won a legal victory on the shoulders of the Sony Corp. v. Universal City Studios case and DAPs were legally ruled as electronic devices. Risk of hearing damage According to the Scientific Committee on Emerging and Newly Identified Health Risks, the risk of hearing damage from digital audio players depends on both sound level and listening time. The listening habits of most users are unlikely to cause hearing loss, but some people are putting their hearing at risk, because they set the volume control very high or listen to music at high levels for many hours per day. Such listening habits may result in temporary or permanent hearing loss, tinnitus, and difficulties understanding speech in noisy environments. The World Health Organization warns that increasing use of headphones and earphones puts 1.1 billion teenagers and young adults at risk of hearing loss due to unsafe use of personal audio devices. Many smartphones and personal media players are sold with earphones that do a poor job of blocking ambient noise, leading some users to turn up the volume to the maximum level to drown out street noise. People listening to their media players on crowded commutes sometimes play music at high volumes feel a sense of separation, freedom and escape from their surroundings. The World Health Organization recommends that "the highest permissible level of noise exposure in the workplace is 85 dB up to a maximum of eight hours per day" and time in "nightclubs, bars and sporting events" should be limited because they can expose patrons to noise levels of 100 dB. The report states The report also recommends that governments raise awareness of hearing loss, and to recommend people visit a hearing specialist if they experience symptoms of hearing loss, which include pain, ringing or buzzing in the ears. A study by the National Institute for Occupational Safety & Health found that employees at bars, nightclubs or other music venues were exposed to noise levels above the internationally recommended limits of 82–85 dB(A per eight hours. This growing phenomena has led to the coining of the term music-induced hearing loss, which includes hearing loss as a result of overexposure to music on personal media players. FCC issues Some MP3 players have electromagnet transmitters, as well as receivers. Many MP3 players have built-in FM radios, but FM transmitters aren't usually built-in due to liability of transmitter feedback from simultaneous transmission and