L2V-PT3Handheld, Satellite Based Personal Tracking Unit

1 SPOT Gen3 USer GUide S.O.S. Tracking Check in Help/SPOT Assist 3 GPS satellites provide signals. SPOT determines your GPS location and sends your location and pre-programmed message to communication satellites. Communication satellites relay your message to specific satellite antennas around the world. Satellite antennas and a global network route your location and message to the appropriate network. Your location and messages are delivered according to your instructions via email, text message, or emergency notification to the GEOS International Emergency Response Coordination Center. 1 HOW SPOT WORKS 2 3 4 5 2 Powered by Google Maps™ When SPOT sends a text or email message to one of your contacts or to GEOS, it includes your GPS coordinates and a web link (email only) to view your location using Google Maps™. Welcome to the SPOT Family! SPOT devices provide satellite-based messaging capability so everyone who enjoys the great outdoors can communicate from remote locations around the globe, beyond the reach of cell phones. Pretty cool, huh? SecTiOn 1: WeLcOMe To begin using SPOT, we recommend you spend a few minutes reading through this User Guide, then visit FindMeSPOT.com to select a service plan and activate your SPOT device. SPOT needs a clear view of the sky to obtain a GPS signal to provide the most accurate location information. SPOT is not as reliable indoors, at the bottom of a deep canyon, in a cave, or in very dense woods. Sunshine is more fun anyway! Orienting SPOT so that the SPOT logo is facing up toward the sky will improve performance as the antenna is located directly under the logo. The coolest adventurers place SPOT on their backpacks. In order to ensure best performance, do not use SPOT immediately adjacent to other GPS devices. Here are a FeW iMPOrTanT THinGS TO reMeMber abOuT yOur SPOT Gen3 45 WHaT yOu need • Your SPOT Gen3 • One of these three power sources: - 4 AAA Energizer ® Ultimate Lithium 8x batteries (L92); included - 4 AAA Energizer ® NiMH rechargeable batteries (NH12) - Line Power with a 5v USB connection • User Guide inSTall THe included baTTerieS 1. Loosen the screws to open the battery cover. 2. Write down the ESN and Authorization Code for use during service activation. 3. Install 4 AAA Energizer ® Ultimate Lithium 8x batteries or NiMH rechargeable batteries. 4. Replace cover, tighten screws with a screwdriver or coin. It is important that you fully tighten the battery cover to maintain SPOT's waterproof seal. WHaT yOu need • Personal contact information • Emergency contact information • Valid email address • Credit card information • SPOT electronic serial number (ESN) and authorization code. accOunT SeTuP 1. Go to FindMeSPOT.com/activate. 2. Existing SPOT customers should login to their current SPOT account to add their new device. New customers will need to select: Set up new account. 3. Follow the instructions given within the activation portal; do not skip forms or pages. 4. Choose the services you wish to add (like the new upgraded Unlimited and Extreme Tracking) to your SPOT device and confirm your order to finish the activation process. Your SPOT Gen3 requires an active SPOT subscription to communicate. To do this, simply activate your device using the instructions outlined below. SecTiOn 2: GeTTinG STaRTed WiTH yOur SPOT aT FindMeSPOT.cOM ESN: 0-0000000 Auth: 00000000 These codes are located inside the battery compartment of your SPOT Gen3. You will need these codes when setting up your account on FindMeSPOT.com/activate. Serial nuMber (eSn) and auTHOrizaTiOn cOde elecTrOnic Serial nuMber (eSn) auTHOrizaTiOn cOde HelP/SPOT aSSiST cuSTOM MeSSaGe TracK S.O.S cHecK in HelP/SPOT aSSiST Request help from your friends & family at your GPS location. Or ask for help from professional assistance organizations. (Example: Flat tire, need a lift.) cuSTOM MeSSaGe Let contacts know where