N7NMC8785850/900/1800/1900/2100 MHz multi-band Module

Sierra Wireless America, Inc 2290 Cosmos Ct. Carlsbad CA, 92011 Tel. 760-476-8700 Fax 760-476-8701 AUTHORIZATION LETTER DATE: 20 February , 2007 Compliance Certification Services Certification Division 47173 Benicia Street Fremont, CA 94538 To whom it may concern: We, the undersigned, hereby authorize the Testing Division of Compliance Engineering Services, Inc., d.b.a. Compliance Certification Services and hereafter referred to as CCS, to act on our behalf in all manners relating to application for equipment authorization, including signing of all documents relating to these matters. Any and all acts carried out by CCS on our behalf shall have the same effect as acts of our own. We, the undersigned, hereby certify that we are not 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). In authorizing CCS Testing Division as our agent, we still recognize that we are responsible to: a) comply with the relevant provisions of the certification program; b) make all necessary arrangements for the conduct of the evaluation, including provision for examining documentation and access to all areas, records (including internal audit reports) and personnel for the purposes of evaluation (e.g. testing, inspection, assessment, surveillance, reassessment) and resolution of complaints; c) make claims regarding certification only in respect of the scope for which certification has been granted; d) do not use our product certification in such a manner as to bring the Certification Division into disrepute and not make any statement regarding our product certification which the Certification Division may consider misleading or unauthorized; e) upon suspension or cancellation of certification, discontinue use of all advertising matter that contains any reference thereto and return any certification documents as required by the Certification Division; f) use certification only to indicate the products are certified as being in conformity with specified standards; g) endeavor to ensure that no certificate or report nor any part thereof is used in a misleading manner; h) ensure that any reference to our product certification in communication media such as documents, brochures or advertising, complies with the requirements of the Certification Division; i) keep a record of all complaints made known to the us relating to the product’s compliance with requirements of the relevant standard and to make these records available to the Certification Division when requested; j) take appropriate action with respect to such complaints and any deficiencies found in products or services that affect compliance with the requirements for certification; k) document the actions taken. This authorization is valid until further written notice from the applicant. Sincerely, Todd Van Cleave Manager Engineering Services Carlsbad Research & Development Sierra Wireless America, Inc.

January 8, 2008 Federal Communications Commission Authorization and Standards Division 7435 Oakland Mills Road Columbia, MD 21046 RE: Authorization Letter for Grantee Code N7N Dear Sir/Madam: I hereby authorize Mr. Todd Van Cleave of Sierra Wireless to act on my behalf in all manners relating to the application for equipment authorization including signing of all documents relating to these matters. Any and all acts carried out by Mr. Todd Van Cleave of Sierra Wireless on my behalf shall have the same effect as acts of my own. Sincerely, Ying Wang Staff Regulatory Specialist

January 17, 2008 Compliance Certification Services Certification Division 47173 Benicia Street Fremont, CA 94538 USA To whom it may concern: I, the undersigned, hereby authorize Ms. Claire Hoque /Application Examiner of Compliance Engineering Services, Inc., d.b.a. Compliance Certification Services and hereafter referred to as CCS, to act on our behalf in submitting our application for the FCC equipment authorization. I, the undersigned, hereby certify that we are not 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). This authorization is valid until further written notice from Sierra Wireless. Sincerely Yours, Ying Wang Staff Regulatory Specialist

January 16, 2008 Federal Communications Commission Authorization and Standards Division 7435 Oakland Mills Road Columbia, MD 21046 To Whom It May Concern: Re: Confidentiality Request for FCC ID: N7NMC8785 We hereby request that the exhibits listed below, submitted with our application for certification, be withheld from public disclosure. This request is made under the provisions of Section 0.457(d) and 0.459 of the Commission’s Rules, and Section 552(b)(4) of the Freedom of Information Act. We cite trade secrets as the reason and purpose of the request. • Schematics • Block Diagram • Operation Description • Tune Up Procedure Furthermore, pursuant to Public Notice DA 04-1705 in order to comply with the marketing regulations in 47 CFR §2.803 and the importation rules in 47 CFR §2.1204, we request the following exhibits be withheld from public viewing for a short limited time of 45 days from the date of the Grant of Equipment Authorization, due to the sensitive business information: • User Guide • Product Photos • Test Setup Photos Best Regards Ying Wang Staff Regulatory Specialist

