause requirements impracticable (DeMichele & Payne, 2009). Under this arrangement, the “special needs” searches are evaluated under the reasonableness standards under the Fourth Amendments (p.6). In this aspect, some special needs searches may be lawful without a warrant by adequately showing the level of suspicion. Other special needs searches justify warrantless, suspicion-less searches in light of the important governmental needs at stake when balanced against the intrusiveness of search upon a person’s reasonable expectation of privacy (DeMichele & Payne, 2009).

Conclusion

Criminal tracking devices are working on the principle of Electronic surveillance, which was originally treated beyond the coverage of the Fourth Amendment since it involved non trespass into defendant’s premises and no seizure of tangible items (DeMichele & Payne, 2009). Even though interception order is required to intercept wire, oral, or electronic communications, judicial approval is not required to covertly enter premises to install a listening (DeMichele & Payne, 2009). Neither is an interception order is required to intercept wire, oral, or electronic communications in emergencies involving immediate danger of death or serious physical injury, or conspiracies threatening national security or involvement of organized crime, although an interception order must be obtained (DeMichele & Payne, 2009).

From the analysis above, it is apparent that many of the devices used have gone through numerous changes in terms of improvement in their efficiency and reliability. On the other hand one must admit that there numerous challenges facing such devices as GPS. As stated earlier, it is a line-of-sight-based system, it requires that transmitters are set up with proper angles that would give readings back from each of the sensors, hence limits some of the abilities to go inside of areas with just pure sensors in sight of the cell (Arslan & Yarkan, 2009). Again electronic monitoring basically requires that a gadget is placed on the criminal’s body with his or her knowledge, a process that may not be possible for run away criminals.

Mobile phone tracking did not originally come as the first reason for invention of mobile phones. However, it is proving to be one of the most important gadgets for tracking criminals, justifying the reason why law enforcers have wholly embraced it as a criminal tracking device (Groot, 2009). As discussed, its usage is usually unknown to the phone user and has been proved more effective in the tracking of the criminals who may not be otherwise traced by the use of other devices like wiretap surveillance (Bangert, 2009).

However, mobile phone as a wireless communication has its limitations due to its dependence on dimensions of time, frequency, and angle in the environment of communication exchange. Again the mobility of the receiver and the transmitter has a possibility of causing rapid change in response to the environmental change thus leading to spectral broadening: the relative broadening of the channel within the transmission of symbol becomes negligible as transmission bandwidth increases (Arslan & Yarkan, 2009). These limitations are well known and understood and that there are other possibilities of other dimensions that could be considered as part of channel selectivity (Arslan & Yarkan, 2009). Such dimensions as polarization, power, interference, and coding are actually part of the signal space rather than being real channel space but rather needs to investigated further (Arslan & Yarkan, 2009). That notwithstanding, mobile phone as a tracking device has generated much more than was expected and its improvement will make it the ultimate choice for security agencies.

The other useful device for security agents and businesses is the newly upgraded HDTV enabled camera. This camera has the ability to give true color and images of objects no matter the speed of the object, hence making the gadget more viable for surveillance operations that require more detailed images (Nilson, 2009). This is why it is highly demanded by the retail stores, airports, immigration stations where passports are controlled, casinos as well as highways (Nilson, 2009).

Reference List

Arslan, H., & Yarkan S. (2009). Real-time Measurements for adaptive and cognitive radio systems. EURASIP Journal on wireless Communications and Networking, Vol.2009, Art. ID 202909, doi:10.1155/2009/202909. Web.

Bangert, M. (2009). GPS Success. Web.

Colin, T. (2000). The information E-conomy: Business strategies for competing in the digital age. London: N.H. Kogan. Web.

DeMichele, M., & Payne B. (2009). Using Technology to monitor offenders: A community corrections perspective. Web.

Groot, N. (2009). Tracking devices and Survaillance Investigation Cdn-PI-Law.com, 901-6021 Yonge Street, Toronto, ON M2M 3W2 (416)-916-8379.

Jackson, E. (2009). Deterring copper thieves. L ISSN: 1087-0849, p.64. Web.

Lukovsky, G., Long J.P., Chung K-B., & Seo H. (2009). Atomically- Engineered interface between cristaline and non-crystalline. e-Journal of Surface Science and Nanotechnology, Vol. 7, No. 0, pp.381-388. Web.

Nilsson, F. 2009. The new HD standard for network cameras. LexisNexis Academics. Vol. 31 No. 9, p. 64. Web.

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