you are by sending a pre-programmed message with your GPS location. S.O.S. In an emergency, send an S.O.S. with your GPS location to GEOS, who facilitates search and rescue. (Example: Snake bite, broken leg) cHecK in Let contacts know where you are and that you’re okay with a pre-programmed message. TracK Automatically send and save your location and allow contacts to track your progress using Google Maps ™ . POWer Press the power button to turn SPOT on; LEDs will illuminate. Press and hold the power button until it blinks rapidly to turn SPOT off. GPS liGHT Notifies you whether or not SPOT is able to see the GPS satellites & obtain your GPS location. MeSSaGe SendinG liGHT Notifies you whether or not your most recent message was transmitted. SecTiOn 3: funcTiOnS 67 89 InItIal SyStem teSt Perform an initial system test to evaluate your messaging system, from the operational condition of the SPOT to the readiness of those you’ve chosen to receive your messages. Once you have set-up the message contacts for SPOT Gen3 in your FindmeSPOt.com account, go outside where SPOT has a clear view of the sky in all directions. Turn SPOT on - press and hold the Power button; lights will illuminate. Press and hold the Check In button until the function light blinks green. Leave SPOT outdoors. The GPS light will blink green as SPOT acquires a GPS fix. Once SPOT acquires your GPS location, the Message Sending light and GPS light will blink green in unison for 15 seconds to notify you that your message is being transmitted with your GPS location. The Message Sending light will continue to blink green until the message cycle is complete. Verify that the message was received in the email or SMS account(s) in your Check In contact list. You can also view your sent messages in your account at FindmeSPOt.com. POwer There are three ways you can power your SPOT: 4 AAA Energizer Ultimate Lithium 8x batteries (included), 4 AAA NiMH rechargeable batteries, or with line power through a 5v USB connection. Insert batteries or attach the USB cable to your SPOT and a power source. Please note: NiMH batte…

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Page 1 of 2 FCC ID: L2V-PT3 IC ID: 3989A-PT3 CT Project: p1310017 From: Chris Harvey Date: June 18, 2013 1. This seems to be a portable, battery operated Satellite transmitter, which should be subject to SAR compliance, but no SAR RF exposure exhibit provided. Exhibits for 20cm separation Power Density calculation have been provided, but this seems inappropriate for this handheld device. Previous versions had very low duty cycles and therefore SAR testing was not required per justification. CT – The RF exposure report has been updated to include additional detail regarding SAR exclusion. 2. Internal Photos do not show the overall construction of this device, but just the PC Boards. Please provide additional photos with the enclosure open and battery installed and removed.... Spot – Customer provided additional photos 6/18 3. The FCC form 731 indicated Equipment Class TNB, but TNT – Worn on Body is more appropriate. CT – Form 731 corrected 4. You have supplied an FCC Part 15 Subpart B compliance report. Please note that because the labeling has the FCC DoC logo, it is assumed that this report is not included in this application and will not officially be reviewed. It is also noted that because this device has a USB port that can be used for powering the device, AC Conducted Emissions is required. If this device can also communicate through the USB port, then Class B Computer Peripheral compliance should be sought (test setup would include computer system per ANSI C63.4). CT – The Part 15B report was sent in error, please disregard. 5. The report lists a Bandwidth Correction Factor of 3.2, but does not indicate how this is obtained or why it is used. Please elaborate. CT – The bandwidth correction formula 10log(RBW/OBW) was used to determine the appropriate measurements considering the plots were taken with a 1MHz RBW. The test has been edited to include this information. 