2AX2URN941RRN941R

Federal Communications Commission 7435 Oakland Mills Road Columbia MD 21046 Date: March 16, 2026 Subject: Certifications concerning “covered” equipment pursuant to Part 2.911(d)(5)(i) and (ii) FCC ID: 2AX2URN941R FCC ID: 2AX2URN941W To whom it may concern, Rolling Wireless S.a r.l. certifies that the equipment for which authorization is sought is not the equipment on the Covered List, as established pursuant to § 1.50002 of CFR Title 47, that is prohibited from obtaining an equipment authorization under this subpart. This includes equipment that: (1) Has been certified as a modular transmitter; or (2) Meets the modular transmitter requirements of § 15.212 of this chapter and could be certified as a modular transmitter. pursuant to section 2.903 resulting the recent adoption of FCC 25-71 (et al., ET Docket No. 21-232, Second Report and Order); or (3) Uncrewed aircraft systems (UAS) and UAS critical components produced in a foreign country and all communications and video surveillance equipment and services listed in Section 1709(a)(1) of the FY25 National Defense Authorization Act (Pub. L. 118-159) Rolling Wireless S.a r.l. certifies that, as of the date of the filing of the application, the applicant [is not] identified on the Covered List (as a specifically named entity or any of its subsidiaries or affiliates) as an entity producing “covered” equipment. Rolling Wireless S.a r.l. further certifies that no Cybersecurity or anti-virus software produced or provided by Kaspersky Lab, Inc. or any of its successors and assignees, including equipment with integrated Kaspersky Lab, Inc. (or any of its successors and assignees) cybersecurity or anti-virus software is installed in the equipment being certified. The above-referenced Covered List is published by the Public Safety and Homeland Security Bureau (PSHSB), pursuant to Section 1.50002 of the Commission’s rules. Name: Gene Santana E-mail: [email protected]

V02072023 Rolling Wireless S.a r.l. Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 USA Date: 06/03/2024 Ref: Attestation Statement Part 2.911(d)(7) Filing Grantee code: 2AX2U Rolling Wireless S.a r.l. certifies that, as of the dates of this application, Americas Compliance Consulting LLC dba iCertifi “iCertifi” is our designated U.S. agent for service of process for the above referenced FCC ID. Rolling Wireless S.a r.l. accepts to maintain an agent for no less than one year after the grantee has terminated all marketing and importation or the conclusion of any commission-related proceeding involving the equipment. iCertifi accepts, as of the date of the filing of the application, the obligation of the designated U.S. agent for service process for the above referenced FCC ID. Designated U.S. Agent Information: Name: Americas Compliance consulting, LLC dba iCertifi FCC FRN: 0033399411 Address: 2445 NE Division Street, Suite 202 Bend, OR 97703 United States Contact Person: Paul Preston Tel: 866-885-4575 Email: [email protected] Sincerely, Rolling Wireless S.a r.l. FRN: 0030146674 Americas Compliance Consulting LLC dba iCertifi Gene Santana Paul Preston Signature

