L2VAXC550EXTAXC550 (External) Transceiver

FCC ID: L2VAXC550EXT FCC ID: L2VAXC550EXT

FCC ID: L2VAXC550EXT L.L.C. 2021 Lakeshore Drive · Suite 500 · New Orleans, Louisiana 70122 · (504) 282-8119 · FAX (504) 304 2427 Date: June 1, 2002 Federal Communications Commission Authorization and Evaluation Division Laboratory Division 7435 Oakland Mills Road Columbia, MD 21046 Dear Sir or Madam: In reference to the application under FCC ID L2VAXC550EXT for the Axonn LLC AXC550EXT Axonn External Regulator Transceiver, we hereby request that the following materials submitted with the application be withheld from public disclosure: Exhibit IBlock DiagramsExhibit IIISchematics Each Exhibit covered by the instant request is marked on the cover page to each. In support of its request for confidentiality, the following is stated. The subject device employs the emerging technology, spread spectrum. Research and development of this technology for commercial applications by the public is being explored by a number of entities and companies. The developer of the technology used to produce the instant device, Axonn LLC, has emerged as one of the industry leaders and has gained a competitive edge over its competition by employing creative and functional circuit designs and production methods. This competitive position has been carefully cultivated and promoted to the benefit of Axonn and its licensees of its technology. Axonn LLC foresees that this Axess point shall only be purchased and installed by professionals. We do not currently foresee ourselves making this product available over-the-counter to the average consumer. Axonn LLC has obtained licenses and continues to file for patents to protect each new generation of its spread spectrum technology. However, as the commission is aware, the time period for grant of such protection does not accommodate the need to bring devices to the marketplace. Accordingly, Axonn LLC desires to bring its devices to the marketplace without creating undue risk of duplication of technical, proprietary design. Best Regards, Ahmad Abdelmajid Axonn LLC

FCC ID: L2VAXC550EXT

FCC ID: L2VAXC550EXT FCC ID: L2VAXC550EXT

Wednesday, October 30, 2002 TO: Timothy Johnson US Tech FROM: Bob Davis Principal RF Engineer Axonn LLC RE: AXC550EXT Antenna Gain Query Dear Mr. Johnson: The initial specification for the antennas provided to you by Ahmad Abdelmajid contained a small error for the overall gain of the specified antennas. Please note the typographical error in the first line of the specification and make the changes indicated below: Incorrect Line: 1.) The gain shall be 1 dBd (3.2dBi) or less Corrected Text: 1.) The gain shall be 2.5 dBi or less. I have attached a corrected copy of Ahmad’s original document for your review. Please do not hesitate to call me if there are any further questions. Sincerely, Bob Davis Principal RF Engineer Axonn LLC

Response for Request for information (request sent 10/18/02) for Re: FCC ID: L2VAXC550EXT Applicant: Axonn L.L.C. Correspondence Reference Number: N/A 731 Confirmation Number: N/A 1) Please explain why the Max 3.2dBi antenna was not used for compliance testing. There was an error in the letter addressing this issue. Please see uploaded letter and corrected Test Report. 2) Does this device operate in the 902 to 928 MHz range or does this device operate in the 2.4GHz range? Please note the report is incorrect. On page 22 you state that power was measured from 2.4 to 2.4835 GHz. Table 3 on page 23 shows tabular measurement data of 2.4000, 2.4400 and 2.4835 GHz. Your plots on pages 24, 25 and 26 show data in the 905 to 926 MHz range. Your 731 says the device operates in the 902-928MHz range. Please correct the report and all documentation to provide consistent and accurate data. The device only operates in the 902-928 MHz. Please refer to corrected test report. 3) Your rf exposure statement is incorrect. You state the use of an internal antenna with gain of 0dBi. This device is listed as having external antenna(s) of up to 3.2dBi gain. Please provide a corrected rf exposure statement showing the correct calculations for MPE. This has been corrected. 4) Please provide evidence that you have an agreement from the FCC that it is OK to remove the regulator from the module. This should also address the issue if the FCC has required you to test the device in all configurations or if the configuration you tested is adequate. From our discussions, you have verified with the FCC that this should be ok for a limited modular approval to the manufacturer.

