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IPH-03626Portable Transceiver

Garmin International Inc
Portable Transceiver - FCC ID IPH-03626 - Garmin International Inc
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Application Details

Equipment Class
TNT - Licensed Non-Broadcast Transmitter Worn on Body
Date of Grant
Sep 22, 2020
Application Purpose
Original Equipment
Date of Application
Sep 22, 2020
Equipment Note
Portable Transceiver
Frequency Range
151.82000000 - 154.60000000
Company
Garmin International Inc
Country
United States

Documents & Files

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Users Manual

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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.

Users Manual

does not assume any responsibility for any fines, penalties, or damages that may be incurred as a result of any state or local law or ordinance relating to the use of your Garmin device. GPS Dog Collar Legal Restrictions Check your state and local laws and ordinances to ensure you fully understand any restrictions applicable to this product in your jurisdiction prior to purchase and/or use. Garmin does not assume any responsibility for any fines, penalties, or damages that may be incurred as a result of any state or local law or ordinance relating to use of the product. GPS Notice The navigation device may experience degraded performance if you use it in proximity to any device that uses a terrestrial broadband network operating close to the frequencies used by any Global Navigation Satellite System (GNSS), such as the Global Positioning Service (GPS). Use of such devices may impair reception of GNSS signals. Product Environmental Programs Information about the Garmin product recycling program and WEEE, RoHS, REACH, and other compliance programs can be found at www.garmin.com/aboutGarmin /environment. Declaration of Conformity Hereby, Garmin declares that this product is in compliance with the Directive 2014/53/EU. The full text of the EU declaration of conformity is available at the following internet address: www.garmin.com/compliance. Innovation, Science and Economic Development Canada Compliance This device complies with Innovation, Science and Economic Development Canada license-exempt RSS standard(s). Operation is subject to the following two conditions: (1) this device may not cause interference, and (2) this device must accept any interference, including interference that may cause undesired operation of the device. Radio Frequency Radiation Exposure This device is a mobile transmitter and receiver that uses an internal antenna to send and receive low levels of radio frequency (RF) energy for data communications. The device emits RF energy below the published limits when operating in its maximum output power mode and when used with Garmin authorized accessories. The device should not be used in other configurations. This device must not be co-located or operated in conjunction with any other transmitter or antenna. FCC Compliance This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) this device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to part 15 of the FCC rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates, uses, and can radiate radio frequency energy and may cause harmful interference to radio communications if not installed and used in accordance with the instructions. However, there is no guarantee that interference will not occur in a particular installation. If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one of the following measures: • Reorient or relocate the receiving antenna. •Increase the separation between the equipment and the receiver. • Connect the equipment into an outlet on a circuit different from that to which the receiver is connected. • Consult the dealer or an experienced radio/TV technician for help. This product does not contain any user-serviceable parts. Repairs should only be made by an authorized Garmin service center. Unauthorized repairs or modifications could result in permanent damage to the equipment, and void your warranty and your authority to operate this device under Part 15 regulations. VHF Radio Information This product may be used only on specific radio frequencies, which vary depending on the country of use. The handheld device and the dog device allow the user to install a different antenna. Changing the antenna can result in improved radio performance and higher radiated power. You must not use the device with a third party antenna or an antenna not approved by Garmin. Go to www.garmin.com/tracking-legal for details about the performance and radio frequency of this product, lawful accessories, and power limits for countries. Map Data Information Garmin uses a combination of governmental and private data sources. Virtually all data sources contain some inaccurate or incomplete data. In some countries, complete and accurate map information is either not available or is prohibitively expensive. 3 Software License Agreement BY USING THE DEVICE, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THE FOLLOWING SOFTWARE LICENSE AGREEMENT. PLEASE READ THIS AGREEMENT CAREFULLY. Garmin Ltd. and its subsidiaries (“Garmin”) grant you a limited license to use the software embedded in this device (the “Software”) in binary executable form in the normal operation of the product. Title, ownership rights, and intellectual property rights in and to the Software remain in Garmin and/or its third-party providers. You acknowledge that the Software is the property of Garmin and/or its third-party providers and is protected under the United States of America copyright laws and international copyright treaties. You further acknowledge that the structure, organization, and code of the Software, for which source code is not provided, are valuable trade secrets of Garmin and/or its third-party providers and that the Software in source code form remains a valuable trade secret of Garmin and/or its third-party providers. You agree not to decompile, disassemble, modify, reverse assemble, reverse engineer, or reduce to human readable form the Software or any part thereof or create any derivative works based on the Software. You agree not to ex…