Request for Modular Approval FCC ID: N7NMC8785 Item Requirements EUT 1 The final device is designed for mobile or fixed operation (Portable is not permitted – Reference TCB Exclusion List (17 July 2002) II (g)). This Modem module will be installed in a host product where the transmitting antenna can provide 20cm separation distance to the body of user. This module is sold to OEM and will only be installed by OEM or OEM authorized installer. Install this module in a portable configuration is not allowed unless proper equipment authorization has obtained. 2 The maximum antenna gain to allow compliance with RF exposure requirements is listed on the Grant of Certification for the module. The antenna gain including cable loss must not exceed 5 dBi in Cellular band and 4 dBi in PCS band, for purposes of 2.1043 and 2.1091. Above MPE estimate is based upon the measured peak conducted output power. MPE estimate is submitted via separate RF exposure attachment. 3 The licensed module must have a FCC ID label on the module itself. That FCC ID label must be visible through a window on the final device or it must be visible when an access panel, door or cover is easily removed. If not, a second label must be placed on the outside of the final device that contains the following text: Contains “FCC ID: N7NMC8785” Please refer to the FCC ID label format. Labeling instruction has been provided in the OEM installation instruction. 4 The Grant should include the following words in the device description or grant notes: “modular transmitter” or “transmitter module”. Modular approval is requested for this application.

answer: 07U11543 TCB question: Sierra Wireless Inc., FCC ID: N7NMC8785, Assessment NO.: AN08T7520, Notice#1 Inbox X Claire Hoque to Timothy, Tim, Timothy, Thu, Chi show details 4:36 PM (1 minute ago) Reply Hi Tim, Pls see answer below. Thanks, Claire -----Original Message----- From: Timothy M. Dwyer Sent: Thursday, January 24, 2008 7:54 PM To: Thu Chan; Claire Hoque Cc: Timothy M. Dwyer Subject: Sierra Wireless Inc., FCC ID: N7NMC8785, Assessment NO.: AN08T7520, Notice#1 Hello Thu, Claire, The review of this application is complete. Please reply to the following items. Q1 : Frequency, power and emission information was not entered in the FCC application. Please confirm that the information for this application is identical to information supplied for the related IC application AN08I2299. Please also provide the frequency tolerance in PPM to be listed on the grant for Part 22 and 24. Reviewers are not allowed to make changes to the application information without authorization of the applicant or agent. I have tentatively entered information in the application form pending your confirmation. <answer>yes, power data is same as IC portion, thanks for your help. Q2: Please confirm that ANSI/TIA/EIA-603-B-2002 test methods were used for measurements reported in the Sierra Wireless test report. The test report does not specify the test methods used. <answer from client> We have never been requested for such a confirmation, not even for the applications submitted directly to the FCC. We understand that FCC lists ANSI/TIA/EIA-603-B-2002 as one of the measurement techniques under Licensed Devices. However FCC states that it is a non-exclusive list of measurement techniques that may be used when testing equipment to determine its compliance with FCC rules. This list is provided as a reference tool to aid interested parties in locating measurement techniques. Any party making measurements to show compliance with the FCC rules should select the appropriate measurement methods as required and specified in the particular part of the FCC rules. We confirm the measurements reported in the Sierra Wireless test report were performed per the test methods in FCC Part 2, 22 and 24. It is also our understanding that FCC only requires test labs to use the substitution method for the radiated spurious emission measurement as specified in ANSI/TIA/EIA- 603-B-2002 (now superseded by TIA-603-C-2004) . There's no requirement to use ANSI/TIA/EIA-603-B-2002 for other measurements such as occupied bandwidth, frequency stability, etc. In fact this standard only applies to radio equipment used in the Private (Dispatch) Land Mobile Services that employ FM or PM modulation, for transmission of voice or data using analog or digital techniques, with a frequency of 1 GHz or less. The items indicated above must be submitted before processing can continue on the above referenced application. Failure to provide the requested information within 30 days of the original e-mail date may result in application dismissal and forfeiture of the filing fee. 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 e-mail address listed below the name of the sender. Best regards, Tim Dwyer Technical Reviewer

PROPOSED FCC ID LABEL FOR HOST DEVICE SIERRA WIRELESS, INC. This device contains N7NMC8785

