EOA-24HALOXF1324HALOXF13

Northwest EMC TCB Compliance Opinion Rev. 12/08/09 STAK0027 Information about the Applicant Grantee (Company Name) Starkey Laboratories, Inc. FCC Contact Person Kenneth Meyer Address 6600 Washington Avenue South City, State, Zip Eden Prarie, MN 55344 Job Number STAK0027 Model 24HALOXF13 FCC ID EOA—24HALOXF13 Agent Approval Type Original Equipment Class DTS Digital Transmission System Rule Part 15C Overview The model 24HALOXF13, FCC ID: EOA—24HALOXF13, is a wireless hearing aid intended for use by the hearing impaired. The wireless features are used during the initial fitting of a hearing aid to program the hearing aid, and used during normal usage to communicate control information and digital audio to and from any properly configured BlueTooth Low Energy compliant accessory. Confidentiality requested for allowed files. Request is properly addressed and referenced. Recommendation All items have been resolved and completed to my satisfaction; therefore I recommend this application for approval. Signature Greg Kiemel, TCB Committee 11/26/2013

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FCC Home | Search | RSS | Updates | E-Filing | Initiatives | Consumers | Find People Office of Engineering and Technology Subject: Response to Inquiry to FCC (Tracking Number 910389) (TCB) From: <[email protected]> Date: 11/25/2013 9:17 AM To: <[email protected]> Link to Federal Communications Commission Home Office of Engineering and Technology Inquiry on 11/19/2013 : Inquiry: The applicant Starkey Laboratories Inc is requesting that they be allowed to place the FCC ID label for their device in the User Manual rather than on the device itself, which is a wireless hearing aid. Due to the extremely small size of the device, they believe the ID label would become illegible if they had to reduce the font size small enough to fit on the device Starkey submitted a similar request a few years ago for FCC ID: EOA-IRIS-HA and the FCC gave them permission to place the label in the manual. They are asking for that same permission for this current application. Attached are photos showing the size of the previous device and label and photos showing the size of the current device and label. Please let us know if you need additional information. Thanks. FCC response on 11/25/2013 FCC Rule SecƟon §2.925 (f) specifically allows for the FCCID to be placed other than on the device. Reason stated below: Where it is shown that a permanently affixed nameplate is not desirable or is not feasible, an alternaƟve method of posiƟ vely idenƟfying the equipment may be used if approved by the Commission. The proposed alternaƟve method of idenƟficaƟon and the jusƟficaƟon for its use must be included with the applicaƟon for equipment authorizaƟon. Similarly, KDB 784748 D01 provides guidance that allows the FCCID to be placed in the user’s manual. The FCC approves your request to place the FCC ID in the user’s manual. Accordingly, you are allowed to place the FCCID in the user’s manual. Please note that the approval of this condiƟon by the FCC must be must be included in the applicaƟon for cerƟficaƟon. Response to Inquiry to FCC (Tracking Number 910389) (TCB) 1 of 211/25/2013 9:42 AM Attachment Details: Photos showing sample devices Do not reply to this message. Please select the Reply to an Inquiry Response link from the OET Inquiry System to add any additional information pertaining to this inquiry. Response to Inquiry to FCC (Tracking Number 910389) (TCB) 2 of 211/25/2013 9:42 AM

XF13 Internal Photo showing backside of spine assembly XF13 Internal Photo showing topside PCA XF13 Internal Photo showing bottomside of antenna PCB XF13 Internal Photo showing bottomside PCA XF13 Internal Photo showing topside of antenna PCB XF13 Internal Photo showing topside of antenna PCB XF13 Internal Photo showing spine assembly removed from case XF13 Internal Photo showing top side of spine assembly XF13 Internal Photo showing right side of spine assembly XF13 Internal Photo showing left side of spine assembly XF13 Internal Photo showing bottomside of spine assembly

Antenna Description The antenna is an asymmetric dipole. The antenna is constructed on a polyimide flexible circuit. The flexible circuit uses 1 ounce copper (1.4 mil). The elements of the dipole antenna are each approximately 1.1 inches long. The peak gain of the antenna in the assembled DUT is – 2 dBi. Figure 1 Antenna artwork.