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Users Manual

© 2020 Garmin Ltd. or its subsidiaries All rights reserved. Under the copyright laws, this manual may not be copied, in whole or in part, without the written consent of Garmin. Garmin reserves the right to change or improve its products and to make changes in the content of this manual without obligation to notify any person or organization of such changes or improvements. Go to www.garmin.com for current updates and supplemental information concerning the use of this product. Garmin ® , the Garmin logo, Alpha ® , ANT+ ® , City Navigator ® , inReach ® , and Xero ® are trademarks of Garmin Ltd. or its subsidiaries, registered in the USA and other countries. BaseCamp ™ , Garmin Explore ™ , Garmin Express ™ , Garmin HuntView ™ , MapShare ™ , tempe ™ , and TT ™ are trademarks of Garmin Ltd. or its subsidiaries. These trademarks may not be used without the express permission of Garmin. Apple ® and Mac ® are trademarks of Apple Inc., registered in the U.S. and other countries. The BLUETOOTH ® word mark and logos are owned by the Bluetooth SIG, Inc. and any use of such marks by Garmin is under license. Powered by GEOS. Iridium ® is a registered trademark of Iridium Satellite LLC. microSD ® and the microSDHC logo are trademarks of SD-3C, LLC. Wi‑Fi ® is a registered mark of Wi-Fi Alliance Corporation. Windows ® is a registered trademark of Microsoft Corporation in the United States and other countries. Other trademarks and trade names are those of their respective owners. Table of Contents Getting Started...............................................................1 Setting Up the Alpha System......................................................1 Device Overviews.......................................................................1 Alpha Handheld Device.........................................................1 Dog Collar Device..................................................................1 Installing the Battery Pack..........................................................1 Charging the Handheld Device...................................................2 Charging the Dog Collar Device.................................................2 Turning On the Device................................................................2 Turning Off the Device...........................................................2 Selecting a Language.................................................................2 Using the Touchscreen...............................................................2 Using the Status Page................................................................2 Acquiring Satellite Signals..........................................................2 Iridium® Satellite Network..........................................................2 Activating the Device.....................................................3 Dog Collar Device Setup................................................3 Methods to Add a Dog Collar Device to a Handheld Device...... 3 Adding a Dog to the Alpha Handheld Using Wireless Pairing....................................................................................3 Sharing a Dog Wirelessly.......................................................3 Adding a Dog Using the Track and Control Codes................3 VHF Radio Information..........................................................4 Managing a Group......................................................................4 Editing Dog Information..............................................................4 Resetting a Dog's Statistics and Track..................................4 Changing the Length of the Dog's Track...............................4 Changing the Dog Name.......................................................4 Changing the Color of the Dog's Track..................................4 Changing the Dog Type.........................................................4 Changing the Dog ID.............................................................4 Setting Dog Alerts..................................................................4 Removing a Dog....................................................................4 Fitting the Collar on Your Dog....................................................4 Communication with the Collar...................................................5 Entering Sleep Mode..................................................................5 Exiting Sleep Mode................................................................5 Dog Tracking..................................................................5 Tracking Your Dog on the Map...................................................5 Dog Status Icons........................................................................5 Dog Tracking Compass..............................................................5 Navigating to Your Dog...............................................................6 Location Alerts............................................................................6 Setting Location Alerts...........................................................6 Editing Location Alerts...........................................................6 Disabling Dog Data Broadcast....................................................6 Dog Training...................................................................6 Selecting and Installing the Contact Points................................6 Removing the Contact Points................................................6 Training Methods........................................................................6 Linear and Traditional Stimulation.........................................6 Choosing the Correct Intensity Level.....................................6 Customizing the Training Keys...................................................7 Using the Hard Keys for Training Adjustments...........................7 Default Training Settings............................................................7 Collar Training...…

