2AEIVE10G-7282-2512E-Band Millimeter Wave Point to Point Equipment

Re: FCC ID: 2AEIVE10G-7282-2512 Applicant: EMClarity Pty Ltd Correspondence Reference Number: 46812 Form 731 Confirmation Number: EA585220 Date of Original E-mail: 05/29/2015 And Re: FCC ID: 2AEMLE10G-7282-2506 Applicant: EMClarity Pty Ltd Correspondence Reference Number: 46809 Form 731 Confirmation Number: EA147388 Date of Original E-mail: 05/29/2015 The following questions were posed with reference to the above applications by Mr Stan Lyles in email to David White and Richard Harris on the 29 th of May 2015. Please accept the following information in red as EMClarity’s response. 1. Explain why did you file under two different grantee codes? The two different grantID codes relate to two different versions of the product which have somewhat different designs and emission characteristics. At the time of submitting the applications it was thought that using different Grant ID’s was the correct method of making the separate applications. For more information on the differences between the two product variants please see discussion below. 2. This application should be DXX and not TNB for the Equipment Code. The beacon transmitted on the 24Ghz band (ref discussion below for explanation) could be described as DXX as it is used for radiolocation purposes, however the primary purpose of the product is as an E band high data-rate link so the TNB code is seem as most appropriate. 3. The fee will change for DXX Equipment Code. We are happy to pay the relevant and correct fees expeditiously. 4. These applications contain only test reports for 15.249 in 24-24.25 GHz band. This is an error on our part as we were advised by the test house (EMC Services) that the unintentional radiation test report was all that is required for FCC registration. The detailed report on the E band and 24GHz intentional radiation for the product has been added to the list of attachments to the application. 5. Please explain why if this device is E-band (70-76 GHz and 81-86 GHz), there is no data in the test report for this band This is an error on our part as we were advised by the test house (EMC Services) that the unintentional radiation test report was all that is required for FCC registration. The detailed report on the E band and 24GHz intentional radiation for the product has been added to the list of attachments to the application. 6. What is the function of this device in the 24-24.5 GHz band? The 24 GHz functionality allows the high gain E band antenna to be accurately and dynamically pointed. The large 4 foot eband antenna can not be practically used without active steering. With the use of the 24 GHz beacon transmitted from the remote end, the 4 foot version of the product actively steers the antenna to within 10 milli-degrees of bore site, thus allowing all the gain of the large antenna to be productively used. For a more complete description of the 2 foot and 4 foot products see discussion below. 7. Please explain why the 24-24.5 GHz signal exceeds the limit? The 24GHz transmission is very low power as discussed below. The measured field strength as documented in the test reports is below 250millivolts/metre in EMC Report 141207 section 4 . This is believed to be in accordance with the intentional emission requirements of 15.249 (a). The report shows during testing some observed emissions above the limit (ref Figures (1a, 1b, 2a and 2b). However in all cases this was ambient radiation and not associated with the product and is believed common of a free air test range. Please refer to the note on the bottom of all figures with limits exceeding the limit, and to Section 6.1 of EMC Report 141207. All ambient emissions were thoroughly investigated and confirmed not associated with the equipment. The note “The signal exceeding the limit at 24Ghz is the intentional emitter” on Figures 5a, 5b, 6a and 6b is in reference to the intentional 24Ghz emission from the product exceeding the non-intentional emission limit - which is the subject of this test. However the measured level of the intentional emission as stated does not exceed the intentional emission limit of 250mV/m as documented in section 4. And all non-intentional emission as below the limit. Further Discussion on the E10G 2 foot and 4 foot products. FCC ID: 2AEMLE10G-7282-2506 FCC ID: 2AEIVE10G-7282-2512 General The two different grantID codes used in the applications relate to two different versions of the same product that have somewhat different designs and emission characteristics. At the time of submitting the applications it was thought that using different Grant ID’s was the correct method of making the separate applications. In common between the two product versions is a high data rate E band radio which operates at 5 Gbps using a 2.1 GHz channel. The two different designs associated with the grantyID codes are the 2 foot (600mm) antenna based product (FCC ID: 2AEIVE10G-7282-2506) and the 4 foot (1200mm) antenna based product (FCC ID: 2AEIVE10G-7282-2512). The Four Foot Version The 4 foot version is highly evolutionary. The antenna is mounted on a gimbal and is actively steered using motors. The need for pointing comes from the 4 foot antenna which has large gain and very small beam-width. Without an active pointing system, the 4 foot antenna is very difficult to use in practice. With the pointing system is can be used on any platform. It may even be deployed on a very flexible mast that can move violently in wind. The method of steering is monopulse. This technique uses a beacon transmitted from the remote terminal end. The monopulse technique measures the direction of the beacon with a phased array of receive antennae. The system then steers the antenna towards the beacon. The final steering accuracy is below 10milli-degree. For the 4 foot system to operate the remote end must transmit a pointing beacon. The system was designed with a highly accurate GPS stabilized clock. Therefore the exact frequency of the beacon can be set withi…

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Re: FCC ID: 2AEIVE10G-7282-2512 Applicant: EMClarity Pty Ltd Correspondence Reference Number: 46827 Form 731 Confirmation Number: EA585220 Date of Original E-mail: 06/12/2015 Questions on 12 June 2015 The following questions were posed with reference to the above applications by Mr Stan Lyles in email to David White and Richard Harris on the 12 th of June 2015. Please accept the following information in red as EMClarity’s response. 1) Submit Test Setup Photos in the exhibit. As requested a new exhibit has been uploaded with specifically the Test setup Photos. 2) Submit a block diagram in the exhibit. As requested a new exhibit has been uploaded with specifically the Block Diagrams. 3) You have requested Short-term and Long-term confidentiality and your letter is not clear. Your Exhibits shows Schematics, User’s Manual, Internal Photos, Parts List, and Operational Description are request for Long-term confidentiality. Please clarify. The attachment below 726920 D01 Confidentiality Request Procedures v01r01 provides guidance for requesting information be held confidential. See KDB publication number 726920 for Confidentiality; Sections 0.457 and 0.459; Long-Term Confidentiality; Short- Term Confidentiality. 726920 D01 Confidentiality Request Procedures v01r01 In order to clarify the confidentiality requirement, an updated letter of confidentiality has been uploaded which supersedes the previous letter. Within this letter a detailed list of the exhibits requiring confidentiality have been included. 4) Per 2.1033(b) (7) the actual FCC ID alphanumeric characters need to be shown as it Re: FCC ID: 2AEMLE10G-7282-2506 Applicant: EMClarity Pty Ltd Correspondence Reference Number: 46830 Form 731 Confirmation Number: EA147388 Date of Original E-mail: 06/12/2015 will appear on the label; "FCC ID: ######" is not acceptable. A new exhibit has been uploaded which contains updated photo’s with the above FCC numbers. 5) The test report needs to spell out compliance with Sections 15.207, 15.31(e), 15.215(c). An updated test report has been uploaded. Specifically: 15.207 The product has been tested as a DC powered unit, and was tested with a battery as supplied for testing. A mains powered DC power supply is not to be supplied with the product and if a mains powered DC power supply was to be used with the product, it would be sourced separately in the USA as an FCC Part 15 compliant power supply. Any necessary conducted emissions compliance testing will then be performed. 15.31(e), 15.215(c) These requirements are addressed in section 4.3 of the updated report. Comments provided by Examiner within correspondence: As explained in November 2014 KDB response to Robert Jackson, Part 101 is verification and not certification. For the Part 101 test report you submitted we will mark that as superseded, it will not be reviewed when we process the part 15 portion, and it will not be shown under the FCC ID record. FYI: Per our policy KDB publication 634817 the grant lines will list the center frequencies of the highest and lowest frequencies test channels. Understood and noted. Question on 17 June 2015 The following additional question was posed with reference to the above applications by Mr Stan Lyles in email to David White and Richard Harris on the 17 th of June 2015. Please accept the following information in red as EMClarity’s response. 1) We checked further and did not see how 15.31(m) test at 3 frequencies complies for each antenna; please explain and / or revise your test reports for both applications. Section 4.3 of the updated test report includes the information needed to clarify compliance with 15.31(m). 2) As explained in KDB publication 634817 item I) c), the grant will list the center frequency of the lowest channel tested to the center frequency of the highest channel tested. Understood and noted. The updated report documents the full range of frequencies tested. Richard Harris EMClarity