American Telecommunications Certification Body Inc. 6731 Whittier Ave, McLean, VA 22101 October 21, 2002 RE: FCC ID: L2VAXC550EXT Attention: Timothy Johnson I have a few comments on this Application. 1 Please explain why the Max 3.2dBi antenna was not used for compliance testing. 2 Does this device operate in the 902 to 928 MHz range or does this device operate in the 2.4GHz range? Please note the report is incorrect. On page 22 you state that power was measured from 2.4 to 2.4835 GHz. Table 3 on page 23 shows tabular measurement data of 2.4000, 2.4400 and 2.4835 GHz. Your plots on pages 24, 25 and 26 show data in the 905 to 926 MHz range. Your 731 says the device operates in the 902-928MHz range. Please correct the report and all documentation to provide consistent and accurate data. 3 Your rf exposure statement is incorrect. You state the use of an internal antenna with gain of 0dBi. This device is listed as having external antenna(s) of up to 3.2dBi gain. Please provide a corrected rf exposure statement showing the correct calculations for MPE. 4 Please provide evidence that you have an agreement from the FCC that it is OK to remove the regulator from the module. This should also address the issue if the FCC has required you to test the device in all configurations or if the configuration you tested is adequate. Dennis Ward mailto:[email protected] The items indicated above must be submitted before processing can continue on the above referenced application. Failure to provide the requested information may result in application termination. Correspondence should be considered part of the permanent submission and may be viewed from the Internet after a Grant of Equipment Authorization is issued. Please do not respond to this correspondence using the email reply button. In order for your response to be processed expeditiously, you must submit your documents through the AmericanTCB.com website. Also, please note that partial responses increase processing time and should not be submitted. Any questions about the content of this correspondence should be directed to the sender.

FCC ID: L2VAXC550EXT PHOTOS OF THE TESTED EUT The following photos are attached: Photo 1.EUT, Top View Photo 2.EUT, Top View - Shield Removed Photo 3.EUT, Bottom View Photo 4. Antennas FCC ID: L2VAXC550EXT Photo 1.EUT, Top View Photo 2.EUT, Top View - Shield Removed FCC ID: L2VAXC550EXT FCC ID: L2VAXC550EXT Photo 3.EUT, Bottom View FCC ID: L2VAXC550EXT Photo 4. Antennas Astron AXH92RTSM 2.2 dBi Astron AXH92RTSMS 2.2 dBi Antenex DEXP92RTSM 2.5 dBi

FCC ID: L2VAXC550EXT Labe l FCC ID: L2VAXC550EXT

FCC ID: L2VAXC550EXT PHOTOS OF THE TESTED EUT The following photos are attached: Photo 1.EUT, Top View Photo 2.EUT, Top View - Shield Removed Photo 3.EUT, Bottom View Photo 4. Antennas FCC ID: L2VAXC550EXT Photo 1.EUT, Top View Photo 2.EUT, Top View - Shield Removed FCC ID: L2VAXC550EXT FCC ID: L2VAXC550EXT Photo 3.EUT, Bottom View FCC ID: L2VAXC550EXT Photo 4. Antennas Astron AXH92RTSM 2.2 dBi Astron AXH92RTSMS 2.2 dBi Antenex DEXP92RTSM 2.5 dBi

FCC ID: L2VAXC550EXT GENERAL INFORMATION 1.1Product Description The Equipment Under Test (EUT) is the Axonn L.L.C.’s, Model AXC550 (External), Rev B Transmitter. The EUT utilizes direct sequence spread spectrum technology for communication on the following channels: 905.58, 908.58, 911.58, 914.58, 917.58, 920.58, 923.58, and 926.58 MHz. The transmitter modulation incorporates BPSK modulation for generating a direct-sequence, spread spectrum carrier. The data modulation for the device utilizes either OOK or BPSK data modulation techniques as selectable by the user application. The EUT it identical to a previously approved version (which was modularly approved under FCC ID: L2VAX550) with the exception that one of the regulators has been removed from the transmitter board and is to be implemented by the outside host devices and this version also incorporates external antennas. This application is being submitted in order to approve the EUT as a stand-alone limited modular approval (limited for use within Axonn L.L.C. products only) since Axonn will maintain control of the final products and ensure that the transmitter module is fully supplied with the proper external regulated voltage. Please refer to the following letter from Axonn L.L.C. FCC ID: L2VAXC550EXT FCC ID: L2VAXC550EXT