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Cover Letter(s)

Conditions from Section 9 of WT Docket No. 20-115 (1) Garmin must ensure that the part 25 component of its combination part 95 MURS/part 25 satellite handheld device is a provisioned service that requires each end user to first obtain authorization before accessing the satellite service. Page 3 of the user’s manual that is provided with each device instructs the user to create an account and activate the device. Through the activation process, the user obtains authorization. (2) Garmin must include a printed disclosure with its combination part 95 MURS/part 25 satellite handheld device indicating that the part 25 transmission capability of the device is provided by a third-party service provider and must be activated through affirmative action by the consumer. Page 3 of the user’s manual that is provided with the device states that the device communicates with the Iridium satellite network, which is a third-party service. This is also states on Pages 7 - 9 under the “InReach services” Page 3 of the manual states that Iridium is a trademark of Iridium Satellite LLC, which identifies a third party. (3) Notwithstanding today’s Order granting Garmin’s waiver request, Iridium must continue to comply with the conditions of its license, including any limitations on the number of end user terminals or subscriber units. Garmin has a note to Iridium reminding Iridium that they have a responsibility to keep their licensure accurate.

Cover Letter(s)

Federal Communications CommissionDA 20-1071 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of GARMIN INTERNATIONAL, INC. Request for Declaratory Ruling, or in the alternative, Waiver of Section 95.2761(c) of the Commission’s Rules ) ) ) ) ) ) WT Docket No. 20-115 ORDER Adopted: September 21, 2020Released: September 21, 2020 By the Chief, Mobility Division, Wireless Telecommunications Bureau: 1. Introduction. This Order addresses a request filed by Garmin International, Inc. (Garmin) for Declaratory Ruling, or in the alternative, Waiver of section 95.2761(c) of the Commission’s Rules. 1 Garmin seeks relief from section 95.2761(c) in order to obtain authorization for a hand-held device that will combine a low-power, terrestrial Multi-Use Radio Service (MURS) 2 transmitter and an emergency satellite communications module in the same unit. 3 Section 95.2761(c) provides that “[a] grant of equipment certification will not be issued for MURS transmitters capable of operating under both this subpart (MURS) and under any other subparts of this chapter (except part 15).” 4 For the reasons stated below, we deny Garmin’s request for a declaratory ruling, but find that it is in the public interest to grant Garmin’s waiver request, subject to the conditions outlined in this Order. 2. Background. MURS is defined in part 95, subpart J, as “[a] two-way, short distance voice or data communication service for facilitating personal or business activities of the general public.” 5 The Commission established MURS in 2000 when reallocating the service from part 90 to part 95 to eliminate the individual licensing requirements for certain radio services. 6 Garmin intends to manufacture a single unit handheld device with two transmitters: a low-power, terrestrial part 95 MURS transmitter to be used for two-way, short distance data terrestrial communication services and a previously certified part 25 module that will allow SOS emergency communications via the Iridium satellite system under a blanket 1 See Request for Declaratory Ruling or, in the Alternative, Waiver of Section 95.2761(c) of the Commission’s Rules by Garmin International, Inc. (filed April 22, 2020) (https://ecfsapi.fcc.gov/file/1042456803042/Amended%20Garmin%20PDR%20or%20Waiver%20(4-24-20).pdf); Amended Request For Declaratory Ruling Or, In The Alternative, Waiver Of Section 95.2761(C) of the FCC’s Rules, Waiver – Expedited Action Requested by Garmin International, Inc. (filed April 24, 2020) (https://ecfsapi.fcc.gov/file/1042456803042/Amended%20Garmin%20PDR%20or%20Waiver%20(4-24-20).pdf) (Amended Waiver Request). 2 Part 95, subpart J. 3 Amended Waiver Request at 1. 4 47 CFR § 95.2761(c). 5 47 CFR § 95.2703. 