IPH-04766Low Power Digital Device Transmitter

Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 Date: June 18, 2024 SUBJECT: FCC Application for FCC ID: IPH-04766 To Whom It May Concern: Garmin will continue to apply processes and procedures to ensure compliance with 47 CFR 2 requirements regarding products produced under Supplier’s Declaration of Conformity procedure for class B computer peripheral portion as applicable to this composite filing. Sincerely, Tim Olson Senior Complianc e Engineer

Rev 1/26/2023 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 USA Date: May 22, 2024 Ref: Attestation Statements Part 2.911(d)(5)(i) Filing FCC ID: IPH-04766 FRN: 0005088588 Garmin International, Inc., (“the applicant”) certifies that the equipment for which authorization is sought is not “covered” eq uipment prohibited fr om receiving an equipment authorization pursuant to section 2.903 of the FCC rules. Sincerely, Ben Karsak

Rev 1/26/2023 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 USA Date: May 22, 2024 Ref: Attestation Statements Part 2.911(d)(7) Filing FCC ID: IPH-04766 Garmin International, Inc., Garmin certifies that, as of the date of t he filing of the application, Garmin International, Inc.. is our designated U.S. agent for service of process for the above referenced FCC ID. Garmin International, Inc., accepts to maintain an agent for no less than one year after the grantee has terminated all marketing and importation or t he conclusion of any Commission-related proceeding involving the equipment. Garmin International, Inc. accepts, as of the date of t he filing of the application, the obligation of the designated U.S. agent for service of process for t he above referenced FCC ID. Designated U.S. Agent Information: FRN: 0005088588 Name: Garmin International, Inc. Address: 1200 East 151 st Street, Olathe, Kansas, 66062 Contact Person: Ben Karsak Tel.: 913-397-1946 Email: [email protected] Sincerely, Garmin International, Inc. Ben Karsak

Rev 1/26/ 2023 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 USA Date: May 22, 2024 Ref: Attestation Statements Part 2.911(d)(5)(ii) Filing FCC ID: IPH-04766 FRN: 0005088588 Garmin International, Inc., (“the applicant”) certifies that, as of the date of the fi ling of the application, the applicant is not identified on the Covered List (as a specifically named entity or any of its subsidiaries or affiliates) as an e ntity producing “covered” equipment. Sincerely, Ben Karsak

Innova tion, Science and Economic Development Canada Certification and Engineering Bureau 3701 Carling Avenue PO Box 11490, Station H Ottawa, Ontario, Canada K2H 8S2 May 22, 2024 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 To Whom It May Concern: Pursuant to 47 CFR 2.911 , Garmin International, Inc. (Garmin) has authorized the following Garmin International Associates to act on Garmin's behalf for the sole and express purpose of processing applications to the Federal Communication Commission (FCC) and Innovation, Science and Economic Development Canada (ISED) for equipment authorization or certification. Mr. William Pertner, Compliance Engineering Team Lead Mr. Jay Everett, Compliance Engineering Team Lead Mr. Richard Kockelkoren, Compliance Engineer Mr. Mike Moranha, Compliance Engineer Ms. Poojita Bhattu, Compliance Engineer Mr. Jeffrey Hailey, Compliance Engineer Mr. Dan Irish, Compliance Engineer Mr. Kiran Kumar, Compliance Engineer Mr. Tim Olson, Compliance Engineer Mr. Jonathan Shafer, Design Certification Engineer Ms. Sara Jones, Design Certification Engineer Mr. Jacky Yeung, Compliance Engineer As such, the Garmin Associates listed above are authorized to: 1) sign Form 731, 2) sign letters of application, 3) request confidentiality, and 4) exchange data and information with the FCC, IC and/ or authorized TCBs on behalf of Garmin. In addition, these individuals shall be considered "authorized individuals" to act on Garmin's behalf where an "authorized individual's" attestation is n ecessary or preferred. This authorization remains in effect until notified to the contrary by Garmin. Sincerely, Be n Karsak Manager Compliance Engineering Garmin International, Inc.