FCC ID: L2VAXC550EXT 6.1 RF Safety Requirements to 2.1091 for Mobile Transmitters The EUT is being submitted for modular approval. However, due to the design of the transmitter and low duty cycle the manufacturer only expects the EUT to be used in mobile environment. The unit under evaluation has an integral antenna of +2.5 dBi gain with a measured output power output of 0.135 Watts at the antenna terminals. Taking into consideration the gain of the antenna, the corrected EIRP is 240 mW. The MPE calculations are shown as follows: The limits for this unit (uncontrolled exposure) are 0.62 mW/cm 2 (928 MHz/1500). Taking the RF Density Field Equation: S = EIRP (mW)/(4πR 2 ) and solving for Distance R R = SQRT(EIRP (mW)/(S4π)) Plugging in data yields R (cm) = SQRT (135 (mw)/(0.6 (mW/cm 2 )*4*π) ) = 5.6 cm The RF Density equation shows that the minimum separation distance to be 5.6 cm. Since the EUT is considered by the manufacture to be a mobile unit, which by definition specifies that the antenna distance is greater than 20 cm, the manual therefore incorporates a caution statement that states that the unit should only be used when a separation of 20 cm is maintained between the antenna and users. This ensures compliance with the MPE requirements.

Axonn L.L.C. FCC Part 15, Certification Application AXC550 (External), Rev B Transmitter UST Project: 02-0267 September 12, 2002 MEASUREMENT/TECHNICAL REPORT COMPANY NAME:Axonn L.L.C. MODEL:AXC550 (External), Rev B Transmitter FCC ID:L2VAXC550EXT DATE:September 12, 2002 This report concerns (check one): Original grant X Class II change_____ Equipment type: Direct Sequence Spread Spectrum (Modular) Deferred grant requested per 47 CFR 0.457(d)(1)(ii)? yes_____ No X If yes, defer until:_________________ date N.A. agrees to notify the Commission by N.A. date of the intended date of announcement of the product so that the grant can be issued on that date. Report prepared by: United States Technologies, Inc. 3505 Francis Circle Alpharetta, GA 30004 Phone Number: (770) 740-0717 Fax Number: (770) 740-1508 FCC ID: L2VAXC550EXT TABLE OF CONTENTS AGENCY AGREEMENT LETTER OF CONFIDENTIALITY SECTION 1 GENERAL INFORMATION 1.1 Product Description 1.2 Related Submittal(s) SECTION 2 TESTS AND MEASUREMENTS 2.1 Configuration of Tested EUT 2.2 Test Facility 2.3 Test Equipment 2.4 Modifications 2.5 Test Procedure and Results 2.6 Antenna Description 2.7 Peak Power (Antenna Conducted at Antenna Terminal) 2.8 Antenna Conducted Spurious Emissions 2.9 Peak Radiated Spurious Emissions 2.10 Average Radiated Spurious Emissions 2.11 Minimum 6 dB Bandwidth 2.12 Power Spectral Density 2.13 Power Line Conducted Emissions for Transmitter 2.14 Radiated Emissions for Digital Device & Receiver (if Applicable) 2.15 Power Line Conducted for Digital Device & Receiver SECTION 3 LABELING INFORMATION SECTION 4 BLOCK DIAGRAM(S)/ SCHEMATIC(S) SECTION 5 PHOTOGRAPHS SECTION 6 RF EXPOSURE INFORMATION SECTION 7 USER'S MANUAL FCC ID: L2VAXC550EXT LIST OF FIGURES AND TABLES 1)Test Configuration 2) Photograph(s) for Spurious and Digital Device Emissions 3) Peak Power Output 4) Antenna Conducted Spurious Emissions 5) Peak Radiated Spurious Emissions 6) Average Radiated Spurious Emissions 7) Minimum 6 dB Bandwidth 8) Power Spectral Density TABLES 1)EUT and Peripherals 2) Test Instruments 3) Peak Power Output 4) Peak Radiated Spurious Emissions 5) Average Radiated Spurious Emissions 6) Power Spectral Density 7) Conducted Emissions Data (Transmitter) 8) Radiated Emissions Data (Digital Device) 9) Conducted Emissions Data (Digital Device) FCC ID: L2VAXC550EXT SECTION 1 GENERAL INFORMATION FCC ID: L2VAXC550EXT GENERAL INFORMATION 1.1Product Description The Equipment Under Test (EUT) is the Axonn L.L.C.’s, Model AXC550 (External), Rev B Transmitter. The EUT utilizes direct sequence spread spectrum technology for communication on the following channels: 905.58, 908.58, 911.58, 914.58, 917.58, 920.58, 923.58, and 926.58 MHz. The transmitter modulation incorporates BPSK modulation for generating a direct-sequence, spread spectrum carrier. The data modulation for the device utilizes either OOK or BPSK data modulation techniques as selectable by the user application. The EUT it identical to a previously approved version (which was modularly approved under FCC ID: L2VAX550) with the exception that one of the regulators has been removed from the transmitter board and is to be implemented by the outside host devices and this version also incorporates external antennas. This application is being submitted in order to approve the EUT as a stand-alone limited modular approval (limited for use within Axonn L.L.C. products only) since Axonn will maintain control of the final products and ensure that the transmitter module is fully supplied with the proper external regulated voltage. Please refer to the following letter from Axonn L.L.C. FCC ID: L2VAXC550EXT FCC ID: L2VAXC550EXT FCC ID: L2VAXC550EXT 1.2Related Submittal(s)/Grant(s) The EUT will be used with part of a system to send/receive data. The transmitter presented in this report will be used with similar transceivers or previously approved receivers. The EUT is subject to the following authorizations: a) Certification as a transmitter (limited modular approval) The information contained in this report is presented for the certification authorization for the EUT. FCC ID: L2VAXC550EXT SECTION 2 TESTS AND MEASUREMENTS FCC ID: L2VAXC550EXT TEST AND MEASUREMENTS 2.1 Configuration of Tested System The sample was tested per ANSI C63.4, Methods of Measurement from Low-Voltage Electrical and Electronic Equipment in the Range of 9 kHz to 40 GHz (1992). Conducted and radiated emissions data were taken with the test receiver or spectrum analyzer's resolution bandwidth adjusted to 9 kHz and 120 kHz, respectively. All measurements are peak unless stated otherwise. The video filter associated with the spectrum analyzer was off throughout the evaluation process. Interconnecting cables were manipulated as necessary to maximize emissions. Interconnecting cables were manipulated as necessary to maximize emissions. A block diagram of the tested system is shown in Figure 1. Test configuration photographs for spurious and fundamental emissions are shown in Figure 2. The sample used for testing was received by U.S. Technologies on July 30, 2002 in good condition. 2.2 Test Facility Testing was performed at US Tech's measurement facility at 3505 Francis Circle, Alpharetta, GA. This site has been fully described and submitted to the FCC, and accepted in their letter marked 31040/SIT. Additionally this site has also been fully described and submitted to Industry Canada (IC), and has been approved under file number IC2982. 2.3 Test Equipment Table 2 describes test equipment used to evaluate this product. 2.4 Modifications No modifications were made by US Tech, to bring the EUT into compliance with FCC Part 15 limits for the transmitter portion of the EUT. FCC ID: L2VAXC550EXT FIGURE 1 TEST CONFIGURATION Transceiver (EUT) Interface Box AC Adapter 6' u To Laptop for Control Commands as Necessary 6' s 120 VAC, 60 Hz Direct Plug In 3' u 3 @ 6” s to Antennas (1 TX, 2 RX) FCC ID: L2VAXC550EXT Test Date:August 5 - August 9, 2002 UST Proj…