REQUEST FOR CONFIDENTIAL TREATMENT April 23, 2015 Marlene Dortch, Secretary Federal Communications Commission 445 12 th Street, SW, Room TW-A325 Washington, D.C. 20054 Attn: Mark Neumann, Chief Equipment Authorization & Compliance Branch Office of Engineering & Technology Federal Communications Commission 445 12 th Street, SW Washington, D.C. 20554 Re: EMClarity Request for Equipment Authorization Request for Confidential Treatment for E10G Equipment Authorization Dear Madam Secretary: Pursuant to Sections 0.457(d) and 0.459 of the Commission’s rules, EMClarity respectfully requests that the Commission accord both short- 1 and long-term 2 confidential treatment to and withhold from public disclosure the response and the information contained in Exhibit 1 through Exhibit 3 attached to EMClarity’s Form 731, Application for Equipment Authorization, (“Confidential Information”), filed on date shown above. As explained more fully below, information contained in these documents is commercially sensitive, confidential and proprietary information that is not otherwise made publicly available and is, therefore, exempt from disclosure under the Freedom of Information Act and the Commission’s rules. In accordance with Section 0.459(b) of the Commission’s rules, and in support of this request, EMClarity provides the following statement of the reasons for withholding this information from inspection and the relevant facts upon which this request is based, including: (1) identification of the specific information for which confidential treatment is sought; (2) a description of the circumstances giving rise to the submission; (3) explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged; (4) explanation of the degree to which the information concerns a service that is subject to competition; (5) explanation of how disclosure of the information could result in substantial competitive harm; (6) identification of any measures taken by the submitting party to prevent unauthorized disclosure; (7) identification of whether the information is available to the public and the extent of any previous disclosure of the information to third parties; (8) justification of the period during which the submitting party asserts 1 Short-term confidential treatment is sought for external photos, block diagrams, schematics, test setup photos, user manual, internal photos, parts list/tune-up, RF exposure information and operational description. EMClarity seeks short-term confidential treatment for the Confidential Information identified herein up to and including seven (7) days after Commission grant of Equipment Authorization that is being requested by EMClarity. 2 Long-term confidential treatment is sought for block diagrams, schematics, test setup photos, user manual, internal photos, parts list/tune-up, RF exposure information and operational description. that materials should not be available for public disclosure; and (9) any other information that the party seeking confidential treatment believes may be useful in assessing whether its request for confidentiality should be granted. 1. Identification of the specific information for which confidential treatment is sought. EMClarity seeks confidential treatment of certain information contained in its Form 731 and in Exhibit 1 through Exhibit 3 attached to its Form. 2. Description of the Circumstances giving rise to the submission. EMClarity is providing the Confidential Information in connection with its submission of Form 731 for equipment authorization. 3. Explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged. The information and documents for which confidential treatment is requested contain commercial, scientific and financial information that would not generally be disclosed by radio manufacturers to the public or to competitors. 4. Explanation of the degree to which the information concerns a service that is subject to competition. The radio equipment manufacturing market is highly competitive. EMClarity is a manufacturer of radio equipment with markets around the world and seeks to protect the commercial, scientific and financial information contained in its Form 731 and accompanying exhibits from its competitors. 5. Explanation of how disclosure of the information could result in substantial competitive harm. Disclosure of this sensitive commercial, scientific and financial information, which is not normally disclosed to the public, could subject EMClarity to unfair competition or cause distortion in the market by revealing proprietary, business, scientific and commercial information to EMClarity’s competitors. EMClarity’s competitors might be able to use this information developing radio equipment in competition with EMClarity without sustaining the costs incurred previously by EMClarity. 