PD5LMWP200RBWireless 2.4 GHz PCMCIA Card

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American Telecommunications Certification Body Inc. 6731 Whittier Ave, McLean, VA 22101 January 13, 2003 RE: Delta Networks, Inc. FCC ID: PD5LMWP200RB After a review of the submitted information, I have a few comments on the above referenced Application. 1) Because this application will stand as the portable end product (after our discussions) with internal antenna only (not modular-mobile application with external application), we will ignore the following files uploaded previously provided on 12/13/02: a) Installation guide addition -2 b) Confidential_Schematics_revised c) Confidential_Technical_spec.-revised d) Mudular Approval Letter_revised e) Mudular Approval Letter (this was uploaded 12/2/02) 2) Please adjust the internal photograph exhibit to show this version only (i.e., remove photographs relating to the external antenna). 3) Please adjust the external photograph exhibit to show this version only (i.e., remove photographs relating to the external antenna). 4) Please adjust the test photograph exhibit to show this version only (i.e., remove photographs relating to the external antenna). 5) The test report makes mention of both internal and external antennas. Please provide a cover letter for the test report which explains which data is valid for which FCC ID. Alternatively, you may provide a corrected test report that removes reference to the external antenna. 6) Since this output power (both EIRP and conducted power) is in excess of 24.6 mW, compliance with SAR testing is required. Please provide SAR report for review. 7) It is not certain which block diagram is appropriate for this device, please confirm whether the one provided 12/2/02 or 12/13/02 is correct, or please upload a current block diagram. 8) The RF exposure conditions given in the users manual (page 2 of 24) reference 20 cm spacing for RF exposure conditions. Please note that this is not considered valid for general purpose PCMCIA Cards that may be used in laptops. The users manual should explain that this device has been evaluated for SAR, and information related to its test configuration should be given to the user. We have provided sample text in a separate attachment. Note that the sample text is suggestive only. You may reword as appropriate. 9) Please provide a schematic specifically for this model. The original schematic provided does not appear to meet you description provided 1/7/03 in your email. 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. z Page 2January 13, 2003 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.

American Telecommunications Certification Body Inc. 6731 Whittier Ave, McLean, VA 22101 January 28, 2003 RE: Delta Networks, Inc. FCC ID: PD5LMWP200RB After a review of the submitted information, I have a few comments on the above referenced Application. SAR Review 1) Please update the test report should include the following: a) statement of compliance with FCC RF exposure included (§2.1093)? b) mobile or portable transmitter device category identified? c) testing for Occupational/Controlled OR General Population/Uncontrolled limits? d) test device is production unit or identical prototype (47 CFR §2.908)? e) procedures to establish the test signals describe? This may include a test equipment list or test codes. f) The probe, validation dipoles, and phantom have been described. However, the test report should also include a brief description of the SAR scanning measurement system (controller, robot, etc.)? g) Composition, ingredients, and amounts for tissue liquid listed. 2) The Z-axis plots provided in the report only confirm a 3-4 cm liquid depth. The FCC likes to be able to confirm that the 15 cm liquid depth was present by supporting photographs or Z-axis data which shows this depth. This was not provided for the actual test. Please confirm that the liquid depth was at least 15 cm. 3) The values on the SAR plots for the conductivity and permitivity do not appear to be provided from the test report, or an explanation at how these values were arrived at. 4) Better information should be supplied regarding the interpolation and extrapolation used by the system. For instance: a) descriptions of extrapolation procedures used to estimate SAR values adjacent to phantom surface (unreachable due to probe case and boundary effects) b) descriptions of within-cube interpolation procedures to get 1 mm or 2 mm SAR grid c) description of averaging (integration) procedures to get 1-g SAR from final interpolated grid. 5) Section 5.1 states that a course scan was performed around the the highest spatial SAR location. However there is not a description of how this location was determined. 6) What was the probe tip distance to phantom inner surface during course scans. 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.

