E5MDS-LN900Industrial Radio Module

MDS LN900 Integrator’s Guide 05-6739A01, revision 4 [1] MDS LN900 Integrator’s Guide 1.0 INTRODUCTION The LN900 (Figure 1), is a fixed location (not intended for mobile use), multi-modem system operating in licensed bands between 896-960MHz, using channel bandwidths of 6.25kHz, 12.5kHz, and 25.0kHz. Modulation choices for each bandwidth include QPSK, 16QAM, and 64QAM. Maximum power and modem speed is based on frequency, modem choice, and applicable emission mask. Transmit operation in a normal running system is governed by a Media Access Control Protocol, with distributed control functionality between AP and remotes, such that all stations act to control the emissions and operation of other stations in the system. The unit is designed for use inside data equipment to provide reliable connectivity in wireless networks. The LN900 power control circuit ensures that the RF output is linear and never exceeds +41 dBm at the antenna connector. The module is designed for OEM use only. Host systems must be professionally installed. Host systems must be factory configured by the OEM to operate at the correct frequency and output power setting. Refer to the table at the end of this guide to determine applicable antenna types and the RF output power allowed. 1.1 Transceiver Features The LN900 maximizes performance and flexibility in wireless networks, offering the following key features:  Selectable frequency (896-960MHz)  Selectable bandwidth (6.25kHz, 12.5kHz, 25.0kHz)  Selectable modem choices (QPSK, 16QAM, 64QAM)  RSSI and EVM readback indicators  Store-and-Forward repeater operation  Same hardware for Master, Remote, or Store-and-Forward configurations  Supports RS/EIA-232(TTL), Ethernet, and USB user interfaces  Operates at 5.0 Vdc at the MiniPCIe card edge power connections and 10-60Vdc at the 3-pin power connector. Figure 1. LN900 Transceiver Module (Mini PCI-Express Card Edge for Data/Power/& I/O and J700 Antenna) NOTE: Some features may not be available on all units, based on the options purchased, or regulatory constraints in the country of operation. MDS LN900 Integrator’s Guide 05-6739A01, revision 4 [2] 2.0 INSTALLATION The transceiver is designed for installation in existing electronic equipment. The I/O and 5.0v power connections are made through the Mini PCI-Express card edge. The 10-60v power is provided through a separate 3-pin connector on the bottom of the module. The transceiver mounts to the host heatsink assembly using two #4 screws inside the RF can area. The required heatsink contact area on the bottom surface of the PCB has the solder mask removed for proper heat transfer. Only one cable connection is required to the radio for the J700 Antenna connector. The module has three optionally populated status LEDs (CR100, CR101, and CR1000) that indicate operating mode details. These LEDs provide important information that is useful during startup and optimization of the radio link. Antennas used with the radio can be either a Yagi directional type (often used at remote sites) or an omni-directional type used for short range applications or at Master stations. Contact your sales representative for information on available antennas. Follow these steps to install the transceiver module: 1. Power down the Host assembly the module is being installed in to. 2. Mate the MiniPCIe card edge of the module into the socket on the Host assembly. 3. Secure the module to the heatsink surface using two #4 screws through the mounting holes in the corners of the RF can area on the radio’s PC board. 4. Install the RF shield over the transceiver section. 5. Select and install an appropriate antenna and feedline for your system coverage requirements. 6. Connect the antenna coaxial lead to J700 on the module. It accepts a Type-TNC male coaxial connector. 7. Host Power Supply Requirements: a. Input power applied on the 52-pin connector (J1100) must be a regulated 5.0 Vdc (-/+0.05 V). b. Input power applied on 3-pin connector (J900) must not exceed the range 10.0-60.0Vdc i. Nominal Input power on J900 is in the range 12-52Vdc - FCC CFR 47 2.1055(d)(1) See Table 1 for power supply interface connections. 