Text truncated - open the document above for the full version.

FCC ID: L2VAXC550EXT Test Date:August 5 - August 9, 2002 UST Project:02-0267 Customer:Axonn L.L.C. Model:AXC550 (External), Rev B Transmitter FIGURE 2a Photograph(s) for Spurious Emissions (Front) EUT Interface Box FCC ID: L2VAXC550EXT Test Date:August 5 - August 9, 2002 UST Project:02-0267 Customer:Axonn L.L.C. Model:AXC550 (External), Rev B Transmitter FIGURE 2b Photograph(s) for Spurious Emissions (Back) FCC ID: L2VAXC550EXT Test Date:August 5 - August 9, 2002 UST Project:02-0267 Customer:Axonn L.L.C. Model:AXC550 (External), Rev B Transmitter FIGURE 2c Photograph(s) for Digital Device/Receiver Emissions (Front) FCC ID: L2VAXC550EXT Test Date:August 5 - August 9, 2002 UST Project:02-0267 Customer:Axonn L.L.C. Model:AXC550 (External), Rev B Transmitter FIGURE 2d Photograph(s) for Digital Device/Receiver Emissions (Back) FCC ID: L2VAXC550EXT Test Date:August 5 - August 9, 2002 UST Project:02-0267 Customer:Axonn L.L.C. Model:AXC550 (External), Rev B Transmitter FIGURE 2e Photograph(s) for Conducted Emissions Transmitter FCC ID: L2VAXC550EXT Test Date:August 5 - August 9, 2002 UST Project:02-0267 Customer:Axonn L.L.C. Model:AXC550 (External), Rev B Transmitter FIGURE 2f Photograph(s) for Conducted Emissions Receiver