6 1998 Biennial Regulatory Review − 47 C.F.R. Part 90 - Private Land Mobile Radio Services, WT Docket No. 91- 182, Report and Order and Further Notice of Proposed Rule Making, 15 FCC Rcd 16673 (2000). Federal Communications CommissionDA 20-1071 2 license held by Iridium, provided the end user subscribes to the Iridium service. 7 On April 24, 2020, Garmin requested that the Commission issue a declaratory ruling that section 95.2761(c) does not apply to its proposed, dual capacity handheld device, or in the alternative, that the Commission waive section 95.2761(c) of its Rules so that Garmin may obtain equipment certification for its device, despite its dual transmitting capability and the fact that it combines a licensed-by-rule service, i.e., MURS with a licensed satellite service. 3. Discussion. The purpose of a declaratory ruling is to terminate a controversy or remove uncertainty, and no such controversy or uncertainty exists here. 8 Garmin argues that section 95.2761(c) “is inapposite to its proposed product” because “it is not meant to prohibit combining into a single unit a certified part 25 module used for emergency satellite communications and a MURS transmitter.” 9 We disagree. As an initial matter, section 95.2761(c) governs Garmin’s proposed device. The provision is clear on its face and does not provide an exception for part 25 modules that do not require separate licensing. 10 It precludes the combination of transmitting equipment, i.e., MURS end products capable of operating under other licensed or licensed-by-rule radio services. The rule states that “[a] grant of equipment certification will not be issued for MURS transmitters capable of operating under both this subpart (MURS) and under any other subparts of this chapter (except part 15).” 11 Garmin’s proposed handheld device possesses the kind of dual capability broadly proscribed by section 95.2761(c). As such, we find that it would not be appropriate to issue a declaratory judgment exempting the device entirely, and we deny Garmin’s request for declaratory relief. 4. We find, however, that it is in the public interest to waive section 95.2761(c) so that Garmin may nevertheless obtain authorization to produce its proposed combination handheld device. Section 1.925 of the Commission's rules provides that we may grant a waiver if it is shown that: (a) the underlying purpose of the rule(s) would not be served or would be frustrated by application to the instant case, and grant of the requested waiver would be in the public interest; or (b) in light of unique or unusual circumstances, application of the rule(s) would be inequitable, unduly burdensome, or contrary to the public interest, or the applicant has no reasonable alternative. 12 5. We find here that Garmin’s proposed device contains an important public safety feature, which would not be brought to market if we were to strictly enforce the rule in this case. “The certified Part 25 module in the MURS unit would allow emergency communications to the outside world at the push of a button.” 13 Second, while Garmin’s device, in fact, combines MURS capability with satellite communications capability, therefore triggering section 95.2761(c), we do not expect it to produce the harm the rule was …

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Cover Letter(s)

Federal Communications Commission Authorization and Evaluation Division 1435 Oakland Mills Road Columbia, MD 21046 Date: March 23, 2020 Subject: FCC application for FCC ID: IPH-03626 To Whom It May Concern: Garmin International Inc. will continue to apply processes and procedures to ensure compliance with 47 CFR 2 requirements regarding products produced under Declaration of Conformity procedures for class B computer peripheral portion as applicable to this composite filing. Thank you, William H. Pertner Lead Compliance Engineer Garmin International, Inc.

Cover Letter(s)

Authority To Act As Agent Date: July 23, 2019 American Certification Body, Inc. 6731 Whittier Avenue Suite C110 McLean, VA 22101 To Whom It May Concern: Nic Johnson of the Nebraska Center for Excellence in Electronics (NCEE Labs) 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. Thank you, Agency Agreement Expiration Date: August 1, 2020 By: William H. Pertner Lead Compliance Engineer Garmin International, Inc.