52-Pin GE MDS NIC Card Edge Pin Description 1, 6, 7, 10, 11, 13, 12, 14, 16, 19, 20, 23, 25, 28, 30, 31, 32, 33, 36, 38, 42, 44, 45, 46, 47, 48, 49, 51 GPIO (Includes Ethernet & Serial) *Consult Factory Documentation for specific details 2, 24, 39, 41, 52 +5.0V 3, 5, 8, 17, 22 NC 4, 9, 15, 18, 21, 26, 27, 29, 34, 35, 37, 40, 43, 50 GND Table 1. LN900 Power Supply Connections 8. Set the radio’s basic configuration with a PC terminal through the Host system. The essential settings for all transceivers are (See Section 3 for commands):  Frequency, Bandwidth, Modem, Power, and Operating Mode 3-Pin GE MDS (J900) connector Pin Description 1 GND 2, 3 +10.0-60.0V MDS LN900 Integrator’s Guide 05-6739A01, revision 4 [3] 9. In a normally operating system, you will see the CR101 POWER LED turn on at start-up. 10. Optimize the installation by checking:  Antenna aiming and RSSI check  Optimal modem rate setting 3.0 RADIO PROGRAMMING There are no manual adjustments on the radio. All programming and control is performed through a PC connected to the Host platform that interfaces with the radio’s J1100 MiniPCIe card edge connector. 3.1 User Commands The following tables provide descriptions of the various user commands for the transceiver. Command Description Notes ABOUT Displays NIC version build time and date. HELP Displays all available commands. RESET Software reset. SER Display the NIC serial number. MODEM Display/set NIC modem selection. [4QAM, 16QAM, 64QAM] BAUD Display/set NIC symbol baud rate selection. [4800,9600,10000,16000,20000] TEST ADDR Read/write test address. [0-7] Address used for tests (e.g. PER) TEST PER Starts a Packet Error Rate Test. [-a] Destination test address [-n] Number of packets to send [-l ] Length of each packet UPTIME Display the amount of time since last power cycle. MDM KEY T…

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175 Science Parkway, Rochester, New York 14620 USA (585) 242-9600 Phone (585) 242-9620 Fax December 7, 2015 FEDERAL COMMUNICATIONS COMMISSION 7435 Oakland Mills Road Columbia, MD 21046 U.S.A. Subject: GE MDS LN900 digital radio frequency attestation Applicant: GE MDS LLC Product: LN900 digital transceiver FCC ID: E5MDS-LN900 Dear Sir/Madam, The LN900 is a multi-modem system operating between 896-960MHz, in channel bandwidths of 6.25kHz, 12.5kHz, and 25.0kHz. Modulation choices in each bandwidth include QPSK, 16QAM, and 64QAM. OTA data rate and maximum ERP power is based on the user site license and on the modem choice and the applicable emission mask for the operating frequency. The LN900 covers 896-960MHz. This device is designed to operate:  under Part 90 rules in the sub-bands 896-901MHz, 928-930, and 935-940 MHz  under Part 101 rules in the sub-bands 928-960 MHz FCC rules are violated if the device operates on unauthorized frequencies. This letter serves as attestation supporting evidence for the frequency banding. If you have any queries, please do not hesitate to contact me at 585 242-8440. Yours truly, Dennis McCarthy Agency Compliance Engineer GE MDS LLC 175 Science Parkway Rochester NY 14620 [email protected]

175 Science Parkway, Rochester, New York 14620 USA (585) 242-9600 Phone (585) 242-9620 Fax January 26, 2016 American Certification Body, Inc. 6731 Whittier Ave., C110 McLean, VA 22101 Subject: GE MDS LN900 frequency stability per 90.645(f) Applicant: GE MDS LLC Product: LN900 digital transceiver FCC ID: E5MDS-LN900 Dear Sir/Madam, GE MDS currently has a product (“LN900”) under review for Part 90 operation including bands at 896-901MHz and 935-940MHz. Per §90.213 these bands specify a fixed station frequency stability requirement of 0.1ppm. FCC rules provide exceptions to this requirement under various conditions including §90.645(f): Where the channel(s) is assigned to an SMRS licensee or exclusively to a single licensee, or where all users of a system agree, more than a single emission may be utilized within the authorized bandwidth. In such cases, the frequency stability requirements of 90.213 shall not apply, but out-of-band emission limits of §90.209 shall be met. GE MDS asserts that pursuant to FCC Part 90.645(f), the frequency stability requirements of §90.213 are precluded, and that our measured frequency stability of 0.3ppm ensures that the out-of-band emission limits of §90.209 are met. As evidence, GE MDS cites an email confirmation from Scot Stone representing the FCC ([email protected]) dated April 15, 2014 agreeing with an assertion from our attorney (Keller & Heckman) that the provisions of 90.645(f) apply without regard to whether multiple emissions are utilized. See Attachment A, included with this letter for the full text of the correspondence. Highlighting was added for clarity. If you have any queries, please do not hesitate to contact me at 585 242-8440. Yours truly, Dennis McCarthy Lead Technical Regulatory Standards Engineer GE MDS LLC 175 Science Parkway Rochester NY 14620 [email protected] From:Scot Stone <[email protected]> Sent:Tuesday, April 15, 2014 2:05 PM To:Kunkle, Gregory Subject:RE: Frequency Stability I agree that “such cases” in 90.645(f) just means “where the channels(s) is assigned to an SMRS licensee or exclusively to a single licensee, or where all users of a system agree” without regard to whether multiple emissions are utilized, just as in 90.733(c) it means “operations requiring less than 4 kHz bandwidth” without regard to whether multiple emissions are utilized.SeeFCC 82-338 paras. 