Close From: [email protected] [SMTP:[email protected]] To: [email protected] Cc: Subject: FCC ID: PD5LMWP200RB SAR Review Sent: 2/10/03 11:43 AM Importance: Normal Hi, Tim For your question (2)~(6), it is answered by my SAR test engineer. Any further question, please let me know it. And I will get back to you for your question (1) very soon. (2) Yes I confirm that the liquid depth is 15cm. (3) Those parameter is measured by vector network analyzer and tissue parameter feature suggested by Smidt & Partner. Please see attached file for test procedures. (See attached file: AN Testing Tissue Simulating Liquids Using HP85070.pdf) (4) a).The extrapolation is based on a least square algorithm [W. Gander, Computermathematik, p.168-180]. Through the points in the first 3 cm in all z-axis, polynomials of order four are calculated. This polynomial is then used to evaluate the points between the surface and the probe tip. The points, calculated from the surface, have a distance of 1 mm from one another. b).The interpolation of the points is done with a 3d-Spline. The 3d-Spline is composed of three one-dimensional splines with the "Not a knot"-condition [W. Gander, Computermathematik, p.141-150] (x, y and z -direction) [Numerical Recipes in C, Second Edition, p.123ff ]. c).Firstly the size of the cube is calculated. The volume is integrated with the trapezoidal algorithm. 8000 points (20x20x20) are interpolated to calculate the average. (5) The maximum search is automatically performed after each coarse scan measurement. It is based on splines in two or three dimensions. The procedure can find the maximum for most SAR distributions even with relatively large grid spacings. After the coarse scan measurement, the probe is automatically moved to a position at the interpolated maximum. The following scan can directly use this position for reference, e.g., for a finer resolution grid or the cube evaluations. Page 1 of 3FCC ID: PD5LMWP200RB SAR Review 2/19/03http://64.50.160.2/exchange/forms/IPM/NOTE/read.asp?command=open&obj=00000000A0... The 1g peak evaluations are only available for the predefined cube 5x5x7 scans. The routines are verified and optimized for the grid dimensions used in these cube measurements. The measured volume of 32x32x30mm contains about 35g of tissue. The first procedure is an extrapolation (incl. boundary correction) to get the points between the lowest measured plane and the surface. The next step uses 3D interpolation to get all points within the measured volume in a 1mm grid (35000 points). In the last step, a 1g cube is placed numerically into the volume and its averaged SAR is calculated. This cube is the moved around until the highest averaged SAR is found.If the highest SAR is found at the edge of the measured volume, the system will issue a warning: higher SAR values might be found outside of the measured volume. In that case the cube measurement can be repeated, using the new interpolated maximum as the center. (6) The distance that probe tip to phantom inner surface is 10mm during course scans. Best Regards, Dr. Alan Lane Tel: +886 3 3270910 Fax: +886 3 3270892 ----- ??? Alan Lane/ADT ? 2003/02/11 12:40 AM ----- "lyang" <lyang@itslabtes ???: <[email protected]>, <[email protected]> t-twn.com> ????: ??: FCC ID: PD5LMWP200RB SAR Review 2003/01/29 05:57 PM ??? ? lyang Dear Demi, Please find the attached of ATCB comments of DNI's project. Should you have any question, please feel free to let me now. Best regards. Lyn Yang (???) ETL Semko TWN EMC Lab Tel +886-3-519-1411 Ext 303 Fax +886-3-519-1410 E-mail: [email protected] Page 2 of 3FCC ID: PD5LMWP200RB SAR Review 2/19/03http://64.50.160.2/exchange/forms/IPM/NOTE/read.asp?command=open&obj=00000000A0... (See attached file: ATCB Comments_012803.pdf) AN Testing Tissue Simulating Liquids Using HP85070.pdf ATCB Comments_012803.pdf Page 3 of 3FCC ID: PD5LMWP200RB SAR Review 2/19/03http://64.50.160.2/exchange/forms/IPM/NOTE/read.asp?command=open&obj=00000000A0...

