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2AXBF-VLU6M32207-01Stolen vehicle recovery product

Redtail Telematics Limited
Stolen vehicle recovery product - FCC ID 2AXBF-VLU6M32207-01 - Redtail Telematics Limited
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Application Details

Equipment Class
TNB - Licensed Non-Broadcast Station Transmitter
Date of Grant
Dec 15, 2020
Application Purpose
Original Equipment
Date of Application
Dec 14, 2020
Equipment Note
Stolen vehicle recovery product
Frequency Range
173.07500000 - 173.07500000
Company
Redtail Telematics Limited
Country
United Kingdom

Documents & Files

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Cover Letter(s)

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External Photos

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ID Label/Location Info

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Internal Photos

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RF Exposure Info

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Test Report

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Test Setup Photos

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Document Text

Text extracted from the exhibit documents filed with the FCC. Open a document above to read the original.

Cover Letter(s)

Our ref: RLLC0048v2 Date : 2.11.2020 Authority to Act as Agent To Whom It May Concern: RN Electronics Limited is authorized to act on our behalf, until otherwise notified, for applications to American Certification Body, Inc. (ACB). We certify that we are not subject to denial of federal benefits, that includes FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 862. Further, no party, as defined in 47 CFR 1.2002 (b), to the application is subject to denial of federal benefits, that includes FCC benefits. We also declare that the information provided to the FCC is true and correct to the best of our knowledge (47 CFR 2.911(d)) and we have been informed of the grantee responsibilities (47 CFR 2.909) with regard to certified equipment. Thank you, Agency Agreement Expiration Date:31 May 2021 By: P J Sanders Title:Development Manager On behalf of:Redtail Telematics Limited Telephone:+44 1799 588588 American Certification Body, Inc. 6731 Whittier Avenue Suite C110 McLean, VA 22101 [Enter Recipient’s Address]

Cover Letter(s)

THIS MUST BE SIGNED BY THE APPLICANT/AGENT AND SHOULD BE PLACED ON APPROPRIATE LETTERHEAD Request for Confidentiality Date: 27 August 2020 Subject: Confidentiality Request for: 2AXBF-VLU6M32207-01 Pursuant to FCC 47 CFR 0.457(d) and 0.459 and IC RSP-100, Section 12.4, the applicant requests that a part of the subject FCC application be held confidential. Type of Confidentiality Requested Exhibit ☐ Short Term☒ Permanent Block Diagrams ☐ Short Term External Photos ☐ Short Term☐ Permanent * 1 Internal Photos ☐ Short Term☒ Permanent Operation Description/Theory of Operation ☐ Short Term☒ Permanent Parts List & Placement/BOM ☐ Short Term☒ Permanent Tune-Up Procedure ☐ Short Term☒ Permanent Schematics ☐ Short Term Test Setup Photos ☐ Short Term☒ Permanent * 3 User’s Manual Redtail Telematics Limited has spent substantial effort in developing this product and it is one of the first of its kind in industry. Having the subject information easily available to "competition" would negate the advantage they have achieved by developing this product. Not protecting the details of the design will result in financial hardship. Permanent Confidentiality: The applicant requests the exhibits listed above as permanently confidential be permanently withheld from public review due to materials that contain trade secrets and proprietary information not customarily released to the public. Short-Term Confidentiality: The applicant requests the exhibits selected above as short term confidential be withheld from public view for a period of ___(specify number of days not to exceed 180) 2 ___ days from the date of the Grant of Equipment Authorization and prior to marketing. This is to avoid premature release of sensitive information prior to marketing or release of the product to the public. Applicant is also aware that they are responsible to notify ACB in the event information regarding the product or the product is made available to the public before the requested period has expired. ACB will then release the documents listed above for public disclosure pursuant to FCC Public Notice DA 04-1705. NOTE for Industry Canada Applications: IC currently only distinguishes Permanent Confidentiality exhibits as shown above. Short Term confidentiality is not considered applicable to IC applications. Sincerely, By: P J Sanders (Signature/Title 3 ) (Print name) 1 - The asterisked items (*) require further information to be provided to ACB before permanent confidentiality will be extended to these exhibits. Please refer to FCC KDB 726920 and the specific Document link for D01 found at: https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?switch=P&id=41731 and review section II, 3) regarding specific information that must accompany these requests. 2 - Please refer to http://acbcert.com/documents/misc-docs/Memo-Short-Term-Vs-Standard-Confidentiality.pdf for complete details. 3 - Must be signed by applicant contact given for applicant on the FCC site, or by the authorized agent if an appropriate authorized agent letter has been provided. Letters should be placed on appropriate letterhead.