10log(1/2.046) = 3.2 6. Also, the calculated EIRP uses antenna gains that look inconsistent across a 7MHz span (ranges from 0.60dBi to 0.09dBi). Please confirm antenna gain. CT – The customer provided swept the antenna gain plots which were used by CTL. Page 2 of 2 7. The Reports document conducted measurements and a calculated EIRP. The Grant should list the conducted emissions as measured (precedent from previous approvals too), which is 19.74dBm, or 0.094W. CT – The grant will list conducted power but most measurements from part 25 list the limits as EIRP. To maintain consistency within the test report fundamental EIRP is listed. 8. The Label indicates Model PT3, but the RSP-100 Appendix A Application Form and Appendix B Test Report Cover Sheet indicate model Spot 3. These models listed must match (even though there is a naming attestation letter). CT – Appendix A & B have been corrected 9. The RSP-100 Appendix B Test Report Cover Sheet shows Emission Designator as 2M04G1D, but the Necessary BW should be rounded up to become 2M05. Please correct. CT – Appendix B has been corrected Response by: John Erhard & Alex Macon Submitted by: Amanda Reed Date: 6/20/2013

Page 1 of 1 FCC ID: L2V-PT3 IC ID: 3989A-PT3 CT Project: p1310017 From: Chris Harvey Date: June 24, 2013 You are apparently using the low-duty-cycle analysis to qualify for SAR exemption, which will require a PBA filing (see KDB 388624 D02 v13, item B.20.) CT – A PBA will be filed for this device per the PBA procedures. The separation distance of 19mm is stated in this exhibit but it is not justified or measured. Please justify this stated separation distance. CT – A CAD drawing shoring the separation distance has been provided. The SAR exemption at 15mm is stated as 37mW, but there is no indication of where this limit comes from or any calculations to obtain this limit. CT – This exemption comes from KDB 447498 Appendix A which is indicated at the top of page 4 of the test report. The Duty Cycle analysis needs some correction. SAR exemptions should use the conducted power as the basis for determining SAR applicability, not the EIRP. You should review KDB 447498 D01 v05r01 section 6.3 for low transmission duty factor devices. CT – Section 6.3 of KDB 447498 indicates that a worst case of maximum output power and minimum separation distance must be used. There is no indication that this must be conducted power and as there is a slight antenna gain in this system EIRP is the worst case. The antenna separation distance chosen for this calculation is 2 mm less than the actual separation distance. For both items the most stringent possible combination was chosen. Section 4.1 (2) does indicate that maximum conducted average power applies to SAR but this is incongruent with the worst case clause in section 6.3. Because of this and other statements throughout KDB 447498 indicating that a worst case analysis must always be applied EIRP was used. Additionally this is a patch antenna which is permanently attached to the transmitter and in application the end user will most assuredly be exposed to the source based time average power in EIRP. Please note that the FCC will review this SAR exemption exhibit under the PBA requirement so you should provide as much detail and justification as possible CT – Noted Response by: John Erhard Submitted by: Amanda Reed Date: 7/16/2013