Evaluation of RF Exposure for MC8785V Wireless Modem as a Mobile Device In this application we seek modular approval to the MC8785V wireless modem for use in mobile configuration. Based on the FCC OET Bulletin 65 Supplement C and 47 CFR §2.1091, we have concluded that the MC8785V will comply with the FCC rules on RF exposure for mobile devices if the antenna gain does not exceed 5 dBi in cellular band and 4 dBi in PCS band. The following analysis will demonstrate such compliance. The analysis will be done in two US bands. Operation in cellular band (824 – 849 MHz) The peak conducted output power of MC8785V in Cellular band is 32 dBm. Take the worst case as an example, in which an antenna with 5 dBi gain is used. The resulted power density at a distance of 20 cm can be deducted as follows: EIRP = 32 + 5 = 37 dBm = 5012 mW Power Density = EIRP*DutyCycle/(4 πR 2 ) = 5012*0.5/(4*π*20 2 ) = 0.50 mW/cm 2 where DutyCycle is 0.5 for GPRS operation (the worst case) and R is 20 cm. The MPE limit for General Population/Uncontrolled Exposure is shown in the FCC OET Bulletin 65 Supplement C and can be calculated as follows: MPE limit = 824/1500 = 0.55 mW/cm 2 As we can see the resulted power density is below the MPE limit, therefore MC8785V in Cellular band is compliant with the FCC rules on RF exposure. Operation in PCS band (1850 – 1910 MHz) The peak conducted output power of MC8785V in PCS band is 29 dBm. Take the worst case as an example, in which an antenna with 4 dBi gain is used. The resulted ERP can be expressed as follows: ERP = 29 + 4 –2.15 = 30.85 dBm (1.22 W) < 3 W The FCC OET Bulletin 65 Supplement C states that mobile devices identified in 47 CFR §2.1091 that operate at frequencies above 1.5 GHz with an ERP of 3.0 watts or more are required to perform routine environmental evaluation for RF exposure prior to equipment authorization or use; otherwise, they are categorically excluded. As we can see this resulted ERP is below 3 W, therefore routine environmental evaluation for RF exposure prior to equipment authorization or use for MC8785V in PCS band is categorically excluded.

 2007 Sierra Wireless, Inc. This document contains information which is proprietary and confidential to Sierra Wireless, Inc. Disclosure to persons other than the officers, employees, agents, or subcontractors of the Company or licensee of this document without the prior written permission of Sierra Wireless, Inc. is strictly prohibited. MC8785V Test Report FCC Part 22, 24 / IC RSS 132, 133 FOR FCC and IC Certifications IC: 2417C-MC8785 FCC ID: N7NMC8785 Prepared by SIERRA WIRELESS INC. 13811 WIRELESS WAY RICHMOND, BC V6V 3A4 CANADA Test Date(s): November 26, 2007 - December 4, 2007 SIERRA WIRELESS, INC. FCC Part 22, 24 / RSS 132, 133 MC8785V Dec 31, 2007 Page 2 of 77  2007 Sierra Wireless, Inc. The contents of this page are subject to the confidentiality information on page one. Table of Contents 1 Introduction and Purpose....................................................................... 3 2 Test Summary ....................................................................................... 3 3 Description of Equipment Under Test ................................................... 4 4 RF Power Output .................................................................................. 4 4.1 Test Procedure .................................................................................................... 4 4.2 Test Equipment.................................................................................................... 5 4.3 Test Results GSM/EDGE .................................................................................... 5 4.4 Test Results UMTS .............................................................................................. 5 4.4.1 Test 1: RF Output Power Results for WCDMA R99................................... 5 4.4.2 Test 2: RF Output Power Results for HSDPA Rel6.................................... 6 4.4.3 Test 3: RF Output Power Results for HSPA (HSDPA & HSUPA) Rel6..... 8 4.5 Test Settings for UMTS Mode on CMU200 ...................................................... 10 5 Occupied Bandwidth ........................................................................... 14 5.1 Test Procedure .................................................................................................. 14 5.2 Test Results ....................................................................................................... 14 5.3 Test Plots........................................................................................................... 15 6 Out of Band Emissions at Antenna Terminals ..................................... 24 6.1 Test Procedure .................................................................................................. 24 6.2 Test Equipment.................................................................................................. 24 6.3 Test Results ....................................................................................................... 24 6.4 Test Plots........................................................................................................... 26 7 Block Edge Compliance...................................................................... 62 7.1 Test Procedure .................................................................................................. 62 7.2 Test Equipment.................................................................................................. 62 7.3 Test Results ....................................................................................................... 62 7.4 Test Plots........................................................................................................... 63 8 Frequency Stability Versus Temperature............................................. 69 8.1 Summary of Results........................................................................................... 69 8.2 Test Procedure .................................................................................................. 69 8.3 Test Equipment.................................................................................................. 69 8.4 Test Results ....................................................................................................... 70 9 Frequency Stability Versus Voltage .................................................... 74 9.1 Summary of Results........................................................................................... 74 9.2 Test Procedure .................................................................................................. 74 9.3 Test Equipment.................................................................................................. 74 9.4 Test Results ....................................................................................................... 75 SIERRA WIRELESS, INC. FCC Part 22, 24 / RSS 132, 133 MC8785V Dec 31, 2007 Page 3 of 77  2007 Sierra Wireless, Inc. The contents of this page are subject to the confidentiality information on page one. 1 Introduction and Purpose This document provides the MC8785V wireless modem test data for the FCC and Industry Canada certifications. The tests included in this report are limited to all conducted tests required. The radiated tests were performed at an external test facility. 2 Test Summary FCC RULE DESCRIPTION OF TEST RESULT PAGE 2.1046 RF Power Output Complies 5 2.1049 Occupied Bandwidth Complies 14 2.1051, 22.901(d) 22.917, 24.238(a) Out of Band Emissions at Antenna Terminals Complies 24 FCC Part 22H/24E Block Edge Requirements Complies 62 2.1053 Field Strength of Spurious Radiation Complies See CCS Report 2.1055 Frequency Stability versus Temperature Complies 69 2.1055 Frequency Stability versus Voltage Complies 74 The tests described in this report were performed by Mr. Hari Shankar Shukla at: Sierra Wireless, Inc. 13811 Wireless Way Richmond, B.C. V6V 3A4 Canada SIERRA WIRELESS, INC. FCC Part 22, 24 / RSS 132, 133 MC8785V Dec 31, 2007 Page 4 of 77  2007 Si…