Cover Letter(s)

RLLC0051v1 Page 1 of 3 MUTUAL CONFIDENTIALITY AGREEMENT THIS AGREEMENT is made on the XX day of XXX 20XX ("Effective Date") BETWEEN: (1)Redtail Telematics Limited a company incorporated in England and registered under number 7407204 whose registered address is at Plextek Building, London Road, Great Chesterford, Essex, CB10 1NY, and (2)XXX, a company incorporated in XXX, whose registered office is at XXX. The parties wish to hold discussions about XXX. Each party is willing to disclose certain confidential information on the terms of this Agreement. OPERATIVE PROVISIONS 1.Definitions and Interpretation 1.1In this Agreement the following words and expressions have the following meanings: (a)"Affiliate" means with respect to a company or person, any other company or person that directly or indirectly, controls, is controlled by or is under common control with such company or person; "control", and with correlative meanings, "controlled by" and "under common control with", shall mean: (a) the possession, directly or indirectly, of the power to direct the management or policies of a company or person, whether through the ownership of voting securities, by contract or otherwise; or (b) the ownership, directly or indirectly, of at least fifty percent of the outstanding voting securities or other ownership interest of a company or person; and, in addition, the following entities shall also be deemed to be Affiliates of Redtail Telematics Ltd: "Confidential Information" means all information of a confidential or proprietary nature which is obtained directly or indirectly by one party (the "Receiving Party") or its Affiliates, from the other party (the "Disclosing Party") or its Affiliates at any time before, on, or after the Effective Date, without regard to the form or manner in which such information is disclosed or obtained (including information disclosed orally or in documentary or electronic form or by way of model, or obtained by observation), and in addition shall include : the fact that the discussions between the parties are taking place and the existence and terms of this Agreement and any information that would be regarded as confidential by a reasonable business person relating to: (i)the business, affairs, customers, clients, suppliers, plans intentions, or market opportunities of the Disclosing Party or of the Disclosing Party's Affiliates; and (ii)the operations, processes, product information, know-how, designs, trade secrets or software of the Disclosing Party or of the Disclosing Party's Affiliates; (iii)any information or analysis derived from Confidential Information. (c)"Permitted Purpose" means evaluation of the Confidential Information in order to decide whether to enter into a further agreement with the Disclosing Party or its Affiliates; and (d)"Representatives" means the directors, officers, employees, contractors and advisors of the Receiving Party and of the Receiving Party's Affiliates. 1.2In this Agreement: (a)references to persons include all forms of legal entity including an individual, company, body corporate, unincorporated association and partnership; (b)the word "including" is to be construed as being by way of illustration only and is not to be construed so as to limit the generality of any preceding words; and (c)headings are used for convenience only and do not affect its interpretation. 2.Confidentiality Obligations 2.1Each Receiving Party shall: (a)keep the Confidential Information of the Disclosing Party secret and confidential and take all proper and reasonable measures to ensure the confidentiality of the same, including applying the same degree of care to such Confidential Information as the Receiving Party applies to its own confidential information; (b)not disclose nor permit the disclosure of any Confidential Information of the Disclosing Party, in whole, in part, or in summary, to any person, except as expressly permitted by this Agreement; (c)not reverse engineer, disassemble or decompile any products, prototypes, software or other tangible objects that embody Confidential Information of the Discloser and that are provided to the Receiving Party hereunder; (d)not use the Confidential Information of the Disclosing Party, nor permit it to be used, for any purpose other than the Permitted Purpose; and (e)inform the Disclosing Party immediately if it becomes aware of the possession or use of any of the Confidential Information of the Disclosing Party by an unauthorised person, and provide any assistance in relation to such possession or use that the Disclosing Party may require. 3.Exceptions to Confidentiality Obligations 3.1The Receiving Party's obligations under this Agreement shall not apply to any Confidential Information of the Disclosing Party that the Receiving Party can prove by means of reasonable written evidence: (a)was known to the Receiving Party or its Affiliates on a non-confidential basis prior to disclosure by the Disclosing Party or its Affiliates; or Page 2 of 3 RLLC0051v1 (b)is or becomes publicly known other than as a result of breach of this Agreement by the Receiving Party or by anyone to whom the Receiving Party or its Affiliates disclosed the Confidential Information of the Disclosing Party; or (c)is received by the Receiving Party or its Affiliates without restriction on disclosure or use from a third party lawfully entitled to make the disclosure without such restrictions; or (d)is developed by any of the Receiving Party's Representatives who have not had any direct or indirect access to, or use or knowledge of, the Confidential Information of the Disclosing Party; except that the above exceptions do not extend to circumstances where the Confidential Information of the Disclosing Party is (i) specific, does not fall within the above exceptions, and is embraced by more general information which does fall within the above exceptions or (ii) a combination of information in the public domain separated across multiple sources.…