6. Identification of any measures taken by the submitting party to prevent unauthorized disclosure. EMClarity has not disclosed to the public any of the information for which confidential treatment is requested. In order to prevent unauthorized disclosure, the documents have been stamped CONFIDENTIIAL – NOT FOR PUBLIC DISCLOSURE. 7. Identification of whether the information is available to the public and the extent of any previous disclosure of the information to third parties. EMClarity has not previously disclosed information contained in these documents to the public. 8. Justification of the period during which the submitting party asserts that material should not be available for public disclosure. EMClarity requests that the information for which long-term confidential treatment is requested remain confidential indefinitely. 9. Other information that EMClarity believes may be useful in assessing whether the request for confidentiality should be granted. EMClarity is providing the Confidential Information to permit the Commission to analyze an…

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REQUEST FOR CONFIDENTIAL TREATMENT April 23, 2015 Marlene Dortch, Secretary Federal Communications Commission 445 12 th Street, SW, Room TW-A325 Washington, D.C. 20054 Attn: Mark Neumann, Chief Equipment Authorization & Compliance Branch Office of Engineering & Technology Federal Communications Commission 445 12 th Street, SW Washington, D.C. 20554 Re: EMClarity Request for Equipment Authorization Request for Confidential Treatment for E10G Equipment Authorization Dear Madam Secretary: Pursuant to Sections 0.457(d) and 0.459 of the Commission’s rules, EMClarity respectfully requests that the Commission accord both short- 1 and long-term 2 confidential treatment to and withhold from public disclosure the response and the information contained in Exhibit 1 through Exhibit 3 and Exhibit 6 through Exhibit 8 attached to EMClarity’s Form 731, Application for Equipment Authorization, (“Confidential Information”), filed on date shown above. As explained more fully below, information contained in these documents is commercially sensitive, confidential and proprietary information that is not otherwise made publicly available and is, therefore, exempt from disclosure under the Freedom of Information Act and the Commission’s rules. In accordance with Section 0.459(b) of the Commission’s rules, and in support of this request, EMClarity provides the following statement of the reasons for withholding this information from inspection and the relevant facts upon which this request is based, including: (1) identification of the specific information for which confidential treatment is sought; (2) a description of the circumstances giving rise to the submission; (3) explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged; (4) explanation of the degree to which the information concerns a service that is subject to competition; (5) explanation of how disclosure of the information could result in substantial competitive harm; (6) identification of any measures taken by the submitting party to prevent unauthorized disclosure; (7) identification of whether the information is available to the public and the extent of any previous disclosure of the information to third parties; (8) justification of the period during which the submitting party asserts 1 Short-term confidential treatment is sought for external photos, block diagrams, schematics, test setup photos, user manual, internal photos, parts list/tune-up, RF exposure information and operational description. EMClarity seeks short-term confidential treatment for the Confidential Information identified herein up to and including seven (7) days after Commission grant of Equipment Authorization that is being requested by EMClarity. 2 Long-term confidential treatment is sought for block diagrams, schematics, test setup photos, user manual, internal photos, parts list/tune-up, RF exposure information and operational description. that materials should not be available for public disclosure; and (9) any other information that the party seeking confidential treatment believes may be useful in assessing whether its request for confidentiality should be granted. 1. Identification of the specific information for which confidential treatment is sought. EMClarity seeks confidential treatment of certain information contained in its Form 731 and in Exhibit 1 through Exhibit 3 and Exhibit 6 through Exhibit 8 attached to its Form. 2. Description of the Circumstances giving rise to the submission. EMClarity is providing the Confidential Information in connection with its submission of Form 731 for equipment authorization. 3. Explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged. The information and documents for which confidential treatment is requested contain commercial, scientific and financial information that would not generally be disclosed by radio manufacturers to the public or to competitors. 