Applicant/Grantee Rolling Wireless S.a r.l. FCC ID: 2AX2URN941R, 2AX2URN941W Section 15.212 Modular Transmitters Request for Modular Approval Request for Limited Modular Approval Requirements EUT Conditions Comply (Y/N) Single Modular Approval Requirements 1 The radio elements of the modular transmitter must have their own shielding. The physical crystal and tuning capacitors may be located external to the shielded radio elements. The radio portion of this module is shielded, please see exhibition external photos. Y 2 The modular transmitter must have buffered modulation/data inputs (if such inputs are provided) to ensure that the module will comply with Part 15 requirements under conditions of excessive data rates or over-modulation. The module has buffer modulation/data inputs. Y 3 The modular transmitter must have its own power supply regulation. The module has its own power supply regulation. Please see the schem.pdf Y 4 The modular transmitter must comply with the antenna and transmission system requirements of Sections 15.203, 15.204(b) and 15.204(c). The antenna must either be permanently attached or employ a “unique” antenna coupler (at all connections between the module and the antenna, including the cable). The “professional installation” provision of Section 15.203 is not applicable to modules but can apply to limited modular approvals under paragraph (b) of this section. The requirements of antenna connector and spurious emission have been fulfilled. Please refer to the Test Report exhibition. Y 5 The modular transmitter must be tested in a stand-alone configuration, i.e., the module must not be inside another device during testing for compliance with Part 15 requirements. Unless the transmitter module will be battery powered, it must comply with the AC line conducted requirements found in Section 15.207. AC or DC power lines and data input/output lines connected to the module must not contain ferrites, unless they will be marketed with the module (see Section 15.27(a)). The length of these lines shall be the length typical of actual use or, if that length is unknown, at least 10 centimeters to insure that there is no coupling between the case of the module and supporting Please refer to the Setup Photo exhibition for the stand-alone test configuration. Y equipment. Any accessories, peripherals, or support equipment connected to the module during testing shall be unmodified and commercially available (see Section 15.31(i)). 6 The modular transmitter must be equipped with either a permanently affixed label or must be capable of electronically displaying its FCC identification number. (A) If using a permanently affixed label, the modular transmitter must be labeled with its own FCC identification number, and, if the FCC identification number is not visible when the module is installed inside another device, then the outside of the device into which the module is installed must also display a label referring to the enclosed module. This exterior label can use wording such as the following: “Contains Transmitter Module FCC ID: XYZMODEL1” or “Contains FCC ID: XYZMODEL1.” Any similar wording that expresses the same meaning may be used. The Grantee may either provide such a label, an example of which must be included in the application for equipment authorization, or, must provide adequate instructions along with the module which explain this requirement. In the latter case, a copy of these instructions must be included in the application for equipment authorization. (B) If the modular transmitter uses an electronic display of the FCC identification number, the information must be readily accessible and visible on the modular transmitter or on the device in which it is installed. If the module is installed inside another device, then the outside of the device into which the module is installed must display a label referring to the enclosed module. This exterior label can use wording such as the following: “Contains FCC certified transmitter module(s).” Any similar wording that expresses the same meaning may be used. The user manual must include instructions on how to access the electronic display. A copy of these instructions must be included in the application for equipment authorization. The Module will be labeled with its own FCC ID, and the instruction on the labeling rule of the end product has been stated in the User Manual of this module. Please refer to the Label and User Manual exhibition. Y 7 The modular transmitter must comply with any specific rules or operating requirements that ordinarily apply to a complete transmitter and the manufacturer must provide adequate instructions along with the module to explain any such requirements. A copy of these instructions must be included in the application for equipment authorization. The required FCC rule has been fulfilled and all the instructions for maintaining compliance have been clearly stated in the User Manual. Y 8 The modular transmitter must comply with any applicable RF exposure requirements in its final configuration. Please refer exhibition RF Exposure for the compliance of MPE RF exposure rule. Y _________________________________ Name: Gene Santana E-mail: [email protected]

Rolling Wireless S.a r.l. Date: March 16, 2026 Federal Communications Commission Office of Engineering and Technology Laboratory Division 7435 Oakland Mills Rd Columbia MD 21046-1609 Subject: Request for Confidentiality FCC ID: 2AX2URN941R FCC ID: 2AX2URN941W To Whom It May Concern, Pursuant to the provisions of Sections 0.457 and 0.459 of Commission’s rules (47CFR§§0.457, 0.459), we are requesting the Commission to withhold the following attachment(s) as confidential document from public disclosure indefinitely. ⚫ Schematic Diagram ⚫ Block Diagram ⚫ Part List ⚫ Operational Description ⚫ Tune-up Procedure Above mentioned document contains detailed system and equipment description are considered as proprietary information in operation of the equipment. The public disclosure of above documents might be harmful to our company and would give competitor an unfair advantage in the market. In additional to above mentioned documents, pursuant to Public Notice DA 04-1705 of the Commission’ s policy, in order to comply with the marketing regulations in 47 CFT §2.803 and the importation rules in 47 CFR §2.1204, while ensuring that business sensitive information remains confidential until the actual marketing of newly authorized devices. We are requesting the commission to grant short-term confidentiality request on the following attachment(s) for 180 days after the grant as outlined in Public Notice DA 04-1705. ⚫ External Photos ⚫ Internal Photos ⚫ Test Setup Photos ⚫ User Manual It is our understanding that all measurement test reports, FCC ID label format and correspondent during certification review process cannot be granted as confidential documents and those information will be available for public review once the grant of equipment authorization is issued. Best Regards, ______________________ Name: Gene Santana E-mail: [email protected]

Rolling Wireless S.a r.l. Date: March 16, 2026 Power of Attorney To whom it may concern, Please be notified that I, Gene Santana, have designated Jim Tsai in Sporton International Inc. (Kunshan) as the person being responsible for this project and to sign the form 731 and other documentation. Any and all acts carried out in their professional capacity by Sporton International Inc. (Kunshan) on the matters of relating to all processes required in the FCC approval and any communication needed with the national authority, shall have the same legal authority as acts on our own behalf including the release of confidential information. We further certifies that neither the applicant nor any party to this application, as defined in 47 CFR Ch. 1.2002 (b), is subject to a denial to Federal benefits, that include FCC benefits, pursuant to section 5301 of the Anti-Drug Abuse Act of 1998, 21 U.S.C. 835(a). This authorization is limited to the product of as following: FCC ID: 2AX2URN941R FCC ID: 2AX2URN941W If you have any acknowledgement and response, please send it to Sporton International Inc. (Kunshan) directly. Should you have any questions or comments regarding this matter, please have my best attention. Sincerely yours, Name: Gene Santana E-mail: [email protected]

Model name: RN941R FCC ID: 2AX2URN941R IC: 26644-RN941R Trade name: Rolling Wireless Label located on the shield.