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Cover Letter(s)

Our ref: RLCO0007v1 Date : 26.11.2020 To Whom It May Concern Regarding certification of our product VLU6M3, FCC ID: 2AXBF-VLU6M32207-01. We are requesting Long Term Confidentiality to be applied to the User Manual (document ref. RLTN0205), on the grounds that it contains proprietary technical information which, if made available for public viewing, could compromise the integrity of the product and its commercial success. The User Manual is intended for professional installation technicians, obligated under a NDA to keep the information secure. An example of our NDA has been submitted along with the certification application. This NDA would be used when setting up agreements with installation partners, to ensure that such proprietary technical information is kept confidential. Yours sincerely Peter Sanders American Certification Body, Inc. 6731 Whittier Avenue Suite C110 McLean, VA 22101

External Photos

Redtail Telematics Ltd Plextek Building London Road Great Chesterford Essex CB10 1NY UK T: +44 (0)1799 533200 W: www.redtailtelematics.com COMPANY CONFIDENTIAL Technical Note Subject:VLU6M3 - External Photos (FCC Item 14) From:Peter Sanders To:ACBcc:RN Electronics Ltd Date:3.11.2020Document ref:RLTN0208v2 1INTRODUCTION This document addresses Item 14 of the “Required Exhibits for FCC Certification (FCC Rule Section 2.1033(b)”. Specifically, external photographs of the VLU6M3 stolen vehicle recovery device. 2VLU6M3 - EXTERNAL PHOTOS RLTN0208v23.11.2020Page 2 of 2 COMPANY CONFIDENTIAL

ID Label/Location Info

Redtail Telematics Ltd Plextek Building London Road Great Chesterford Essex CB10 1NY UK T: +44 (0)1799 533200 W: www.redtailtelematics.com COMPANY CONFIDENTIAL Technical Note Subject:VLU6M3 - Label Artwork and Location (FCC Items 7 & 8) From:Peter Sanders To:ACBcc:RN Electronics Ltd Date:3.11.2020Document ref:RLTN0223v2 1PURPOSE This document addresses the request for technical information in support of FCC certification of VLU6M3, part number 4901-2207-01. “Required Exhibits for FCC Certification (FCC Rule Section 2.1033(b))” Specifically: Item 7 – FCC ID Label Artwork Item 8 – Label Location RLTN0223v23.11.2020Page 2 of 5 COMPANY CONFIDENTIAL 2FCC ID LABEL ARTWORK (FCC RULE SECTION 2.1033(B), ITEM 7) 2.1Label Design 2.2Label Material and Printing Quality RLTN0223v23.11.2020Page 3 of 5 COMPANY CONFIDENTIAL RLTN0223v23.11.2020Page 4 of 5 COMPANY CONFIDENTIAL 3LABEL LOCATION (FCC RULE SECTION 2.1033(B), ITEM 8) 3.1Location of Product Label The FCC ID label is attached to the product enclosure at time of manufacture. An example placement is shown here: 3.2Location of FCC Statement The FCC Statement, per section 15.19(a)(3), is printed on an adhesive label attached to the product box, as shown here: RLTN0223v23.11.2020Page 5 of 5 COMPANY CONFIDENTIAL The FCC Statement is also included in the User Manual. END OF DOCUMENT