Compliance with 47 CFR 15.247(i) “Systems operating under the provisions of this section shall be operated in a manner that ensures that the public is not exposed to radio frequency energy levels in excess of the Commission's guidelines. See § 1.1307(b)(1) of this chapter.” The EUT is a Bluetooth Low Energy transceiver contained within a host system of a hearing aid. It will be used within 20 cm to the head since it will be worn in the ear as a typical hearing aid is utilized. However, due to its low output power, there is no restriction from placing it within 20cm of the user. The maximum antenna gain of flex circuit trace dipole antenna is -2.0 dBi. The maximum peak conducted output power is 0.622 mW. The maximum peak radiated power is 0.39 mW EIRP. The transmit frequency is 2402 MHz to 2480 MHz, therefore the EUT does not require routine SAR evaluation because it falls below the low power threshold. Please see this excerpt from KDB 447498 D01 Mobile Portable RF Exposure v05r01, Section 4.3.1, Item #1: “The 1-g and 10-g SAR test exclusion thresholds for 100 MHz to 6 GHz at test separation distances ≤ 50 mm are determined by: [(max. power of channel, including tune-up tolerance, mW)/(min. test separation distance, mm)] · [√f(GHz)] ≤ 3.0 for 1-g SAR and ≤ 7.5 for 10-g extremity SAR, where • f(GHz) is the RF channel transmit frequency in GHz • Power and distance are rounded to the nearest mW and mm before calculation • The result is rounded to one decimal place for comparison • 3.0 and 7.5 are referred to as the numeric thresholds in the step 2 below The test exclusions are applicable only when the minimum test separation distance is ≤ 50 mm and for transmission frequencies between 100 MHz and 6 GHz. When the minimum test separation distance is < 5 mm, a distance of 5 mm according to 5) in section 4.1 is applied to determine SAR test exclusion.” Using the most conservative exposure condition (closest to the user), the applicant’s wireless radio, FCC ID: EOA-24HALOXF13, is compliant with the requirements of FCC 15.247(i). Per KDB 447498 it is excluded from SAR testing and deemed compliant. Using the equation above: (0.39mW / 5mm)*2.48GHz = 0.19 which is < 3.0 for 1-g SAR.