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FCC CFR47 PART 22H AND 24E & INDUSTRY CANADA RSS-132 AND RSS-133 CERTIFICATION TEST REPORT FOR 850/900/1800/1900/2100 MHZ MULTI-BAND MODULE MODEL NUMBER: MC8785V FCC ID: N7NMC8785 IC: 2417C-MC8785 REPORT NUMBER: 07U11543-1 ISSUE DATE: JANUARY 09, 2008 Prepared for SIERRA WIRELESS INC. 13811 WIRELESS WAY RICHMOND, BC V6V 3A4, CANADA Prepared by COMPLIANCE CERTIFICATION SERVICES 47173 BENICIA STREET FREMONT, CA 94538, U.S.A. TEL: (510) 771-1000 FAX: (510) 661-0888 REPORT NO: 07U11543-1 DATE: JANUARY 09, 2008 FCC ID: N7NMC8785 IC: 2417C-MC8785 Page 2 of 23 COMPLIANCE CERTIFICATION SERVICES FORM NO: CCSUP4031B 47173 BENICIA STREET, FREMONT, CA 94538, USA TEL: (510) 771-1000 FAX: (510) 661-0888 This report shall not be reproduced except in full, without the written approval of CCS. Revision History Rev. Issue Date Revisions Revised By -- 01/09/08 Initial Issue T. Chan REPORT NO: 07U11543-1 DATE: JANUARY 09, 2008 FCC ID: N7NMC8785 IC: 2417C-MC8785 Page 3 of 23 COMPLIANCE CERTIFICATION SERVICES FORM NO: CCSUP4031B 47173 BENICIA STREET, FREMONT, CA 94538, USA TEL: (510) 771-1000 FAX: (510) 661-0888 This report shall not be reproduced except in full, without the written approval of CCS. TABLE OF CONTENTS 1. ATTESTATION OF TEST RESULTS.................................................................................... 4 2. TEST METHODOLOGY ........................................................................................................ 5 3. FACILITIES AND ACCREDITATION.................................................................................... 5 4. CALIBRATION AND UNCERTAINTY .................................................................................. 5 4.1. MEASURING INSTRUMENT CALIBRATION ............................................................... 5 4.2. MEASUREMENT UNCERTAINTY................................................................................ 5 5. EQUIPMENT UNDER TEST ................................................................................................. 6 5.1. DESCRIPTION OF EUT................................................................................................ 6 5.2. SOFTWARE AND FIRMWARE..................................................................................... 7 5.3. DESCRIPTION OF TEST SETUP............................................................................... 10 6. TEST AND MEASUREMENT EQUIPMENT ....................................................................... 12 7. LIMITS AND RESULTS ...................................................................................................... 13 7.1. FIELD STRENGTH OF SPURIOUS RADIATION ....................................................... 13 8. SETUP PHOTOS................................................................................................................. 