Internal Photos

Redtail Telematics Ltd Plextek Building London Road Great Chesterford Essex CB10 1NY UK T: +44 (0)1799 533200 W: www.redtailtelematics.com COMPANY CONFIDENTIAL Technical Note Subject:VLU6M3 - Internal Photos (FCC Item 15) From:Peter Sanders To:ACBcc:RN Electronics Ltd Date:28.9.2020Document ref:RLTN0211v1 1INTRODUCTION This document addresses Item 15 of the “Required Exhibits for FCC Certification (FCC Rule Section 2.1033(b)”. Specifically, internal photographs of the VLU6M3 stolen vehicle recovery device. RLTN0211v128.9.2020Page 2 of 4 COMPANY CONFIDENTIAL 2VLU6M3 - INTERNAL PHOTOS 2.1PCB assembly – bottom side RLTN0211v128.9.2020Page 3 of 4 COMPANY CONFIDENTIAL 2.2PCB assembly – top side RLTN0211v128.9.2020Page 4 of 4 COMPANY CONFIDENTIAL 2.3Internal sub-assemblies

RF Exposure Info

EXPOSURE LIMITS FOR ELECTROMAGNETIC RADIATION Referenced Documents“Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic and Electromagnetic Fields (up to 300GHz)” ICNIRP Guidelines. Health Pysics 74 (4); 1998 FCC Part 47 of CFR, 1 October 2004, paragraph 1.1307 IEEE C95.1-2005 IEEE Standard for Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz -Description Table 8 and Table 9 EN 50392:2002 This Document ref : Last updated near/far field boundary d1.40m t = time exposure correction factor (referenced to 3.5 minutes) Transmission Frequency 173.075MHz Wavelength l1.733352593m maximum dimension of the antenna D1.1m Transmit Power P2W Maximum Duty Cycle correction factor x0.10 x = 200ms burst every 2 seconds in Track mode Mean Tx Power (inc. duty cycle) 0.20W Gain of Antenna G1dBi Linear Gain of Antenna 1.258925412 Exposure Limit 2 W/m 2 0.2 mW/cm 2 ref 47 CFR §1.1310 Table 1 (Limits for MPE, General Population/Uncontrolled Exposure, 30-300MHz) Power Density @ d (d=R) P d 0.0010 mW/cm 2 Safety margin @d89.9dB Exposure Limit in near field 0.6667 W/m 2 see note 10.0667 mW/cm 2 Note 1: Applies 300% uncertainty factor for calculations in near field Safe Distance from Antenna R0.17mWorst case scenario - Track Mode  2 .2D d 2 .R4. .P.G.  xt P d  d P xt R ..4 G.P..  