4. Explanation of the degree to which the information concerns a service that is subject to competition. The radio equipment manufacturing market is highly competitive. EMClarity is a manufacturer of radio equipment with markets around the world and seeks to protect the commercial, scientific and financial information contained in its Form 731 and accompanying exhibits from its competitors. 5. Explanation of how disclosure of the information could result in substantial competitive harm. Disclosure of this sensitive commercial, scientific and financial information, which is not normally disclosed to the public, could subject EMClarity to unfair competition or cause distortion in the market by revealing proprietary, business, scientific and commercial information to EMClarity’s competitors. EMClarity’s competitors might be able to use this information developing radio equipment in competition with EMClarity without sustaining the costs incurred previously by EMClarity. 6. Identification of any measures taken by the submitting party to prevent unauthorized disclosure. EMClarity has not disclosed to the public any of the information for which confidential treatment is requested. In order to prevent unauthorized disclosure, the documents have been stamped CONFIDENTIIAL – NOT FOR PUBLIC DISCLOSURE. 7. Identification of whether the information is available to the public and the extent of any previous disclosure of the information to third parties. EMClarity has not previously disclosed information contained in these documents to the public. 8. Justification of the period during which the submitting party asserts that material should not be available for public disclosure. EMClarity requests that the information for which long-term confidential treatment is requested remain confidential indefinitely. 9. Other information that EMClarity believes may be useful in assessing whether the request for confidentiality should be granted. EMClarity is providing the…

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REQUEST FOR CONFIDENTIAL TREATMENT June 17, 2015 Marlene Dortch, Secretary Federal Communications Commission 445 12 th Street, SW, Room TW-A325 Washington, D.C. 20054 Attn: Mark Neumann, Chief Equipment Authorization & Compliance Branch Office of Engineering & Technology Federal Communications Commission 445 12 th Street, SW Washington, D.C. 20554 Re: EMClarity Request for Equipment Authorization Request for Confidential Treatment for E10G Equipment Authorization Dear Madam Secretary: Pursuant to Sections 0.457(d) and 0.459 of the Commission’s rules, and in response to FCC Questions of the 12 June 2015 requesting clarification of the confidentiality request, EMClarity respectfully requests that the Commission accord both short- 1 and long-term 2 confidential treatment to and withhold from public disclosure the response and the information contained in Exhibit 1 through Exhibit 2 and Exhibit 6 through Exhibit 9 attached to EMClarity’s Form 731, Application for Equipment Authorization, (“Confidential Information”), filed on April 23, 2015 and updated as a results of questions from the FCC received on 1 June 2015 and 15 June 2015. This correspondence supersedes previous requests for short and long term confidentiality made with respect to the application. As explained more fully below, information contained in these documents is commercially sensitive, confidential and proprietary information that is not otherwise made publicly available and is, therefore, exempt from disclosure under the Freedom of Information Act and the Commission’s rules. In accordance with Section 0.459(b) of the Commission’s rules, and in support of this request, EMClarity provides the following statement of the reasons for withholding this information from inspection and the relevant facts upon which this request is based, including: (1) identification of the specific information for which confidential treatment is sought; (2) a description of the circumstances giving rise to the submission; (3) explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged; (4) explanation of the degree 1 Short-term confidential treatment is sought for external photos, block diagrams, schematics, test setup photos, user manual, internal photos, parts list/tune-up, RF exposure information and operational description. EMClarity seeks short-term confidential treatment for the Confidential Information identified herein up to and including seven (7) days after Commission grant of Equipment Authorization that is being requested by EMClarity. 2 Long-term confidential treatment is sought for block diagrams, schematics, test setup photos, user manual, internal photos, parts list/tune-up, RF exposure information and operational description. to which the information concerns a service that is subject to competition; (5) explanation of how disclosure of the information could result in substantial competitive harm; (6) identification of any measures taken by the submitting party to prevent unauthorized disclosure; (7) identification of whether the information is available to the public and the extent of any previous disclosure of the information to third parties; (8) justification of the period during which the submitting party asserts that materials should not be available for public disclosure; and (9) any other information that the party seeking confidential treatment believes may be useful in assessing whether its request for confidentiality should be granted. 