Close From: [email protected] [SMTP:[email protected]] To: [email protected] Cc: [email protected]; [email protected] Subject: FCC ID: PD5LMWP200RB SAR Review Sent: 2/11/03 2:40 AM Importance: Normal Hi, Tim, For your question (1), a) done b) it is portable, and it has been described in attached revised test report. c) It is General Population/uncontrolled limit, I have stated this in the revised report. d) Production unit e) what test signal do you mean here ?? for validation ?? f) done g) done (See attached file: SA920109R03A revised.pdf) Dear Demi, Please find the attached of ATCB comments of DNI's project. Should you have any question, please feel free to let me now. Best regards. Lyn Yang (???) ETL Semko TWN EMC Lab Tel +886-3-519-1411 Ext 303 Fax +886-3-519-1410 E-mail: [email protected] (See attached file: ATCB Comments_012803.pdf) SA920109R03A revised.pdf ATCB Comments_012803.pdf Page 1 of 1FCC ID: PD5LMWP200RB SAR Review 2/19/03http://64.50.160.2/exchange/forms/IPM/NOTE/read.asp?command=open&obj=00000000A0...

   





 


FCC ID Label Location 63.00 mm 39.50 mm



 











 












FCC ID: PD5LMWP200RB Report No.: SA920109R03A 1 Issued: Jan. 15, 2003 SAR TEST REPORT REPORT NO.: SA920109R03A MODEL NO.: LM-WP200RB RECEIVED: Jan. 09, 2003 TESTED: Jan. 10, 2003 APPLICANT: Delta Networks, Inc. ADDRESS:252, Shang Ying Road, KueiShan 333, Taiwan, R.O.C. ISSUED BY: Advance Data Technology Corporation LAB LOCATION: 47 14th Lin, Chiapau Tsun, Linko, Taipei, Taiwan, R.O.C. This test report consists of 16 pages in total except Appendix. It may be duplicated completely for legal use with the approval of the applicant. It should not be reproduced except in full, without the written approval of our laboratory. The client should not use it to claim product endorsement by CNLA, NVLAP or any government agencies. The test results in the report only apply to the tested sample. FCC ID: PD5LMWP200RB Report No.: SA920109R03A 2 Issued: Jan. 15, 2003 Table of Contents 1. CERTIFICATION....................................................................................... 3 2. GENERAL INFORMATION..................................................................... 4 2.1 GENERAL DESCRIPTION OF EUT .............................................................. 4 2.2 GENERAL DESCRIPTION OF APPLIED STANDARDS ............................... 4 2.3 GENERAL INOFRMATION OF THE SAR SYSTEM...................................... 5 2.4 GENERAL DESCRIPTION OF THE PROBE SCAN RULE ........................... 7 3. DESCRIPTION OF TEST MODES AND CONFIGURATIONS...... 8 4. DESCRIPTION OF SUPPORT UNITS................................................ 9 5. TEST RESULTS...................................................................................... 10 5.1 TEST PROCEDURES ................................................................................. 10 5.2 MEASURED SAR RESULT ......................................................................... 10 5.3 SAR LIMITS ................................................................................................ 11 5.4 EUT CONDUCTED POWER VARIATION ................................................... 11 5.5 TISSUE ....................................................................................................... 12 5.6 TEST EQUIPMENT FOR TISSUE PROPERTY .......................................... 12 6. SYSTEM VALIDATION.......................................................................... 13 7. MEASUREMENT UNCERTAINTIES.................................................. 14 8. INFORMATION ON THE TESTING LABORATORIES.................. 