Page 1 of 1 FCC ID: L2V-PT3 IC ID: 3989A-PT3 CT Project: p1310017 From: Chris Harvey Date: July 18, 2013 1. You provided an ‘antenna separation’ drawing exhibit in response to the need for clarity in selecting the 19mm as the antenna separation to the user for RF Exposure calculation. The drawing exhibit seems to show the side cut-away view of the EUT (please confirm) with 2 distances shown Dist: 26.187mm dY: 0.537mm CT – for some reason the original CAD drawing did not convert to a pdf correctly and ended up as a truncated image without the rest of the information required. A new version of this has been generated with all the information and an explanation of the dimensions including calculations. 2. The drawing does not clearly show the antenna (is it the red line?) or what these distances are with respect to the user, and does not seem to justify the 19mm stated or the 15mm apparently used in the RF Exposure exemption calculation. Please clarify the antenna separation exhibit and indicate how it justifies the 19mm used. CT – See item 1. 3. Thank you for telling me that you used the exclusion calculation from KDB 447498 section 4. Now show me the calculation as I asked. CT – The source based time averaged power has been included in the RF exposure test report which shows that the power level is significantly below the SAR exemption level from KDB 447498 section 4. If there is a different calculation required please indicate where this I may find the requirement. 4. Because this application is to be submitted to the FCC for PBA review you are welcome to not make the clarifications I have requested and submit this directly to the FCC under the PBA for their further guidance as you wish. CT – Noted Response by: John Erhard Submitted by: Amanda Reed Date: 7/18/2013

Page 1 of 2 Internal Photos: FCC ID: L2V-PT3 IC: 3989A-PT3 Distance from front face of antenna to front face of plastic (mm): 3.68 3.52 2.48 (min) 4.60 (max) Page 2 of 2

p1310017_FCC_Part 1.1310_Rev 7.0 Page 1 of 4 Test Report Prepared for: Spot, LLC Model: Spot 3 Description: Handheld, Satellite Based Personal Tracking Unit To FCC Part 1.1310 Date of Issue: May 7, 2013 On the behalf of the applicant: Spot, LLC 300 Holiday Square Blvd. Covington, LA 70433 Attention of: Eric Blanchard, Senior Design Engineer Ph.: (985)335-1513 E-Mail: [email protected] Prepared By Compliance Testing, LLC 3356 N San Marcos Pl, Suite 107 Chandler, AZ 85225-7176 (866) 311-3268 phone / (480) 926-3598 fax www.compliancetesting.com Project No: p1310017 Alex Macon Project Test Engineer This report may not be reproduced, except in full, without written permission from Compliance Testing All results contained herein relate only to the sample tested p1310017_FCC_Part 1.1310_Rev 7.0 Page 2 of 4 Test Report Revision History Revision Date Revised By Reason for Revision 1.0 May 7, 2013 Alex Macon Original Document 2.0 June 20, 2013 John Erhard Update to provide SAR exclusion calculations 3.0 July 16, 2013 John Erhard Update to EIRP/Duty Cycle calculation 4.0 August 31, 2013 John Erhard Include timing diagram 5.0 September 16, 2013 John Erhard Edit per FCC guidance 6.0 September 27, 2013 John Erhard Edit per FCC guidance 7.0 September 27, 2013 John Erhard Edit per FCC guidance p1310017_FCC_Part 1.1310_Rev 7.0 Page 3 of 4 ILAC / A2LA Compliance Testing, LLC, has been accredited in accordance with the recognized International Standard ISO/IEC 17025:2005. This accreditation demonstrates technical competence for a defined scope and the operation of a laboratory quality management system (refer joint ISO-ILAC-IAF Communiqué dated January 2009) The tests results contained within this test report all fall within our scope of accreditation, unless noted below. Please refer to http://www.compliancetesting.com/labscope.html for current scope of accreditation. Testing Certificate Number: 2152.01 FCC OATS Rag, #933597 IC Reg. #2044A-1 Non-accredited tests contained in this report: N/A p1310017_FCC_Part 1.1310_Rev 7.0 Page 4 of 4 This is a portable device as it is a hand-held satellite transmitter with the Low Duty Cycle SAR exclusion from KDB 447498 Appendix A being applied. Duty Cycle Calculation Maximum on time = 1.44 Second Minimum time between transmissions = 150 Seconds Duty Cycle = 0.96% (On time / Time between transmissions) *100 = Duty Cycle (1.44 / 150)*100 = 0.96 Satellite Transmitter Duty