Sporton International Inc. (ShenZhen) Page Number : 1 of 20 TEL : +86-755-8637-9589 Report Issued Date : Mar. 25, 2026 FAX : +86-755-8637-9595 Report Version : Rev. 01 FCC ID : 2AX2URN941R Report Template No.: BU5-FC15B Version 3.0 FCC Test Report Report No. : FC5D3103 FCC Test Report APPLICANT : Rolling Wireless S.à r.l. EQUIPMENT : RN941R BRAND NAME : Rolling Wireless MODEL NAME : RN941R FCC ID : 2AX2URN941R STANDARD : 47 CFR Part 15 Subpart B CLASSIFICATION : Certification TEST DATE(S) : Jan. 11, 2026 We, Sporton International Inc. (ShenZhen), would like to declare that the tested sample has been evaluated in accordance with the test procedures given in ANSI C63.4-2014 and has been in compliance with the applicable technical standards. The test results in this report apply exclusively to the tested model / sample. Without written approval of Sporton International Inc. (ShenZhen), the test report shall not be reproduced except in full. Approved by: Fly Liang Sporton International Inc. (ShenZhen) 1/F, 2/F, Bldg 5, Shiling Industrial Zone, Xinwei Village, Xili, Nanshan, Shenzhen, 518055 People’s Republic of China Sporton International Inc. (ShenZhen) Page Number : 2 of 20 TEL : +86-755-8637-9589 Report Issued Date : Mar. 25, 2026 FAX : +86-755-8637-9595 Report Version : Rev. 01 FCC ID : 2AX2URN941R Report Template No.: BU5-FC15B Version 3.0 FCC Test Report Report No. : FC5D3103 TABLE OF CONTENTS REVISION HISTORY .......................................................................................................................................... 3 SUMMARY OF TEST RESULT ......................................................................................................................... 4 1. GENERAL DESCRIPTION .......................................................................................................................... 5 1.1. Applicant ............................................................................................................................................ 5 1.2. Manufacturer ..................................................................................................................................... 5 1.3. Product Feature of Equipment Under Test ....................................................................................... 5 1.4. Modification of EUT ........................................................................................................................... 5 1.5. Test Location ..................................................................................................................................... 6 1.6. Test Software .................................................................................................................................... 6 1.7. Applicable Standards ........................................................................................................................ 6 2. TEST CONFIGURATION OF EQUIPMENT UNDER TEST ........................................................................ 7 2.1. Test Mode ......................................................................................................................................... 7 2.2. Connection Diagram of Test System ................................................................................................ 8 2.3. Support Unit used in test configuration and system .......................................................................... 8 2.4. EUT Operation Test Setup ................................................................................................................ 9 3. TEST RESULT ........................................................................................................................................... 10 3.1. Test of AC Conducted Emission Measurement .............................................................................. 10 3.2. Test of Radiated Emission Measurement ....................................................................................... 14 4. LIST OF MEASURING EQUIPMENT ........................................................................................................ 19 5. MEASUREMENT UNCERTAINTY ............................................................................................................ 20 APPENDIX A. SETUP PHOTOGRAPHS Sporton International Inc. (ShenZhen) Page Number : 3 of 20 TEL : +86-755-8637-9589 Report Issued Date : Mar. 25, 2026 FAX : +86-755-8637-9595 Report Version : Rev. 01 FCC ID : 2AX2URN941R Report Template No.: BU5-FC15B Version 3.0 FCC Test Report Report No. : FC5D3103 REVISION HISTORY REPORT NO. VERSION DESCRIPTION ISSUED DATE FC5D3103 Rev. 01 Initial issue of report Mar. 25, 2026 Sporton International Inc. (ShenZhen) Page Number : 4 of 20 TEL : +86-755-8637-9589 Report Issued Date : Mar. 25, 2026 FAX : +86-755-8637-9595 Report Version : Rev. 01 FCC ID : 2AX2URN941R Report Template No.: BU5-FC15B Version 3.0 FCC Test Report Report No. : FC5D3103 SUMMARY OF TEST RESULT Report Section FCC Rule Description Limit Result Remark 3.1 15.107 AC Conducted Emission < 15.107 limits PASS Under limit 14.60 dB at 9.30 MHz 3.2 15.109 Radiated Emission < 15.109 limits PASS Under limit 8.61 dB at 44.55 MHz Conformity Assessment Condition: The test results (PASS/FAIL) with all measurement uncertainty excluded are presented against the regulation limits or in accordance with the requirements stipulated by the applicant/manufacturer who shall bear all the risks of non-compliance that may potentially occur if measurement uncertainty is taken into account. Please refer to each test results in the section “Measurement Uncertainty”. Disclaimer: The product specifications of the EUT presented in the test report that may affect the test assessments are declared by the manufacturer who shall take full responsibility for the authenticity. Sporton International Inc. (ShenZhen) Page Number : 5 of 20 TEL : +86-755-8637-9589 Report Issued Date : Mar. 25,…

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