R EQUEST FOR CONFIDENTIALITY D ate: Applicant: Subject: 22 May 2024 Garmin Interna�onal Confiden�ality Request for FCC ID:IPH-04766 IC:1792A-04766 Pursuant to FCC 47 CFR 0.457(d) and 0.459, and IC RSP-100 Sec�on 12.4, we request that a part of the FCC and ISED applica�on be held confiden�al. Type Of Confiden�ality Requested Exhibit ☐Short Term☒Permanent☐Not Provided Block Diagrams ☐Short Term☒Permanent☐Not Provided Schema�cs ☐Short Term☒Permanent☐Not Provided Opera�onal Descrip�on/ Theory of Opera�on ☐Short Term☐Permanent☒Not Provided Parts List & Placement/BOM ☐Short Term☐Permanent☒Not Provided Tune-Up Procedure ☒Short Term☐Permanent☐Not Provided Test Setup Photos ☒Short Term☐Permanent☐Not Provided User’s Manual(s) ☒Short Term☐Permanent☐Not Provided External Photos ☒Short Term☐Permanent☐Not Provided Internal Photos Garm in Interna�onal has spent a substan�al effort in developing this product and it is one of the first of its kind in the industry . Having the subject informa�on easily available to "compe��on" would negate the advantage we have achieved by developing this product. Not protec�ng the details of the design will result in financial hardship. P ermanent Confiden�ality: Garmin requests the exhibits listed above as permanently confiden�al be permanently withheld from public review due to materials that contain trade secrets and proprietary informa�on not customarily released to the public. S hort-Term Confiden�ality (if applicable): The applicant requests the exhibits selected above as short term confiden�al be withheld from public view for a period of 180 days from the date of the Grant of Equipment Authoriza�on and prior to marke�ng. This is to avoid premature release of sensi�ve informa�on prior to marke�ng or release of the product to the public. S incerely, T im Olson Compliance Engineer

Test Report 2024-119 Version A Issued 24 Jun 2024 Project GCL-0407 Model Identifier A04766 Primary Test Standard RSS-102 FCC Parts 2.1091 and 2.1093 Garmin Compliance Lab Garmin International 1200 E 151 st Street Olathe Kansas 66062 USA Client-supplied Information FCC ID: IPH-04766 IC ID: 1792A-04766 See section 6 of this report regarding the presence or absence of accreditation logos or marks on this cover page. Page 2 of 19 GCL Test Report 2024-119 Version A This report may be reproduced in whole. Reproduction of parts or excerpts requires lab management approval. Garmin 1. Summary The equipment or product described in section 5 of this report was tested at the Garmin Compliance Lab according to standards listed in section 6. This report focuses on the RF exposure safety aspects of the transceiver(s). The results are as follows. Parameter Description Key Performance Values [Performance Class] Result Data starts at page Transmit Power The average transmit power presented to the antenna is used to determine the undesired biological effects the test sample could evoke. This data has no Pass or Fail values under this standard, but is used in subsequent analyses. Measured 11 Exemption from routine evaluation Radio emissions at the separation distance are sufficiently low to exempt the radio from a detailed evaluation. The tuned time-averaged EIRP power was below the exemption limit in each case analyzed. Exempt 17 Exposure Reference Level (MPE) Radio emissions at the separation distance are below the exposure reference level where health effects could be a concern. N/A N/A N/A NT (Not Tested) means the requirement may or may not be applicable, but the relevant measurement or test was not performed as part of this test project. N/A (Not Applicable) means the lab judged that the test sample is exempt from the requirement. Table 1: Summary of results Report Organization For convenience of the reader, this report is organized as follows: 1. Summary 2. Test Background 3. Report History and Approval 4. Test Sample Modifications and Special Conditions 5. Description of Equipment Tested 6. Test Standards Applied 7. Measurement Instrumentation Uncertainty 8. Selected Examples of Calculations 9. Environmental Conditions During Test 10. Immunity Performance Criteria Annex: Test records are provided for each type of test, following the order and page numbering stated in the summary table. Concluding notes appear on the final page of this report. Page 3 of 19 GCL Test Report 2024-119 Version A This report may be reproduced in whole. Reproduction of parts or excerpts requires lab management approval. Garmin 2. Test Background 2.1 The Test Lab The testing reported here was performed at the Garmin Compliance Lab, an organization within Garmin International, located at 1200 E 151 st St, Olathe Kansas, USA. The contact telephone number is +1.913.397.8200. 2.2 The Client The testing was performed on behalf of the Garmin design group, a separate organization located at 1200 E 151 st St, Olathe Kansas, USA. Witnesses from the business group included: Tim Olson, Sam Bruner, Patrick Flett. 2.3 Other Information Test Sample received: 04 Mar 2024 Test Start Date: 20 Mar 2024 Test End Date: 28 May 2024 The data in this test report apply only to the specific samples tested. Upon receipt all test samples were believed to be properly assembled and ready for testing. 3. Report History and Approval This report was written by David Arnett and initially issued on 24 Jun 2024 as Version A. Report Technical Review: _________________________________________ David Arnett Technical Lead EMC Engineer Report Approval: _________________________________________ Shruti Kohli Manager Test and Measurement (EMC, Reliability and Calibration) 4. Test Sample Modifications and Special Conditions The following special conditions or usage attributes were judged during test to be necessary to achieve compliance with one or more of the standards listed in section 6 of this report: None The following modifications to the test sample(s) were made, and are judged necessary to achieve compliance with one or more of the standards listed in section 6 of this report: Modification 1 Detailed Description: Update firmware from version 1.1 to 1.2 Date applied: 17 Apr 2024 Reason for this modification: Reduce Tx power slightly on IEEE 802.11 b for PSD conformity to ETSI rules The following tests were performed without this modification being present, and the presence or absence of the modification is judged by the lab and client to have no significant effect on these specific tests: Tests for BLE and for WiFi in G or N modes; For WiFi in B mode - bandwidth tests, radiated emission tests, and various immunity tests were not repeated as a small Tx power reduction would either have no effect or would only create additional margin to the limit. Page 4 of 19 GCL Test Report 2024-119 Version A This report may be reproduced in whole. Reproduction of parts or excerpts requires lab management approval. Garmin 5. Description of the Equipment Tested 5.1 Unique Identification Product Model A04766 Serial Numbers Tested 8A5000017, 8A5000018 This product tested is a device for sensing, data storage, and telemetry. The client affirmed that the test samples will be representative of production in all relevant aspects. 5.2 Key Parameters EUT Input Power: 5 Vdc, often from 12 Vdc sources I/O Ports: USB, microSD Radio Transceivers: IEEE 802.11 b/g/n, Bluetooth Low Energy Radio Receivers: None Primary Functions: Sensing, data storage, communication Typical use: Vehicle mounted Highest internal frequency: 2.484 GHz Firmware Revision 1.20 (See also section 4 of this report) 5.3 Operating modes During test, the EUT was operated in one or more of the following modes. M3 (BleTx). Bluetooth Low Energy radio transmits pseudorandom data continuously on a selected frequency and data rate. M4 (BleLnk). Bluetooth Low Energy radio links to another device according to the standard protoco…