1. Identification of the specific information for which confidential treatment is sought. EMClarity seeks confidential treatment of certain information contained in its Form 731 and in Exhibit 1 through Exhibit 2 and Exhibit 6 through Exhibit 9 attached to its Form. Exhibit 1 containing an operational description including block diagrams and internal photos. Exhibit 2 containing the user manual, Exhibit 6 being internal photos, Exhibit 7 being the parts list, Exhibit 8 being the schematics, and Exhibit 9 being an Exhibit uploaded in response to June 12 questions containing the block Diagrams. 2. Description of the Circumstances giving rise to the submission. EMClarity is providing the Confidential Information in connection with its submission of Form 731 for equipment authorization. 3. Explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged. The information and documents for which confidential treatment is requested contain commercial, scientific and financial information that would not generally be disclosed by radio manufacturers to the public or to competitors. 4. Explanation of the degree to which the information concerns a service that is subject to competition. The radio equipment manufacturing market is highly competitive. EMClarity is a manufacturer of radio equipment with markets around the world and seeks to protect the commercial, scientific and financial information contained in its Form 731 and accompanying exhibits from its competitors. 5. Explanation of how disclosure of the information could result in substantial competitive harm. Disclosure of this sensitive commercial, scientific and financial information, which is not normally disclosed to the public, could subject EMClarity to unfair competition or cause distortion in the market by revealing proprietary, business, scientific and commercial information to EMClarity’s competitors. EMClarity’s competitors might be able to use this information developing radio equipment in competition with EMClarity without sustaining the costs incurred previously by EMClarity. 6. Identification of any measures taken by the submitting party to prevent unauthorized disclosure. EMClarity has not disclosed to the public any of the information for which confidential treatment is requested. In order to prevent unauthorized disclosure, the documents have been stamped CONFIDENTIIAL – NOT FOR PUBLIC DISCLOSURE. 7. Ident…

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REQUEST FOR CONFIDENTIAL TREATMENT July 3, 2015 Marlene Dortch, Secretary Federal Communications Commission 445 12 th Street, SW, Room TW-A325 Washington, D.C. 20054 Attn: Mark Neumann, Chief Equipment Authorization & Compliance Branch Office of Engineering & Technology Federal Communications Commission 445 12 th Street, SW Washington, D.C. 20554 Re: EMClarity Request for Equipment Authorization Request for Confidential Treatment for E10G Equipment Authorization Dear Madam Secretary: Pursuant to Sections 0.457(d) and 0.459 of the Commission’s rules, and in response to FCC Questions of the 12 June 2015 requesting clarification of the confidentiality request, EMClarity respectfully requests that the Commission accord both short- 1 and long-term 2 confidential treatment to and withhold from public disclosure the response and the information contained in Exhibit 1 through Exhibit 2 and Exhibit 6 through Exhibit 9 attached to EMClarity’s Form 731, Application for Equipment Authorization, (“Confidential Information”), filed on April 23, 2015 and updated as a results of questions from the FCC received on 1 June 2015 and 15 June 2015. In accordance with KDB 726920 D01, the request for long-term confidentiality treatment seeks protection once the short-term confidentiality treatment expires. This correspondence supersedes previous requests for short and long term confidentiality made with respect to the application. 1 Short-term confidential treatment is sought for external photos, block diagrams, schematics, test setup photos, user manual, internal photos, parts list/tune-up, and operational description. EMClarity seeks short-term confidential treatment for the Confidential Information identified herein up to and including one hundred and eighty (180) days after Commission grant of Equipment Authorization that is being requested by EMClarity. 2 Long-term confidential treatment is sought for block diagrams, schematics, user manual (contains proprietary information intended for purchasers and their technicians pursuant to a no…

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