Cycle Timing Diagram Spot Gen3 has a worst case duty cycle in 5 minute “Track Mode”. In this mode of operation, the device first obtains a GPS fix which typically takes anywhere from 15 seconds to 4 minutes at roughly 30 mA. After obtaining a fix, the GPS receiver is shutdown and the TCXO clock source is turned on and allowed to stabilize (roughly 1 second). Then the device transmits the first of two 1.44 second long satellite messages which draws roughly 250mA. After 6 seconds of delay, it sends the second message which contains redundant GPS information from previous points for improved reliability. The device then goes into a sleep state until the remainder of the 5 minute period elapses and the cycle repeats as illustrated in the timing diagram below. 1.44 seconds * 2 messages / 300 second period = .0096 -> 0.96% duty cycle Exclusion Ratio Formula 1 from Section 4.3.1 of KDB 447498 D01 0 50 100 150 200 250 300 0 25 50 75 100 125 150 175 200 225 250 275 300 325 350 375 400 425 450 475 500 525 550 575 Current (mA) Time (sec) Spot Gen3 Maximum Duty Cycle p1310017_FCC_Part 1.1310_Rev 7.0 Page 5 of 4 [(conducted max. power of channel in mW*duty cycle)/(test separation distance in mm)] * (√f(GHz) (97*0.0096/5) * (√1.611) = Exclusion Ratio (0.186) * (1.27) = Exclusion Ratio 0.23 = Exclusion Ratio Exclusion Threshold = 3.0 The final ratio of 0.23 is below the exclusion threshold of 3.0 therefore SAR testing is excluded. Mechanical Information Minimum test separation distance = 5 mm Minimum test separation distance is less than 5mm, so default value of 5mm is used per Formula 1 PER the exclusion requirement of KDB 447498 a SAR measurement is not necessary. END OF TEST REPORT

p1310017_FCC_Part 25_Rev 3.0 Page: 1 of 30 Test Report Prepared for: SPOT, LLC Model: Spot 3 Description: Handheld, Satellite Based Personal Tracking Unit To FCC Rule Part 25 Date of Issue: April 17, 2013 On the behalf of the applicant: SPOT, LLC 300 Holiday Square Blvd. Covington, LA 70433 Attention of: Eric Blanchard, Sr. Design Engineer Ph: (985) 335-1513 E-Mail: [email protected] Prepared By Compliance Testing, LLC 3356 N San Marcos Pl, Suite 107 Chandler, AZ 85225-7176 (866) 311-3268 phone / (480) 926-3598 fax www.compliancetesting.com Project No: p1310017 Alex Macon Project Test Engineer This report may not be reproduced, except in full, without written permission from Compliance Testing All results of this test report relate only to the item(s) there were tested p1310017_FCC_Part 25_Rev 3.0 Page: 2 of 30 Test Report Revision History Revision Date Revised By Reason for Revision 1.0 April 17, 2013 Alex Macon Original Document 2.0 May 30, 2013 John Erhard Draft reports inadvertently provided to the manufacturer 3.0 June 20, 2013 John Erhard Add bandwidth correction factor to power measurement p1310017_FCC_Part 25_Rev 3.0 Page: 3 of 30 Table of Contents Description Page Standard Test Conditions and Engineering Practices 5 Test Result Summary 6 Power Limits 7 Emissions Limitations for Mobile Earth Stations 8 Occupied Bandwidth 11 Emission Masks 14 Emissions Limits for Mobile Earth Stations 19 Frequency Tolerance (Temperature Variation) 29 Test Equipment Utilized 30 p1310017_FCC_Part 25_Rev 3.0 Page: 4 of 30 ILAC / A2LA Compliance Testing, LLC, has been accredited in accordance with the recognized International Standard ISO/IEC 17025:2005. This accreditation demonstrates technical competence for a defined scope and the operation of a laboratory quality management system (refer joint ISO-ILAC-IAF Communiqué dated January 2009) The tests results contained within this test report all fall within our scope of accreditation, unless noted below. Please refer to http://www.compliancetesting.com/labscope.html for current scope of accreditation. Testing Certificate Number: 2152.01 FCC OATS Reg, #933597 IC Reg. #2044A-1 Non-accredited tests contained in this report: N/A p1310017_FCC_Part 25_Rev 3.0 Page: 5 of 30 Test