150- 60, which adopted 90.645(f) for 800 MHz (it was expanded to 900 MHz in FCC 86-333). From:Kunkle, Gregory [mailto:[email protected]] Sent:Friday, April 04, 2014 5:20 PM To:Scot Stone Subject:RE: Frequency Stability Scot, Thisfollows up on the email below regarding the 896-901/935-940 MHz band frequency stability requirements.After looking into this further, I don’t believe a waiver is required.Since the language in the rules isn’t completely clear, I wanted to confirm thatyou agree. Section 90.645(f) states “where the channels(s) is assigned to an SMRS licensee or exclusively to a single licensee, or where all users of a system agree, more than a single emission may be utilized within the authorized bandwidth.In suchcases, the frequency stability requirements of 90.213 shall not apply, but out-of-band emission limits of 90.209 shall be met.” My previous email stated that 15 years ago we requested, and received, a waiver from the frequency stability requirements forfixed devices in the 220-222 MHz band. While researching this further, I realized that’s not quite right.We originally submitted a waiver request, then later sent a note to Roger stating that we thought the waiver was not required because of the language in Section 90.733(c).We then sent a letter to the Bureau requesting clarification that a waiver was not required and that clarification was granted.See attached. Although the clarification applies to the 220-222 MHz band, the operative languagein Section 90.733(c) is identical to the language in Section 90.645(f) (“In such cases, the frequency stability requirements of 90.213 shall not apply, but out-of-band emission limits of 90.209 shall be met.”). Although it isn’t clear in 90.645 whether“in such cases” refers only to cases in which multiple emissions are used, it does seem that because the language is identical to 90.733(c) the same interpretation should apply to both sections.Thus, where a channel is assigned to an SMRS licensee or exclusively to a single licensee, or where all users of a system agree, alternate frequency stabilities may be used as long as out- of-band emissions are met (adjacent users are protected in either case because the mask must still be met). Let me know if you disagree. I can call if you would rather discuss. Thanks, Greg Gregory E. Kunkle tel:+1 202.434.4178|fax: +1 202.434.4646|[email protected] 1001 G Street NW, Suite 500 West | Washington, DC20001 Visit our website atwww.khlaw.comfor additional information. From:Scot Stone [mailto:[email protected]] Sent:Wednesday, March 05, 2014 1:04 PM To:Kunkle, Gregory Subject:RE: Frequency Stability Yes, it should be filed with WTB.You can direct it to Roger. It doesn’t strike me either way yet. From:Kunkle, Gregory [mailto:[email protected]] Sent:Wednesday, March 05, 2014 12:16 PM To:Scot Stone Subject:Frequency Stability Scot, I have another Part 90 equipment issue for you, About 15 years ago, on behalf of a client, we requested and received, a waiver from the frequency stability requirements in Part 90 for fixed devices in the 220-222 MHz band.A copy of the request is attached. That client’s successor-in-interest has asked for a similar blanket waiver for the 896-901/935-940 MHz Part 90 band to use stability of .5 ppm instead of .1 ppm for fixed devices.The equipment complies with the mask, similar to the equipment in the attached showing. I checked with OET and they suggested this should be filed with WTB.Can you confirm?Should we address it to Roger Noel? Also, please let me know if this strikes you as significantly different from the previous 220 MHz request such that …

