Re: Software vs Firmware @BILLG
More and more equipment does not have "firmware" loaded into the device by the manufacturer. It's loaded onto the device at boot. From the hard disk. (Or SSD. Perhaps that makes it firmware?)
I would say a phone os is no different to a pc os. "Software". Where it's stored and how difficult it is to get at to modify or replace is another matter.
"Firmware" used to mean software loaded into rom on the device to make the hardware work. Software which survived shutdown. Like the bios. Then you had os specific device drivers to talk to the os and the device interface. Things are getting more and more blured these days.
The FCC are a goverment organisation with less and less technical understanding. (Although they probably have lots of extremely good engineers working for them. But hey, we're the FCC what do those guys know,eh?