AZ489FT5772

Motorola Inc., iDEN Subscriber Group, 8000 W. Sunrise Blvd., Plantation, FL 33324 June 21, 2001 Mr. Richard Fabina Chief Equipment Authorization Branch Federal Communications Commission Laboratory 7435 Oakland Mills Road Columbia, MD 21046 Dear Mr. Fabina; As conveyed verbally during our visit on 15 May 2001, Motorola discovered on April 26, 2001, through an internal quality audit in our distribution center at Plantation, Florida, that FCC ID labels had been misapplied to certain radios during manufacturing. Specifically, FCC ID “AZ489FT5772” was printed on the label applied to 352,000 radios, which should have been labeled with a different identifier as noted in Table 1 below. “AZ489FT5772” is the correct FCC ID identifier for the iDEN r370 and r470 product lines, which are no longer produced. Table 1 Product Line Correct FCC ID Misprinted ID i550plus AZ489FT5792 AZ489FT5772 i700plus AZ489FT5792 AZ489FT5772 i1000plus AZ489FT5793 AZ489FT5772 The labeling error occurred because of the conversion on current products to an in-line label printing system using a computer database, which was programmed with the wrong identifier . In the past, each label variation was a specific part number on a production bill of material unique to each product, and the pre-printed label information was on the blueprint (under formal manufacturing revision control) used for parts procurement. This new process had been introduced into the factories with the introduction of our new i85s product line in late March of this year. The first occurrence of mislabeling appears to have occurred on 28 March for the i550plus and i700plus product line units that were sent to our Plantation, Florida, distribution center from a contract production facility located outside the US. The first occurrence of mislabeling for the i1000plus product line units occurred on 12 April, and these were produced at an offshore Motorola production facility in Penang, Malaysia. Upon discovery, immediate actions were taken to stop shipment, correct the in-line printing process computer database at all production facilities and our repair centers, and rework all 80,000 units still in the distribution center. The results were that 272,000 radios of the 352,000 mislabeled radios shipped and are in use at this time. Of that quantity 237,000 are in the US as – 2 –May 25, 2001 35,000 were shipped to foreign countries. Our carrier customers who received the erroneously marked units have been notified of this error, but, as noted, we believe the units are now in use. The rework was implemented by marking out the incorrect identifier on the already attached label, then adding a smaller label listing the correct identifier, as shown in Figure 1. Radios that are returned to our repair centers for any reason in the future will be inspected, and reworked if incorrectly labeled. Figure 1 – Distribution center reworked i1000plus (AZ489FT5793) To reduce the possibility of future occurrences, the in-line label printing operation will be treated like our computer controlled in-line electronic testing process. Computer program data for printing on blank labels will be input from an engineering specification that is under formal manufacturing revision control. Thus, the label information will now be handled like the test limit data that are inputted into the manufacturing process for determining that phones have been correctly adjusted, a process that should prove to be far less prone to the sort of error that occurred. One consequence of the mislabeling is that a user will not obtain any SAR information for their radio from the OET equipment authorization web pages if they input the erroneous FCC ID AZ489FT5772. This occurs not only because of the labeling error but also because of the fact that the grant for the erroneously applied number AZ489FT5772 was received prior to the implementation date of 47 CFR § 2.1093. Consequently, we respectfully ask that an entry be added at the OET web page for FCC ID AZ489FT5772 that would convey the correct FCC ID numbers to be used to obtain SAR information based on the contents in Table 1 and that would, in fact, include the maximum SAR information for the products to which the label was misapplied. A draft for this purpose is provided as an Attachment. Figure 1.2 Misprinted FCC Label with black mark Figure1.1 Correct FCC Number – 3 –May 25, 2001 I appreciate the time that you, Mr. Nichols, and Mr. LaForge spent in meeting with me on this matter last week. Should you have any questions, please call me at 954 723-5539. Sincerely yours, /s/ Al Wieczorek Al Wieczorek Regulatory, Safety and Standards, iDEN Subscriber Group cc: Messrs. Nichols and LaForge

June21,2001 ATTACHMENT TEXT FOR OET WEB SITE FOR FCC ID: AZ489FT5772 This identifier has been placed on several different products, sometimes erroneously. To access FCC information for these erroneously labeled units examine the front of your radio product to determine the product line name, the correct FCC identifier and RF exposure information. Note that no information is on file for the r370 and r470 radio products. Product Lin eCorrect FCC IDMaximum Calculated SAR (Watts/kg) SAR report file may be found at r370 AZ489FT5772 Not on file r470 AZ489FT5772 Not on file i550plus i700plus AZ489FT5792 0.58 @ ear position, phone mode 0.06 in front of face, 2-way mode 1.29 @ abdomen, phone mode, with NTN8981 leather carry case http://gullfoss2.fcc.g ov/prod/oet/forms/bl obs/retrieve.cgi?atta chment_id=40837& native_or_pdf=pdf i1000plus AZ489FT5793 0.81 @ ear position, phone mode 0.12 @ in front of face, 2-way mode 0.32 @ abdomen, with NTN8657 belt clip holster, 2-way mode http://gullfoss2.fcc.g ov/prod/oet/forms/bl obs/retrieve.cgi?atta chment_id=33077& native_or_pdf=pdf Information may also be obtained at the manufacturer’s web site, www.motorola.com/rfhealth/ , for products certified after June 2000.