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Test Report 2024-070 Version A Issued 14 Jun 2024 Project GCL-0407 Model Identifier A04766 Primary Test Standard CFR 47, FCC Part 15, Subpart C RSS-247 Issue 3 Garmin Compliance Lab Garmin International 1200 E 151 st Street Olathe Kansas 66062 USA Client-supplied Information FCC ID: IPH-04766 IC ID: 1792A-04766 See section 6 of this report regarding the presence or absence of accreditation logos or marks on this cover page. Page 2 of 77 GCL Test Report 2024-070 Version A This report may be reproduced in whole. Reproduction of parts or excerpts requires lab management approval. Garmin 1. Summary The equipment or product described in section 5 of this report was tested at the Garmin Compliance Lab according to standards listed in section 6. This report focuses on the IEEE 802.11 b/g/n (WiFi) and Bluetooth Low Energy (BLE) transceivers. The results are as follows. Parameter Description Key Performance Values Result Data starts at page Radio Modulation Summary of the kinds of communication this radio can achieve, as stated by the client. [RSS-GEN at Annex A item 10b] Digitally modulated spread spectrum at rates as high as 72 Mbps. Reported N/A Hopping Channels The radio manages it use of channels appropriately. [15.247(a)(1); RSS-247 at 5.1] N/A. The radios described in this report are not subjected to the Frequency Hopping rules. N/A N/A DTS Bandwidth The nature of the radio signal is broadband, being at least 500 kHz wide. [15.247(a)(2); RSS-247 at 5.2(a)] The 6dB bandwidth is 0.698 kHz or greater. PASS 14 Other Bandwidths Regulatory agencies also require the reporting of signal bandwidths using alternate processes. [2.202; RSS-GEN at 6.7] These values are reported but have no actual performance requirements. Reported 18 Transmit Power The peak transmit power presented to the antenna is no greater than 1 Watt or 30 dBm. The effective radiated power is limited to 4 Watts or 36 dBm EIRP. [15.247(b); RSS-247 at 5.4(d)] The maximum transmit power is 19.96 dBm or 98.4 mW. PASS 24 Antenna Gain The radio should not focus too much energy in any direction. Unless additional rules are applied, the antenna gain is no greater than 6 dBi. [15.247(b)(4) and (c)] NT. The client stated that the antenna gain was 0.8 dBi and will document antenna gain separately. NT NT Unwanted Emissions (Conducted Spurious) The radio should not provide too much radio energy to the antenna at frequencies beyond its intended frequency band. [15.247(d); RSS-247 at 5.5] Emissions outside the band must be reduced at least 20 dB from in-band levels. The measured reduction was at least 51 dB. PASS 30 Restricted Bands The radio must not emit in certain designated restricted frequency bands above a set of limit values. [15.247(d) and 15.205; RSS- 247 at 3.3] Emissions in the restricted bands were at least 5.9 dB below the applicable limits. PASS 36 Page 3 of 77 GCL Test Report 2024-070 Version A This report may be reproduced in whole. Reproduction of parts or excerpts requires lab management approval. Garmin Power Spectral Density The radio must not focus too much radio energy in a narrow frequency band. [15.247(e); RSS-247 at 5.2(b)] The limit is 8 dBm in a 3 kHz band. The strongest emission level was measure at -5.11 dBm in a band of at least 3 kHz. PASS 49 Hybrid Systems A radio that is both frequency hopping and digitally modulated should satisfy a combination of system rules. [15.247(f); RSS-247 at 5.3] N/A. The radios described in this report are not subjected to the Hybrid System rules. N/A N/A Frequency Hopping Rules Frequency hopping systems have additional functional requirements. [15.247(g) and (h); RSS-247 at 5.1] N/A. The radios described in this report are not subjected to the Frequency Hopping rules. N/A N/A Radio Safety The radio emissions must meet public health & safety guidelines related to human exposure. [15.247(i) and 1.1307; RSS- Gen at 3.4] NT. Client will report radio energy safety results separately. NT NT Frequency Stability The radio tuning must be robust over a range of temperature and supply voltage conditions. [RSS-Gen at 6.11] Radio emissions remained within the allowed radio band under all environmental conditions tested. PASS 53 Unwanted Emissions (Radiated Spurious) While transmitting, the radiated emissions must not be too strong. [15.209, RSS- Gen at 8.9] Emissions other than the fundamental and harmonics must meet the ‘Class B’ limits. The measured emissions had at least 4.1 dB of margin. PASS 61 Unwanted Emissions (Mains Conducted) While transmitting, the emissions conducted into the power mains must not be too strong. [15.207, RSS-Gen at 8.8] N/A N/A N/A NT (Not Tested) means the requirement may or may not be applicable, but the relevant measurement or test was not performed as part of this test project. N/A (Not Applicable) means the lab judged that the test sample is exempt from the requirement. Table 1: Summary of results Page 4 of 77 GCL Test Report 2024-070 Version A This report may be reproduced in whole. Reproduction of parts or excerpts requires lab management approval. Garmin Report Organization For convenience of the reader, this report is organized as follows: 1. Summary 2. Test Background 3. Report History and Approval 4. Test Sample Modifications and Special Conditions 5. Description of Equipment Tested 6. Test Standards Applied 7. Measurement Instrumentation Uncertainty 8. Selected Examples of Calculations 9. Environmental Conditions During Test 10. Immunity Performance Criteria Annex: Test records are provided for each type of test, following the order and page numbering stated in the summary table. Concluding notes appear on the final page of this report. Due to confidentiality, certain material (such as test setup photographs) has been removed from this report and placed in GCL Test Report 2024-076. That report is treated as a part of this document by way of this reference. Page 5 of 77 GCL Test Report 2024-070 Version A This report may be reproduced in whole. Reproduction of…