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175 Science Parkway, Rochester, New York 14620 USA (585) 242-9600 Phone (585) 242-9620 Fax January 20, 2016 FEDERAL COMMUNICATIONS COMMISSION 7435 Oakland Mills Road Columbia, MD 21046 U.S.A. Subject: GE MDS LN900 Part 90 / RSS-119 frequency stability attestation Applicant: GE MDS LLC Product: LN900 digital transceiver FCC ID: E5MDS-LN900 Dear Sir/Madam, The LN900 is operates between 896-960MHz, in channel bandwidths of 6.25kHz, 12.5kHz, and 25.0kHz. Under Part 90 rules this device is designed to operate in the sub-bands 896-901MHz, 928-930, and 935-940 MHz. All transmit operation in a normal running LN900 network is governed by a Media Access Control Protocol. The MAC uses distributed control functionality between the AP and all other radios in the network, such that the transmissions of stations act to automatically control the emissions and operation of other stations in the system. As such all stations function as control stations, as defined in Part 90.7. FCC Part 90.213 footnote 14 and IC RSS-119 section 5.3 footnote 6, each state that control stations may operate with the frequency tolerance specified for associated mobile frequencies. The applicable sub-bands and minimum frequency tolerance are provided below: Frequency Range FCC Minimum ppm IC Minimum ppm 896-901 MHz 1.5 1.5 929-930 MHz 1.5 1.5 935-940 MHz 1.5 3 The measured frequency stability of 0.3ppm meets the minimum frequency stability for each sub-band. This letter serves as attestation supporting evidence for the frequency stability. If you have any queries, please do not hesitate to contact me at 585 242-8440. Yours truly, Dennis McCarthy Agency Compliance Engineer GE MDS LLC 175 Science Parkway Rochester NY 14620 [email protected]

175 Science Parkway, Rochester, New York 14620 USA (585) 242-9600 Phone (585) 242-9620 Fax December 7, 2015 To Whom It May Concern: Subject: Manufacturer’s Declaration for Limited Modular approval for FCC part 90 licensed spectrum and IC RSS-119. FCC ID: E5MDS-LN900, IC: 101D-LN900 FCC KDB 996369 Modular Approval Checklist: Modular approval requirement Yes No (*) 1. The modular transmitter must have its own RF shielding. This is intended to ensure that the module does not have to rely upon the shielding provided by the device into which it is installed in order for all modular transmitter emissions to comply with Part 15 limits. It is also intended to prevent coupling between the RF circuitry of the module and any wires or circuits in the device into which the module is installed. Such coupling may result in non-compliant operation. YES, the RF circuitry is shielded on the PCB 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. YES, the Data is buffered through communication drivers to the processors 3. The modular transmitter must have its own power supply regulation. This is intended to ensure that the module will comply with Part 15 requirements regardless of the design of the power supplying circuitry in the device into which the module is installed. No, we will control the host integration and DC regulation as described in Integrator’s Guide. 4. The modular transmitter must be tested in a stand-alone configuration, i.e., the module must not be inside another device during testing. This is intended to demonstrate that the module is capable of complying with Part 15 emission limits regardless of the device into which it is eventually installed. 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 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 equipment. Any accessories, peripherals, or support equipment connected to the module during testing shall be unmodified or commercially available (see Section 15.31(i)). Yes, the module was tested on the bench outside of the enclosure as a stand-alone device and complies with emission requirements for Parts 15, 90, and 101C 5. The modular transmitter must be labeled with its own FCC ID number, and, if the FCC ID 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. Yes, there will be a FCC label on the module. The host device will be labeled with “Contains FCC ID: E5MDS- LN900” 6. The modular transmitter must comply with any specific rule or operating requirements applicable to the 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. For example, there are very strict operational and timing requirements that must be met before a transmitter is authorized for operation under Section 15.231. For instance, data transmission is prohibited, except for operation under Section 15.231(e), in which case there are separate field strength level and timing requirements. Compliance with these requirements must be assured. Yes, Instructions to the OEM installer regarding such requirements for use in host device(s) are included in this application. Modular approval requirement Yes No (*) 7. The modular transmitter must comply with any applicable RF exposure requirements. For example, RSS-102 and FCC Rules in Sections 2.1091, 2.1093 and specific Sections of Part 15, including 15.319(i), 15.407(f), 15.253(f) and 15.255(g), require that Unlicensed PCS, UNII and millimeter wave devices perform routine environmental evaluation for