22 REPORT NO: 07U11543-1 DATE: JANUARY 09, 2008 FCC ID: N7NMC8785 IC: 2417C-MC8785 Page 4 of 23 COMPLIANCE CERTIFICATION SERVICES FORM NO: CCSUP4031B 47173 BENICIA STREET, FREMONT, CA 94538, USA TEL: (510) 771-1000 FAX: (510) 661-0888 This report shall not be reproduced except in full, without the written approval of CCS. 1. ATTESTATION OF TEST RESULTS COMPANY NAME: SIERRA WIRELESS INC. 13811 WIRELESS WAY RICHMOND, BC V6V 3A4, CANADA EUT DESCRIPTION: 850/900/1800/1900/2100 MHz MULTI-BAND MODULE MODEL: MC8785V SERIAL NUMBER: S5628970083E2-0L DATE TESTED: JANUARY 2-3, 2007 APPLICABLE STANDARDS STANDARD TEST RESULTS FCC PART 22H and 24E AND IC RSS-132 ISSUE 2 and RSS-133 ISSUE 3 No Non-Compliance Noted (Radiated Portion) Compliance Certification Services, Inc. tested the above equipment in accordance with the requirements set forth in the above standards. The test results show that the equipment tested is capable of demonstrating compliance with the requirements as documented in this report. Note: The results documented in this report apply only to the tested sample, under the conditions and modes of operation as described herein. This document may not be altered or revised in any way unless done so by Compliance Certification Services and all revisions are duly noted in the revisions section. Any alteration of this document not carried out by Compliance Certification Services will constitute fraud and shall nullify the document. No part of this report may be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any government agency. Approved & Released For CCS By: Tested By: THU CHAN MENGISTU MEKURIA EMC SUPERVISOR EMC ENGINEER COMPLIANCE CERTIFICATION SERVICES COMPLIANCE CERTIFICATION SERVICES REPORT NO: 07U11543-1 DATE: JANUARY 09, 2008 FCC ID: N7NMC8785 IC: 2417C-MC8785 Page 5 of 23 COMPLIANCE CERTIFICATION SERVICES FORM NO: CCSUP4031B 47173 BENICIA STREET, FREMONT, CA 94538, USA TEL: (510) 771-1000 FAX: (510) 661-0888 This report shall not be reproduced except in full, without the written approval of CCS. 2. TEST METHODOLOGY The tests documented in this report were performed in accordance with TIA/EIA 603C (2004), FCC CFR 47 Part 2, and FCC CFR 47 Part 22H, 24E, RSS-GEN, RSS132, & RSS133. 3. FACILITIES AND ACCREDITATION The test sites and measurement facilities used to collect data are located at 47173 Benicia Street, Fremont, California, USA. CCS is accredited by NVLAP, Laboratory Code 200065-0. The full scope of accreditation can be viewed at http://www.ccsemc.com . 4. CALIBRATION AND UNCERTAINTY 4.1. MEASURING INSTRUMENT CALIBRATION The measuring equipment utilized to perform the tests documented in this report has been calibrated in accordance with the manufacturer's recommendations, and is traceable to recognized national standards. 4.2. MEASUREMENT UNCERTAINTY Where relevant, the following measurement uncertainty levels have been estimated for tests performed on the apparatus: PARAMETER UNCERTAINTY Radiated Emission, 30 to 200 MHz +/- 3.3 dB Radiated Emission, 200 to 1000 MHz +4.5 / -2.9 dB Radiated Emission, 1000 to 2000 MHz +4.5 / -2.9 dB Power Line Conducte…

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REPORT NO: 07U11543-1 DATE: JANUARY 09, 2008 FCC ID: N7NMC8785 IC: 2417C-MC8785 Page 22 of 23 COMPLIANCE CERTIFICATION SERVICES FORM NO: CCSUP4031B 47173 BENICIA STREET, FREMONT, CA 94538, USA TEL: (510) 771-1000 FAX: (510) 661-0888 This report shall not be reproduced except in full, without the written approval of CCS. 8. SETUP PHOTOS RADIATED RF MEASUREMENT SETUP RADIATED FRONT PHOTO REPORT NO: 07U11543-1 DATE: JANUARY 09, 2008 FCC ID: N7NMC8785 IC: 2417C-MC8785 Page 23 of 23 COMPLIANCE CERTIFICATION SERVICES FORM NO: CCSUP4031B 47173 BENICIA STREET, FREMONT, CA 94538, USA TEL: (510) 771-1000 FAX: (510) 661-0888 This report shall not be reproduced except in full, without the written approval of CCS. END OF REPORT RADIATED BACK PHOTO