16 APPENDIX A: TEST CONFIGURATIONS AND TEST DATA APPENDIX B: ADT SAR MEASUREMENT SYSTEM APPENDIX C: PHOTOGRAPHS OF SYSTEM VALIDATION APPENDIX D: SYSTEM CERTIFICATE & CALIBRATION FCC ID: PD5LMWP200RB Report No.: SA920109R03A 3 Issued: Jan. 15, 2003 1. CERTIFICATION PRODUCT : 11Mbps Wireless LAN PCMCIA Card MODEL NO. : LM-WP200RB BRAND : DNI APPLICANT : Delta Networks, Inc. STANDARDS : 47 CFR Part 2 (Section 2.1093), FCC OET Bulletin 65, Supplement C (01-01), RSS-102 We, Advance Data Technology Corporation, hereby certify that one sample of the designation has been tested in our facility on 10 th Jan. 2003. The test record, data evaluation and Equipment Under Test (EUT) configurations represented herein are true and accurate, and it was tested according to the standards listed above. This device was found to be in compliance with the Specific Absorption Rate (SAR) requirement specified in FCC part 2.1093 under General Population / Uncontrolled Exposure condition. FCC ID: PD5LMWP200RB Report No.: SA920109R03A 4 Issued: Jan. 15, 2003 2. GENERAL INFORMATION 2.1 GENERAL DESCRIPTION OF EUT PRODUCT 11Mbps Wireless LAN PCMCIA Card MODEL NO. LM-WP200RB POWER SUPPLY 3.3VDC powered by host CLASSIFICATION Portable device, production unit MODULATION TYPE BPSK, QPSK, CCK RADIO TECHNOLOGY DSSS TRANSFER RATE 1/2/5.5/11Mbps FREQUENCY RANGE 2412MHz ~ 2462MHz NUMBER OF CHANNEL 11 CONDUCTED OUTPUT POWER 62.6 mW ANTENNA TYPE Printed Inverted-F Antenna PEAK SAR 1.11 W/kg DATA CABLE NA I/O PORTS PCMCIA ASSOCIATED DEVICES NA 2.2 GENERAL DESCRIPTION OF APPLIED STANDARDS According to the specifications of the manufacturer, this product must comply with the requirements of the following standards: FCC CFR 47 Part 2 (2.1093) FCC OET Bulletin 65, Supplement C (01- 01) RSS-102 All tests have been performed and recorded as per the above standards. FCC ID: PD5LMWP200RB Report No.: SA920109R03A 5 Issued: Jan. 15, 2003 2.3 GENERAL INOFRMATION OF THE SAR SYSTEM DASY3 (software 3.1d) consists of high precision robtics system, probe alignment sensor, phantom, robot controller, controlled PC and near-field probe. The robot includes six axis that can move to the precision position of the DASY3 software defined. The DASY3 software can define the area which is detected by the probe. The robot is connected to controlled box. Controlled PC is connected to the controlled robot box. The DAE includes amplifier, signal multiplexing, AD converter, offset measurement, surface detection. It is connected to the Electro-optical coupler (ECO). The ECO performs the conversion form the optical into digital electric signal of the DAE and transfers data to the PC. ET3DV6 ISOTROPIC E-FIELD PROBE Construction Symmetrical design with triangular core. Built-in optical fiber for surface detection system. Built-in shielding against static charges. PEEK enclosure material (resistant to organic solvents, e.g., glycolether). Calibration Basic Broad Band Calibration in air: 10-2500 MHz Conversion Factors (CF) for HSL 900 and HSL 1800 CF-Calibration for other liquids and frequencies upon request Frequency 10 MHz to 3 GHz; Linearity: ± 0.2 dB (30 MHz to 3 GHz) Directivity ± 0.2 dB in HSL (rotation around probe axis) ± 0.4 dB in HSL (rotation normal to probe axis) Dynamic Range 5 μW/g to > 100 mW/g; Linearity: ± 0.2 dB Optical Surface Detection ± 0.2 mm repeatability in air and clear liquids over diffuse reflecting surfaces Dimensions Overall length: 337 mm (Tip Length: 10 mm) Tip diameter: 7.0 m…

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Page 1 ANNEX PHOTOGRAPHS OF EUT Page 2 Page 3 Page 4 Page 5

      













  








































  




































       
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