RF Exposure to demonstrate compliance. In addition, spread spectrum transmitters operating under Section 15.247 are required to address RF Exposure compliance in accordance with Section 15.247(b)(4). Modular transmitters approved under other Sections of Part 15, when necessary, may also need to address certain RF Exposure concerns, typically by providing specific installation and operating instructions for users, installers and other interested parties to ensure compliance. The module meets this requirement for a Fixed device that shall be used at separation distance of more than 20cm from the human body. The module complies with applicable RSS-102 exposure requirements, in its intended configuration/integration in a host. Refer to the MPE calculation and Integrator’s Guide. IC RSP-100, 7.3 Modular Approval Checklist: Modular approval requirement Yes No * a) The radio elements shall have the radio frequency circuitry shielded. Physical / discrete and tuning capacitors may be located external to the shield, but must be on the module assembly. YES, the RF circuitry is shielded on the PCB b) The module shall have buffered modulation/data input(s)…

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Page 1 of 1 American TCB 6731 Whittier Avenue, Suite C110 McLean, VA. 22101 To whom it may concern: The enclosed documents constitute a formal submittal and application for a Limited Modular Approval for an industrial radio module pursuant to the following rules: Parts 90 and 101 of FCC Rules RSS-119, Issue 12, May 2015, “Radio Transmitters and Receivers Operating in the Land Mobile and Fixed Services in the Frequency Range 27.41-960 MHz” A waiver of section 90.207(i) is granted by FCC to use emission designator D1D. National Technical Systems – Silicon Valley, as duly authorized agent prepared this submittal. A copy of the letter of our appointment as agent is included with the application. If there are any questions or if further information is needed, please contact National Technical Systems – Silicon Valley for assistance. Sincerely, David W. Bare Chief Engineer, National Technical Systems - Silicon Valley

033015-24a 175 Science Parkway, Rochester, New York 14620 USA (585) 242-9600 Phone (585) 242-9620 Fax December 7th, 2015 Attn: Director of Certification Authority to Act as Agent I appoint __National Technical Systems – Silicon Valley___ to act as our agent in the preparation of this application for equipment certification. I certify that submitted documents properly describe the device or system for which equipment certification is sought. I also certify that each unit manufactured, imported or marketed, as defined in Industry Canada’s regulations will have affixed to it a label identical to that submitted for approval with this application. For instances where our authorized agent signs the application for certification on our behalf, I acknowledge that all responsibility for complying with the terms and conditions for Certification, as specified by American Certification Body, Inc. (ACB), still resides with ___GE MDS LLC, 175 Science Parkway, Rochester NY 14620. Dated this 7 th day of December, 2015. Agency Agreement Expiration Date: December 7 th , 2016 By: Title: Agency Compliance Engineer On behalf of: ____ GE MDS LLC_________ (Company Name) Telephone: _____ 585 242-8440__________

Federal Communications Commission Washington, D.C. 20554 May 18, 2015 DA 15-593 Greg Kunkle Keller and Heckman LLP 1001 G Street, N.W., Suite 500W Washington, DC 20001 Re:GE MDS, LLC Request for Wavier of Section 90.207(i) of the Commission’s Rules Dear Mr.Kunkle: Introduction. We have before us a request for waiver of Section 90.207(i) of the Commission’s Rules 1 filed by GE MDS, LLC (“GE”) to allow use of the D1D emission designator 2 by equipment in GE’s ORBIT radio platform equipment for telemetry operations. 3 For the reasons discussed herein, we grant GE’s request. Background. Section 90.207 sets forth the emissions that may be authorized under Part 90 of the Commission’s Rules and references the types of operations in which they may be utilized. 4 Section 90.207(i) provides, “For telemetry operations, when specifically authorized under this part, only A1D, A2D, F1D, or F2D will be authorized.” 5 GE, a radio equipment designer/manufacturer, states that it is developing a narrowband high- efficiency point-to-point and point-to-multipoint telemetry radio system that will provide data rates greatly exceeding the 4800 bps/6.25 kHz bandwidth standard contained in Section 90.203 of the Commission’s Rules. 