Starkey Laboratories, Inc. 24HALOXF13 FCC 15.247:2013 Report #: STAK0027 Report Prepared By Northwest EMC Inc. NORTHWEST EMC – (888) 364-2378 – www.nwemc.com California – Minnesota – Oregon – New York – Washington WTD 12.5.23 CERTIFICATE OF TEST Last Date of Test: January 14, 2013 Starkey Laboratories, Inc. Model: 24HALOXF13 Emissions Test Description Specification Test Method Pass/Fail Duty Cycle FCC 15.247:2013 ANSI C63.10:2009 Pass Occupied Bandwidth FCC 15.247:2013 ANSI C63.10:2009 Pass Output Power FCC 15.247:2013 ANSI C63.10:2009 Pass Band Edge Compliance FCC 15.247:2013 ANSI C63.10:2009 Pass Spurious Conducted Emissions FCC 15.247:2013 ANSI C63.10:2009 Pass Power Spectral Density FCC 15.247:2013 ANSI C63.10:2009 Pass Spurious Radiated Emissions FCC 15.247:2013 ANSI C63.10:2009 Pass Deviations From Test Standards None Approved By: Tim O'Shea, Operations Manager NVLAP Lab Code: 200881-0 Test Facility The measurement facility used to collect the data is located at: Northwest EMC, Inc. 9349 W Broadway Ave., Brooklyn Park, MN 55445 Phone: (763) 425-2281 Fax: (763) 424-3469 This site has been fully described in a report filed with and accepted by the FCC (Federal Communications Commission) and Industry Canada (Site filing #2834E-1). This report must not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the federal government of the United States of America. Product compliance is the responsibility of the client, therefore the tests and equipment modes of operation represented in this report were agreed upon by the client, prior to testing. This Report may only be duplicated in its entirety. The results of this test pertain only to the sample(s) tested. The specific description is noted in each of the individual sections of the test report supporting this certificate of test. REV 2012.08.02 REVISION HISTORY Revision Number Description Date Page Number 00 None Barometric Pressure The recorded barometric pressure has been normalized to sea level. REV 2012.05.24 ACCREDITATIONS AND AUTHORIZATIONS United States FCC - Designated by the FCC as a Telecommunications Certification Body (TCB). Certification chambers, Open Area Test Sites, and conducted measurement facilities are listed with the FCC. A2LA - Accredited by A2LA to ISO / IEC Guide 65 as a product certifier. This allows Northwest EMC to certify transmitters to FCC and IC specifications. NVLAP - Each laboratory is accredited by NVLAP to ISO 17025 Canada IC - Recognized by Industry Canada as a Certification Body (CB). Certification chambers and Open Area Test Sites are filed with IC. European Union European Commission – Validated by the European Commission as a Conformity Assessment Body (CAB) under the EMC directive and as a Notified Body under the R&TTE Directive. Australia/New Zealand ACMA - Recognized by ACMA as a CAB for the acceptance of test data. Korea KCC / RRA - Recognized by KCC’s RRA as a CAB for the acceptance of test data. Japan VCCI - Associate Member of the VCCI. Conducted and radiated measurement facilities are registered. Taiwan BSMI – Recognized by BSMI as a CAB for the acceptance of test data. NCC - Recognized by NCC as a CAB for the acceptance of test data. Singapore IDA – Recognized by IDA as a CAB for the acceptance of test data. Hong Kong OFTA – Recognized by OFTA as a CAB for the acceptance of test data. Vietnam MIC – Recognized by MIC as a CAB for the acceptance of test data. Russia GOST – Accredited by Certinform VNIINMASH, CERTINFO, SAMTES, and Federal CHEC to perform EMC and Hygienic testing for Information Technology products to GOST standards. SCOPE For details on the Scopes of our Accreditations, please visit: http://www.nwemc.com/accreditations/ REV 2012.08.02 MEASUREMENT UNCERTAINTY Measurement Uncertainty When a measurement is made, the result will be different from the true or theoretically correct value. The difference is the result of tolerances in the measurement system that cannot be completely eliminated. To the extent that technology allows us, it has been our aim to minimize this error. Measurement uncertainty is a statistical expression of measurement error qualified by a probability distribution. A measurement uncertainty estimation has been performed for each test per our internal quality document WP 342. The estimation is used to compare the measured result with its "true" or theoretically correct value. The expanded measurement uncertainty (K=2) for each test is on each data sheet. Our measurement data meets or exceeds the measurement uncertainty requirements of the applicable specification; therefore, the test data can be compared directly to the specification limit to determine compliance. The calculations for estimating measurement uncertainty are based upon ETSI TR 100 028 (or CISPR 16-4-1 as applicable), and are available upon request. The following table represents the Measurement Uncertainty (MU) budgets for each of the tests that may be contained in this report. Test + MU - MU Frequency Accuracy (Hz) 0.12 -0.01 Amplitude Accuracy (dB) 0.49 -0.49 Conducted Power (dB) 0.41 -0.41 Radiated Power via Substitution (dB) 0.69 -0.68 Temperature (degrees C) 0.81 -0.81 Humidity (% RH) 2.89 -2.89 Field Strength (dB) 4.00 -4.00 AC Powerline Conducted Emissions (dB) 2.70 -2.70 REV 2013.01.07 LOCATIONS Oregon Labs EV01-12 22975 NW Evergreen Pkwy Hillsboro, OR 97124 (503) 844-4066 California Labs OC01-13 41 Tesla Irvine, CA 92618 (949) 861-8918 New York Labs WA01-04 4939 Jordan Rd. Elbridge, NY 13060 (315) 685-0796 Minnesota Labs MN01-08 9349 W Broadway Ave. Brooklyn Park, MN 55445 (763) 425-2281 Washington Labs NC01-05,SU02,SU07 19201 120 th Ave. NE Bothell, WA 98011 (425) 984-6600 VCCI A-0108 A-0029 A-0109 A-0110 Industry Canada 2834D-1, 2834D-2 2834B-1, 2834B-2, 2834B-3 2834E-1 2834C-1 WTD 12.5.23 PRODUCT DESCRIPTION Client and Equipment Under Test (EUT) Information Company Name: Starkey Laboratories, Inc. Address: 6600 Washington Ave. SO. City, Sta…

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Duty Cycle XMit 2012.09.20 NORTHWEST Duty Cycle EMC Direct 001.JPG Duty Cycle Occupied Bandwidth XMit 2012.09.20 NORTHWEST Occupied Bandwidth EMC Direct 001.JPG Occupied Bandwidth Output Power XMit 2012.09.20 NORTHWEST Output Power EMC Direct 001.JPG Output Power Band Edge Compliance XMit 2012.09.20 NORTHWEST Band Edge Complian EMC Direct 001.JPG Band Edge Compliance Spurious Conducted Emissions XMit 2012.09.20 NORTHWEST Spurious Conducted EMC Direct 001.JPG Spurious Conducted Emissions Power Spectral Density XMit 2012.09.20 NORTHWEST Power Spectral Dens EMC Direct 001.JPG Power Spectral Density photo SRE 001.JPG SRE 002.JPG Spurious Radiated Emissions PSA-ESCI 2012.12.14 photo SRE 003.JPG SRE 004.JPG Spurious Radiated Emissions PSA-ESCI 2012.12.14