Test Report

Page 1 of 43 File Name: Redtail Telematics Ltd.12252-2 Issue 01 QMF21J - Issue 05 - RNE Issue 03; FCC Part 90B & 90I 2019 Radio Test Report Redtail Telematics Ltd VLU6M3 4901-2207-01 47 CFR Part 90B & 90I Effective Date 1st October 2019  47CFR part 2J 2019 TNB: Licensed Non-Broadcast Station Transmitter Test Date: 30th July 2020 to 6th November 2020 Report Number: 09-12252-2-20 Issue 01 R.N. Electronics Ltd. Arnolds Court Arnolds Farm Lane Mountnessing Essex CM13 1UT U.K. www.RNelectronics.com Telephone: +44 (0) 1277 352219 Email: [email protected] This report is not to be reproduced by any means except in full and in any case not without the written approval of R.N. Electronics Ltd. ©2020 RN ELECTRONICS LIMITED REPORT NUMBER: 09-12252-2-20 Issue 01 ALL RIGHTS RESERVED Page 2 of 43 File Name: Redtail Telematics Ltd.12252-2 Issue 01 QMF21J - Issue 05 - RNE Issue 03; FCC Part 90B & 90I 2019 Arnolds Court, Arnolds Farm Lane, Mountnessing, Brentwood Essex, CM13 1UT Certificate of Test 12252-2 The equipment noted below has been fully tested by R.N. Electronics Limited and, where appropriate, conforms to the relevant subpart of FCC Part 90B & 90I. This is a certificate of test only and should not be confused with an equipment authorisation. Other standards may also apply. Equipment: VLU6M3 Model Number: 4901-2207-01 Unique Serial Number: 129701D (Transient frequency behaviour, frequency stability) 1297000 (All other tests) Applicant: Redtail Telematics Ltd Plextek Building London Road Great Chesterford Essex CB10 1NY Proposed FCC ID 2AXBF-VLU6M32207-01 Full measurement results are detailed in Report Number: 09-12252-2-20 Issue 01 Test Standards: 47 CFR Part 90B & 90I Effective Date 1st October 2019  47CFR part 2J 2019 TNB: Licensed Non-Broadcast Station Transmitter NOTE: Certain tests were not performed based upon manufacturer's declarations. Certain other requirements are subject to manufacturer declaration only and have not been tested / verified. For details refer to section 3 of this report. DEVIATIONS: No deviations have been applied. This certificate relates only to the unit tested as identified by a unique serial number and in the condition at the time it was tested. It does not relate to any other similar equipment and performance of the product before or after the test cannot be guaranteed. Whilst every effort is made to assure quality of testing, type tests are not exhaustive and although no non-conformances may be found, this doesn't exclude the possibility of unit not meeting the intentions of the standard or the requirements of the Federal Regulations, particularly under different conditions to those during testing. Any compliance statements are made reliant on (a) the application of the product and use of the assigned band being acceptable to the FCC and (b) the modes of operation as instructed to us by the Customer based on their specific knowledge of the application and functionality of the EUT. Statements of compliance, where measurements were made, do not include the measurement uncertainty. The measurement uncertainty, where stated, is the expanded uncertainty based on a standard uncertainty multiplied by a coverage factor of k=2, providing a level of confidence of approximately 95%. Date Of Test: 30th July 2020 to 6 th November 2020 Test Engineer: Approved By: Radio Approvals Manager Customer Representative: ©2020 RN ELECTRONICS LIMITED REPORT NUMBER: 09-12252-2-20 Issue 01 ALL RIGHTS RESERVED Page 3 of 43 File Name: Redtail Telematics Ltd.12252-2 Issue 01 QMF21J - Issue 05 - RNE Issue 03; FCC Part 90B & 90I 2019 1 Contents 1 Contents .......................................................................................................................................................... 3 2 Equipment under test (EUT) ........................................................................................................................... 4 2.1 Equipment specification ......................................................................................................................... 4 2.2 Configurations for testing ....................................................................................................................... 5 2.3 Functional description ............................................................................................................................ 5 2.4 Modes of operation ................................................................................................................................. 6 2.5 Emissions configuration ......................................................................................................................... 7 3 Summary of test results .................................................................................................................................. 8 4 Specifications .................................................................................................................................................. 9 4.1 Relevant standards .................................................................................................................................. 9 4.2 Deviations ................................................................................................................................................. 9 4.3 Tests at extremes of temperature & voltage ............................................................................................ 9 4.4 Test fixtures .............................................................................................................................................. 9 5 Tests, methods and results ........................................................................................................................... 10 5.1 Radiated emissions .............................................................................................................................. 10 5.2 Conducted emissions .................…

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Test Setup Photos

1.1 8-30MHz Spurious emissions test set-up 1.2 30-1000MHz Spurious emissions test set-up 1.3 Above 1GHz Spurious emissions test set-up

Contact Information

Applicant

Peter Sanders(Development Manager)
[email protected]01799588588Fax: 01799588588

Technical Contact

Redtail Telematics LimitedPeter Sanders
[email protected]+441799588588

Plextek Building, London Road · Great Chesterford · United Kingdom

Non-Technical Contact

Redtail Telematics LimitedPeter Sanders
[email protected]+441799588588

Test Firm

RN Electronics LtdClint Hilling
[email protected]+44 1277 352219

Technical Specifications

#Rule PartsFrequency RangePower OutputEmissionTolerance
190173.075 MHz - 173.075 MHz1.549 W7K11F1D1.2000000000 ppm
Confidentiality
Long Term
Grant Notes
Output power listed is peak ERP. Co-location with other transmitter equipment would require the use of FCC multi product procedures. Users must be provided with operating instructions to satisfy RF exposure compliance.