6 Because the ORBIT radio platform utilizes a QAM radio module topology, 7 GE requests a blanket waiver of Section 90.207(i) to allow certification, licensing, and use of its ORBIT radio platform for telemetry radios with D1D emissions. 8 Discussion. To obtain a waiver of the Commission's Rules, a petitioner must demonstrate either that the underlying purpose of the rule(s) would not be served or would be frustrated by application to the 1 47 C.F.R. § 90.207(i). 2 The emission designator is a series of alphanumeric characters that denotes the necessary bandwidth, type of modulation, nature of the signal modulating the main carrier, and type of information to be transmitted. See47 C.F.R. §§ 2.201(b), 2.202(b). D1D is a digital emission that is amplitude- and angle-modulated. 3 SeeRequest for Waiver of Section 90.207(i) of the Commission’s Rules filed by GE MDS, LLC on December 23, 2014 (Request). 4 Amendment of the Commission’s Rules governing the Private Land Mobile Radio Service to provide a new Part 90 that reregulates and consolidates Parts 89, 91, and 93, Report and Order, Docket No. 21348, 29 F.C.C. 2d 1612, 1616 ¶ 11 (1978). 5 See47 C.F.R. § 90.207(i). 6 SeeGE Request at 4. See also47 C.F.R. § 90.203(j). 7 Quadrature Amplitude Modulation, or QAM, is a sophisticated modulation technique, using variations in signal amplitude and phase, that allows multiple bits to form a single “symbol,” which is then impressed on a single sine wave. Cable Television Technical and Operational Requirements, Notice of Proposed Rulemaking, MB Docket No. 12-217, 27 FCC Rcd 9678, 9683 n. 29 (2012). 8 See GE Requestat 2. GE MDS, LLC2 present case and that grant of the waiver would be in the public interest; or that, in view of unique or unusual factual circumstances of the instant case, application of the rule(s) would be inequitable, unduly burdensome, or contrary to the public interest, or the applicant has no reasonable alternative. 9 We conclude that grant of a waiver to permit certification, licensing, and use of GE’s ORBIT radio platform equipment is warranted. Allowing licensees to utilize the D1D emissions will promote the efficient use of limited spectrum resources, and can improve the effectiveness of critical infrastructure operations that protect life, property, and the environment. 10 Based on the information before us, we conclude that grant of a waiver would not frustrate the underlying purposes of the emission designator rules and would serve the public interest. 11 Conclusion. We grant a waiver of Section 90.207(i)to permit certification, licensing, and use of GE’s ORBIT radio platform equipment using D1D emissions for telemetry operations. A copy of this lettershall be submitted with any equipment authorization application. License applications must reference this letter by the DA number set forth above. No license applications will be granted until GE obtains equipment authorization. Accordingly, IT IS ORDERED, pursuant to Section 4(i) of the Communications Act of 1934, as amended, 47 U.S.C. § 154(i), and Section 1.925 of the Commission’s Rules, 47 C.F.R. § 1.925, that the waiver request filed by GE MDS, LLC, on December 23, 2014 IS GRANTED as set forth herein. This action is taken under delegated authority pursuant to Sections 0.131 and 0.331 of the Commission’s Rules, 47 C.F.R. §§ 0.131, 0.331. FEDERAL COMMUNICATIONS COMMISSION Scot Stone Deputy Chief, Mobility Division Wireless Telecommunications Bureau 9 See47 C.F.R. §1.925(b)(3). 10 See GE Request at 2-3. 11 See4RF Limited, Order, WT Docket No. 13-188, 29 FCC Rcd 2898, 2899 ¶ 5 (WTB MD 2014) (granting waive to permit D1D emission for telemetry equipment utilizing linear modulation methods to address spectrum efficiency) (citing Lojack Corporation, Order, 20 FCC Rcd 20497, 20499 ¶ 7 (WTB PSCID 2005) (granting waiver to permit D1D emission on frequency on which 47 C.F.R. § 90.20(e)(6) permitted only F1D and F2D, on the grounds that allowing greater efficiency was in the public interest and would not frustrate the rule's underlying purpose)).

175 Science Parkway, Rochester, New York 14620 USA (585) 242-9600 Phone (585) 242-9620 Fax December 7, 2015 Request for Confidentiality Subject: Confidentiality Request for: FCC ID: E5MDS-LN900 and IC: 101D-LN900 Pursuant to FCC 47 CRF 0.457(d) and 0.459 and/or RSP-100, the applicant requests that a part of the subject FCC and/or IC 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* User’s Manual *Note: GE MDS LLC 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 NA days from the date of the Grant of Equipment Authorization and prior to marketing. …

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