and Measurement Data All tests and measurement data shown were performed in accordance with FCC Rules and Regulations, Volume II; Part 2 and the following individual Parts: FCC Part 25 Satellite Communications. Standard Test Conditions and Engineering Practices Except as noted herein, the following conditions and procedures were observed during the testing: In accordance with ANSI C63.4-2009, section 6.1.9, and unless otherwise indicated in the specific measurement results, the ambient temperature of the actual EUT was maintained within the range of 10° to 40°C (50° to 104° F) unless the particular equipment requirements specify testing over a different temperature range. Also, unless otherwise indicated, the humidity levels were in the range of 10% to 90% relative humidity. Environmental Conditions Temp (ºC) Humidity (%) Pressure (mbar) 25.2° C – 28.8° C 21.9% - 27.1% 951.3 – 970.2 Measurement results, unless otherwise noted, are worst case measurement. EUT Description Model: Spot 3 Description: Handheld, Satellite Based Personal Tracking Device Additional Information The EUT is a handheld personal satellite tracking system for use in a wilderness environment. EUT Operation during Tests EUT is placed in a test mode allowing for frequency selection via mode using a dip switch settings provided by the manufacturer. Accessories: None Cables: None Modifications: None p1310017_FCC_Part 25_Rev 3.0 Page: 6 of 30 Test Result Summary Specification Test Name Pass, Fail, N/A Comments 25.204 Power Limits Pass 25.202(f) Emissions Limitations for Mobile Earth Stations Pass 25.202(f) Emissions Mask Pass 25.216(c)(g)(i) Emissions Limits for Mobile Earth Stations Pass 25.202(d) Frequency Tolerance Pass p1310017_FCC_Part 25_Rev 3.0 Page: 7 of 30 Power Limits Name of Test: Power Limits Specification: 25.204 Engineer: Alex Macon Test Equipment Utilized: i00008, i00331 Test Date: 4/11/2013 Test Procedure The UUT was connected to a Spectrum analyzer through a 20 dB attenuator. Attenuator and cable losses were input into the analyzer as a reference level offset to ensure accurate measurements were obtained. All measurements were made in a 1 MHz RBW. The EIRP is a summation of the conducted power, the antenna gain, and the bandwidth correction factor. BW correction factor = 10log(1/2.046) = 3.2 Test Setup Transmitter Peak Output Power Tuned Frequency (MHz) Conducted Output Power (dBm) Antenna Gain (dBi) Bandwidth CF (dB) EIRP Output Power (dBm) Specification Limit 1611.25 18.22 0.59 3.2 22.01 No limit for Mobile Earth Stations 1613.75 19.72 0.60 3.2 23.52 No limit for Mobile Earth Stations 1616.25 19.72 0.53 3.2 23.45 No limit for Mobile Earth Stations 1618.75 19.74 0.09 3.2 23.03 No limit for Mobile Earth Stations EUT Spectrum Analyzer 20 dB Attenuator p1310017_FCC_Part 25_Rev 3.0 Page: 8 of 30 Emissions Limitations for Mobile Earth Stations Name of Test: Emissions Limitations for Mobile Earth Stations Specification: 25.202(f) Engineer: Alex Macon Test Equipment Utilized: i00008, i00331 Test Date: 04/08/2013 Test Procedure The EUT was connected directly to a spectrum analyzer and the conducted spurious emissions were measured to ensure that the EUT met the requirements specified. Only the worst case emission at each frequency was reported. Attenuator losses were input into the analyzer as a reference level offset to ensure accurate measurements were obtained. Test Setup Emissions Limitations Summary Table Tuned Frequency (MHz) Result Comments 1611.25 Pass See Plots 1613.75 Pass See Plots 1616.25 Pass See Plots 1618.75 Pass See Plots EUT Spectrum Analyzer 20 dB Attenuator p1310017_FCC_Part 25_Rev 3.0 Page: 9 of 30 Emissions Limitations Plot 1611.25 MHz Emissions Limitations Plot 1613.75 MHz p13…

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Page 1 of 2 Test Setup Photos: Spot, LLC FCC ID: L2V-PT3 IC: 3989A-PT3 Radiated Emissions Radiated Emissions Page 2 of 2 Receiver Test Transmitter Test