M3N-65981411ECU Unit for Easy Key PASE System

Re: Certification for Siemens 5WY7369 Transmitter Model: 5WY7369 FCC ID: M3N-65981411 IC: 267F-659814 USER'S MANUAL INFORMATION (PRELIMINARY) The User's Manual is in preparation. The following material will be contained in the manual: FCC ID: M3N-65981411 IC: 267F-659814 This device complies with Part 15 of the FCC Rules and with RSS-210 of Industry Canada. 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. WARNING: Changes or modifications not expressively approved by the party responsible for compliance could void the user's authority to operate the equipment. The term “IC:” before the radio certification number only signifies that Industry Canada technical specifications were met.

125kHz (PASE), 128kHz (Immobilizer) Console Driver Door Pass. Door Trunk CID 315MHz 315 MHz Receiver Block 455kHz Logic Block 8.19MHz LF (PASE) Driver and Relay Block LF (Immobilizer) Driver Block 455kHz 4.095MHz

RE: Siemens Automotive Corporation FCC ID: M3N-65981411 The following is in response to the comments made on the above referenced Application. 1) This device consists of a UHF 315 MHz RX and LF 125 kHz TX/RX. This application is only requesting Certification of the 125 kHz TX (the 125 kHz RX portion does not fall under the scope of Part 15). Note that the 315 MHz UHF RX is considered a separate RX under 15.101 and not part of a transceiver. Therefore this portion of the device must be approved under a DoC or Certification. Please provide further information regarding which authorization is being utilized for the RX. The 315 MHz receiver used in this module has been Authorized previously in Germany under a DoC. 2) Please provide a photograph underneath the shield of the RX. Since the (shielded) 315 MHz receiver is not subject to Authorization procedures in this application (see (1) above) there is no need to proved photos of the RX under the shield. 3) The label contains an FCC logo and the phrase “Tested to Comply With FCC Standards”. It appears that the device may be subjected to a DoC for the RX (see 1 above). However, please note that to approve a device under a DoC, the RX testing must be performed by an accredited lab (NLAP or A2LA, etc). Please explain. Please see (1) above. 4) Section 5.2 of the test report states that the RBW was usually 1 kHz which contradicts page 6 which states 9 kHz. According to ANSI C63.4, the RBW in this range should be greater than or equal to 100 Hz for 9 kHz to 150 kHz and 9 kHz for 150 kHz to 30 MHz. Please provide further information regarding use of the RBW to ensure that accurate amplitude readings were taken. Your comment is noted and reports will be clarified for future applications. As a rule, we make measurements at a specified RBW, but when the signal is near the noise floor, or near an ambient, we reduce the bandwidth, and at the same time verifying that the signal is narrow-band and that the readings are not affected by the reduction in bandwidth. 5) The ASK modulation does not necessarily look Manchester encoded. Additionally, because this is actually ASK modulation and not OOK, a 50% duty cycle assumption may not be correct since there is no guarantee the data bit length is 50%. Please provide further information regarding the modulation and duty cycle. We agree that, since the third pulse in the pulse train is wider than the normal double pulse, the system does not appear Manchester encoded. This may reduce the duty factor by a fraction of a dB. However, the DTU will still meet the limits by some 60 dB. 6) According to the bandwidth measured, it appears that part of the bandwidth falls in the 90 – 110 kHz restricted band. Note that the FCC considers all emissions within 26 dB of the fundamental to be modulation products and are therefore part of the fundamental. Therefore all emissions that fall in the restricted band must be < 26 dB below the fundamental, regardless of the power level at the fundamental. We agree that at 110 kHz the spectrum is down only 18dB (p. 8, Report #415031-167A). Please note that this is the second sidelobe of a sin(x)/x pattern, and FCC has accepted the argument that the sidelobes can be considered as spurious and not part of the fundamental emission. Siemens has performed an experiment evaluating the operation of the system with reduced bandwidth that demonstrates the sidelobes are not essential for operation of the system. The experiment write-up is attached. Siemens EasyKey LF PASE Transmitter (5WY7369) Attn: Dr. Valdis Leipa 8/01/03 Radiation Laboratory / EECS University of Michigan Ann Arbor, MI 48109-2122 Ph: (734) 483-4211 This report shows the results of a demonstration that the secondary side lobes and beyond are not required for proper operation of the EasyKey system. Measurements were taken at the Siemens VDO lab using a "custom" laboratory modulator centered at 125kHz and data generated by the ECU (electronic control unit). A tuned ferrite antenna was used for transmitting the information. The results of modulation are shown in the plot below (fig. 1). (Fig. 1) The maximum lower side lobe (105.1kHz) is 29.58dB down from the center frequency power level. The EasyKey system successfully operated with the suppression of this side lobe. Successful operation was monitored using test software to ensure an appropriate transmission to and response from the CID (customer identification device). Siemens EasyKey LF PASE Transmitter (5WY7369) A resonant circuit was not implemented in the EasyKey system for this function due to the following reasons: 1. Resonant antennas would result in too much ringing which would lower the maximum data rate. 2. The center frequency would not be nearly as stable due to component tolerances. The variation in center frequency would greatly vary the output power resulting in an unreliable system. 3. Using resonant antennas in this system would be cost prohibitive due to the type and size of components required to handle the high voltage levels. Kind Regards, Matthew Doyle 4685 Investment Drive Troy, MI 48098