Cover Letter(s)

Page 1 of 1 Request for Confidentiality Date: September 23, 2020 Subject: Confidentiality Request for: Garmin International, Inc. FCC ID: IPH-03626 Pursuant to FCC 47 CFR 0.457(d) and 0.459 and IC RSP-100, Section 9.4, the applicant requests that a part of the subject FCC application be held confidential. Type of Confidentiality Requested Exhibit ☐ Short Term ☒ Permanent ☐ Not Provided Block Diagrams ☐ Short Term ☐ Not Provided External Photos ☐ Short Term ☐ Permanent ☐ Not Provided Internal Photos ☐ Short Term ☒ Permanent ☐ Not Provided Operation Description/Theory of Operation ☐ Short Term ☐ Permanent ☒ Not Provided Parts List & Placement/BOM ☐ Short Term ☒ Permanent ☐ Not Provided Tune-Up Procedure ☐ Short Term ☒ Permanent ☐ Not Provided Schematics ☐ Short Term ☐ Not Provided Test Setup Photos ☐ Short Term ☐ Permanent ☐ Not Provided User’s Manual The above-mentioned company 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 (if applicable): The applicant requests the exhibits selected above as short term confidential be withheld from public view for 180 days. 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 Provided to IC applications Sincerely, By: __________________________ Nic Johnson, Technical Manager, NCEE Labs

External Photos

EXTERNAL PHOTOS Page 1 of 9 EXTERNAL PHOTOS Page 2 of 9 EXTERNAL PHOTOS Page 3 of 9 EXTERNAL PHOTOS Page 4 of 9 EXTERNAL PHOTOS Page 5 of 9 EXTERNAL PHOTOS Page 6 of 9 EXTERNAL PHOTOS Page 7 of 9 EXTERNAL PHOTOS Page 8 of 9 EXTERNAL PHOTOS Page 9 of 9

ID Label/Location Info

E-Label Information The following specific instructions are provided in the Quick Start Manual that ships with the device Label viewing directions are found in the user manual (outlined here for reference) and available on line at www.garmin.com Getting the Owner's Manual The owner's manual includes instructions for using device features and accessing regulatory information Go to www.garmin.com/manuals/A03626 The following are the specific instructions provided in the owner’s manual that is provided at www.garmin.com/manuals: Device Information Viewing Regulatory and Compliance information. 1 Go to Setup 2 Select About A03626 E-Label The above FCC ID numbers are installed in the factory and are unalterable. This information can also be found printed on the product packaging.