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Antenna Data Sheet Antenna Manufacturer Information: The antenna(s) for Garmin Model A04766 is a custom designed and manufactured by Garmin International, Inc. (Garmin) with headquarters located at 1200 E. 151 st Street, Olathe, KS, 66062, USA. Garmin is an antenna manufacturer that specializes in antenna construction and has been a technology leader in high performance antenna design for over thirty years. State-of-the art equipment is used as described below to design, measure, and analyze new designs that are superior to competitor de signs and highly proprietary in nature. Equipment Description: This data sheet contains the antenna gain information for the antenna(s) for Garmin Model A04766. The approximate operational frequency band of these technologies is given, and the maximum gai n within the frequency band is reported. Reported Data: Antenna Model Number Antenna Maximum Gain @ Frequency Antenna Approximate Frequency Band A04766-A1 +0.8dBi @ 2480 MHz 2402 to 2480 MHz Data Sheet Requirements: This data sheet contains the following, as required by the FCC’s Antenna Data Sheet Requirements (Refer to Page 4 of https://transition.fcc.gov/oet/ea/presentations/files/oct22/35-Part-15-Antenna-Updates- TCB_Oct_2022.pdf): •Name and Address of the Manufacturer •Model Number of the Antenna(s) •The Maximum Antenna Gain in the frequency band of operation. Additional Information: Proprietary information regarding antenna design, dimensions, cable length, etc. are provided in the Confidential Operation Description exhibit.