American Telecommunications Certification Body Inc. 6731 Whittier Ave, McLean, VA 22101 July 7, 2003 RE: Siemens Automotive Corporation FCC ID: M3N-65981411 After a review of the submitted information, I have a few comments on the above referenced Application. 1) This device consists of a UHF 315 MHz RX and LF 125 kHz TX/RX. This application is only requesting Certification of the 125 kHz TX (the 125 kHz RX portion does not fall under the scope of Part 15). Note that the 315 MHz UHF RX is considered a separate RX under 15.101 and not part of a transceiver. Therefore this portion of the device must be approved under a DoC or Certification. Please provide further information regarding which authorization is being utilized for the RX. 2) Please provide a photograph underneath the shield of the RX. 3) The label contains an FCC logo and the phrase “Tested to Comply With FCC Standards”. It appears that the device may be subjected to a DoC for the RX (see 1 above). However, please note that to approve a device under a DoC, the RX testing must be performed by an accredited lab (NLAP or A2LA, etc). Please explain. 4) Section 5.2 of the test report states that the RBW was usually 1 kHz which contradicts page 6 which states 9 kHz. According to ANSI C63.4, the RBW in this range should be greater than or equal to 100 Hz for 9 kHz to 150 kHz and 9 kHz for 150 kHz to 30 MHz. Please provide further information regarding use of the RBW to ensure that accurate amplitude readings were taken. 5) The ASK modulation does not necessarily look Manchester encoded. Additionally, because this is actually ASK modulation and not OOK, a 50% duty cycle assumption may not be correct since there is no guarantee the data bit length is 50%. Please provide further information regarding the modulation and duty cycle. 6) According to the bandwidth measured, it appears that part of the bandwidth falls in the 90 – 110 kHz restricted band. Note that the FCC considers all emissions within 26 dB of the fundamental to be modulation products and are therefore part of the fundamental. Therefore all emissions that fall in the restricted band must be < 26 dB below the fundamental, regardless of the power level at the fundamental. Timothy R. Johnson Examining Engineer 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.

267F-659814

General Product Information Design Location: Siemens VDO Automotive 4685 Investment Drive Troy, MI 48098 Manufactured Location: Siemens VDO S.A. de C.V. Camino a la Tijera # 3 Km 3.5 Carretera Guadalajara-Morelia C.P. 45640 Mpio. Tlajomulco de Zúñiga, Jalisco Mexico Device ID: GM Easy Key 215 ECU ID: 5WY7369 General Description The Easy Key PASE system consists of a CID (Customer Identification Device), an ECU (Electronic Control Unit), and 4 passive ferrite antennas. The ECU transmits information to the CID through a 125kHz ASK carrier and the CID transmits information to the ECU through a 315MHz ASK carrier. The passive antennas are used to transmit the 125kHz. The system allows for PASE (Passive Start and Entry) and well as RKE (Remote Keyless Entry). Passive entry is initiated by lifting the door handle. The ECU will then generate a 125kHz field, which the CID will read and respond back to the ECU via 315MHz. The keypad on the CID can be used for RKE, where pushing a button transmits a command at 315MHz. Passive start is initiated by pressing the start button inside the vehicle. As with passive entry, the ECU generates a 125kHz signal and the CID responds back with a 315MHz signal. A backup for instances where RF is not possible is through limphome mode with the CID. In this case, the CID is placed near a designated ferrite antenna and the ECU generates a 125kHz field. The CID will respond back by dampening the field through absorption modulation. Power Supply The ECU is powered by the vehicle battery. Typical Usage Pattern 110 PASE operations in 24 hours with a total transmission length of 5.5 seconds Transmitter ON 0.23 seconds/hour Transmitter OFF 3599.77 seconds/hour Duty Cycle: T ON / T (ON+OFF) X100% = 0.23/3599.77X100% = 0.006%

DUT on OATS Close-up on the DUT on OATS 10