Internal Photos

INTERNAL PHOTOS INTERNAL PHOTOS INTERNAL PHOTOS INTERNAL PHOTOS INTERNAL PHOTOS

RF Exposure Info

© 2019 RF Exposure Lab, LLC This report shall not be reproduced except in full without the written approval of RF Exposure Lab, LLC. 802 N. Twin Oaks Valley Road, Suite 105 • San Marcos, CA 92069 • U.S.A. TEL (760) 471-2100 • FAX (760) 471-2121 http://www.rfexposurelab.com CERTIFICATE OF COMPLIANCE SAR EVALUATION Garmin International, Inc. Dates of Test: November 9-14, 2019 & May 14, 2020 1200 E. 151 st Street Test Report Number: SAR.20191107 Olathe, KS 66062 Revision J This wireless mobile and/or portable device has been shown to be compliant for localized specific absorption rate (SAR) for uncontrolled environment/general exposure limits specified in ANSI/IEEE Std. C95.1-1992 and had been tested in accordance with the measurement procedures specified in IEEE 1528-2013 and IEC 62209-2:2010 (See test report). I attest to the accuracy of the data. All measurements were performed by myself or were made under my supervision and are correct to the best of my knowledge and belief. I assume full responsibility for the completeness of these measurements and vouch for the qualifications of all persons taking them. RF Exposure Lab, LLC certifies that no party to this application is subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 853(a). Jay M. Moulton Vice President Testing Cert. # 2387.01 FCC ID: IPH-03626 Model(s): A03626 Test Sample: Engineering Unit Same as Production Serial Number: Eng 1 Equipment Type: Wireless GPS Location Device Classification: Portable Transmitter Next to Body TX Frequency Range: 1616 – 1626 MHz; 2412 – 2462 MHz, 151.82 – 154.6 MHz Frequency Tolerance: ± 2.5 ppm Maximum RF Output: 1620 MHz – 32.20 dBm; 2450 MHz (b) – 17.00 dBm, 2450 MHz (g) – 13.20 dBm, 2450 MHz (n20) – 12.20 dBm, 150 MHz – 31.76 dBm Conducted & Radiated Signal Modulation: FDMA-FM, DSSS, OFDM, FM Antenna Type: Internal: WiF, External Stubby: Satellite, External Whip: VHF Application Type: Certification FCC Rule Parts: Part 2, 15C, 25, 95 KDB Test Methodology: KDB 447498 D01 v06, KDB 248227 v02r02 Maximum SAR Value: 1.46 W/kg Reported Simultaneous SAR Value: 0.60 W/kg Reported Separation Distance: 0 mm Report Number: SAR.20191107 © 2019 RF Exposure Lab, LLC Page 2 of 92 This report shall not be reproduced except in full without the written approval of RF Exposure Lab, LLC. Table of Contents 1. Introduction ................................................................................................................................... 4 SAR Definition [5] .............................................................................................................................. 5 2. SAR Measurement Setup .............................................................................................................. 6 Robotic System ................................................................................................................................. 6 System Hardware .............................................................................................................................. 6 System Electronics ............................................................................................................................ 7 Probe Measurement System ............................................................................................................. 7 3. Probe and Dipole Calibration ....................................................................................................... 15 4. Phantom & Simulating Tissue Specifications ............................................................................... 16 Head & Body Simulating Mixture Characterization .......................................................................... 16 5. ANSI/IEEE C95.1 – 1992 RF Exposure Limits [2] ........................................................................ 17 Uncontrolled Environment ............................................................................................................... 17 Controlled Environment ................................................................................................................... 17 6. Measurement Uncertainty............................................................................................................ 18 7. System Verification ...................................................................................................................... 19 Tissue Verification ........................................................................................................................... 19 Test System Verification .................................................................................................................. 19 8. SAR Test Data Summary ............................................................................................................ 20 Procedures Used To Establish Test Signal ..................................................................................... 20 Device Test Condition ..................................................................................................................... 20 SAR Data Summary – 150 MHz Body ............................................................................................. 23 SAR Data Summary – 1640 MHz Body Model A03626 Only ........................................................... 24 SAR Data Summary – 2450 MHz Body 802.11b Model A03626 Only ............................................. 25 SAR Data Summary – Simultaneous Evaluation ............................................................................. 26 9. Test Equipment List .....................................…

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Contact Information

Applicant

Ben Karsak(Manager, Compliance Engineering)
[email protected]9134401946Fax: 913 397-8282

Technical Contact

Garmin International Inc.Bill H Pertner
[email protected]9134405471

1200 E 151st Street · Olathe, Kansas · United States

Test Firm

Nebraska Center for Excellence in ElectronicsNic Johnson
[email protected]4023236233Fax: 4024725881

Technical Specifications

#Rule PartsFrequency RangePower OutputEmissionTolerance
195J151.82 MHz - 154.6 MHz1.473 W7K42F1D5.0000000000 ppm
Confidentiality
Long Term
Grant Notes
Output power listed is conducted. This device is authorized in accordance with the Waiver granted in DA 20-1071 on September 21, 2020, as shown in the filing. The highest reported SAR values are: 0.45 W/kg (body) and 0.60 W/kg (simultaneous transmission).

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