POZ-ERU-0202001PCS External Radio Unit

185 Berry Street #2000 San Francisco, CA 94107 Federal Communications Commission 7435 Oakland Mills Road Columbia, MD 21046 April 29, 2002 CONFIDENTIAL Dear Examiner: Re: Request pursuant to 47 C.F.R § 0.457(d)(1) and (2) I am writing to the Commission pursuant to 47 C.F.R § 0.457 (d)(1) and (2) requesting that the records provided to the Commission with regard to the accompanying 731application by SOMA Networks Inc. (“SOMA”) and submitted on its behalf of by Elliott Laboratories Inc. will not be disclosed or made routinely available to the public (the “Request”). The material being provided to the Commission in support of the Application contains both trade secrets and contains commercial information that is confidential and contains information such that any disclosure would result in substantial competitive harm. Elliott Laboratories, Inc., is a consulting and testing laboratory, and is filing a Form 731 Application as authorized under 47 C.F.R § 2.1033 with the Commission on our behalf. Included with the Application as exhibits to Application are block diagrams, schematics, and a detailed description of the theory of operation of the device that are the subject of the Request. In accordance with 47 C.F.R. § 0.459 (a) and (b) and in support of its Request, SOMA submits the following facts to be considered by the Commission. SOMA submits that the facts as presented shall enable the Commission to grant the Request that the material provided by SOMA in support of its Application shall neither be disclosed or made generally available to the public pursuant to 47 C.F.R. § 0.460 and § 0.461. SOMA is a company incorporated under the laws of California with its registered head office located at 185 Berry Street, Suite 2000, San Francisco, CA 94107. SOMA is involved in the development and exploitation of wireless broadband technology consisting of proprietary telecommunications software operating system, air interface software, system hardware and end-user hardware known as customer premises hardware. The circumstances giving rise to this Request are that it is the intention of SOMA to make available to the United State certain of its hardware and software products as part of its normal course of business. As part of SOMA’s operations and compliance with the Commission’s governing statues and regulations, SOMA is submitting to the Commission pursuant to 47 C.F.R § 47 C.F.R. 2.1033 an Application regarding certain SOMA technologies. Included therein are exhibits with the enclosed application are block diagrams, schematics, and a detailed description of the theory of operation of the device. Each of these block diagrams, schematics and detailed descriptions of the theory of operation of the devices and/components described therein have been marked as “Proprietary and Confidential” or as “Confidential“. The material provided in support of the Application has been developed by SOMA in order to provide to the marketplace leading edge technology with respect to broadband data and voice hardware and software. In particular, the material being provided is with regard to an antenna booster for SOMA’s consumer premises device, the SOMAport™. The block diagrams, schematics and detailed theory of operations of the device and/or components as provided in the materials represent many years of research and development by SOMA in order to provide its unique solution to the marketplace. Furthermore, the antenna booster is significant to the current and future development of the SOMAport™ and the future commercialization of SOMA’s software and hardware solutions for the wireless provision of broadband data and voice products to its customers. All the material provided in support of the Application (pending certification) provides SOMA with the opportunity to obtain an advantage over its competitors who do not know how to use the information. The material provided in the Application constitute trade secrets in that any competitor obtaining the material through a third-party such as the Commission would obtain a commercial advantage that they would not have had through their own research and development efforts. The materials provided in support of the Application describe the proprietary operation of SOMA’s products. These details are not readily discernable, even to technically sophisticated individuals. As such any disclosure of any of this material shall cause substantial competitive harm to SOMA. Any disclosure will remove the market lead that SOMA has developed in focusing its resources into research and development and now commercial exploitation of its research and development efforts. Overall, the marketplace to which SOMA provides its products is competitive. However, SOMA is a unique player in the marketplace as it provides broadband solutions for both voice and data utilizing proprietary software and hardware designs to provide “First Mile” and “Last Mile” solutions to the telecom industry. As stated previously, SOMA has invested substantial time and resources in its research and development efforts to bring its products to market and the materials provided in support of the Application contain proprietary information and trade secrets that, if disclosed, to the general public would cause substantial economic harm to SOMA, including the continued viability of SOMA by severely diminishing the market lead it has achieved. SOMA maintains a company-wide and comprehensive effort with respect to confidential and proprietary information. A system has been put in place to ensure that all employees, consultants and agents execute comprehensive non-disclosure agreements. Further, non-disclosure agreements are in place with all major suppliers and all third- parties providing services and products to SOMA. SOMA is unaware at this time of any unauthorized disclosure by SOMA, any related party of SOMA or any third party that has been engaged by SOMA of any material being provided to the Commission in support of th…

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American Telecommunications Certification Body Inc. 6731 Whittier Ave, McLean, VA 22101 June 10, 2002 RE: FCC ID: POZ-ERU-0202001 Attention: Juan Martinez I have a few comments on this Application. 1 The 731 form says the emissions designator is 4M18FXW, page 2 of the report says the emissions designator is 4M02FXW and page 6 of the report says the emissions is 4.208Mhz. Please clarify as to what the actual emissions designator. Please provide consistent information on the emissions designator. Also, please verify FXW not F9W. 2Does the output power vary with loading? 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.

Page 1 of 1 Soma Networks RE: FCC ID: POZ-ERU-0202001 1) The 731 form says the emissions designator is 4M18FXW, page 2 of the report says the emissions designator is 4M02FXW and page 6 of the report says the emissions is 4.208Mhz. Please clarify as to what the actual emissions designator. Please provide consistent information on the emissions designator. Also, please verify FXW not F9W. Response: Both 731 form and report has been corrected and revised. Both documents have been uploaded. FXW is correct. 2) Does the output power vary with loading? Response: The output power at the ERU will vary. The ERU will adjust itself for best possible pick-up signal, so the ERU will either be at maximum output power or minimum output power. Hopefully this answers all of your questions. Please contact me via [email protected] if you require more information. Regards, Juan Martinez Sr. EMC Engineer

BOTTOM SIDE OF ERU

1.750 ±0.010 3.400 ±0.010 R 0.150 DRAWING SCALE 2:1 3 4 5 7 8 8 9 8 13 9 14 7 10 D C B A A B C D NETWORKS CAD GENERATED DRAWING, DO NOT MANUALLY UPDATE SCALE SIZE CAD FILE: DWG. NO. B SHEET1OF1 REV. DATE APPROVALS DRAWN CHECKED RESP ENG MFG ENG QUAL ENG UNLESS OTHERWISE SPECIFIED DIMENSIONS ARE IN INCHES TOLERANCES ARE: FRACTIONS DECIMALS ANGLES + .XX+ .XX + 1 .XXX+.XXX MATERIAL FINISH -- -- DO NOT SCALE DRAWING APPLICATION USED ONNEXT ASSY ITEM NO. PART OR IDENTIFYING NO. NOMENCLATURE OR DESCRIPTION MATERIAL SPECIFICATION QTY REQD PARTS LIST 123 456 7 8 87 6 5 4 32 1 THE INFORMATION CONTAINED IN THIS DRAWING IS THE SOLE PROPERTY OF SOMA NETWORKS. ANY REPRODUCTION IN PART OR WHOLE WITHOUT THE WRITTEN PERMISSION OF SOMA NETWORKS IS PROHIBITED. REVISIONS REV.DESCRIPTIONDATEAPPROVED 003024 01 LABEL, REGULATORY, U.S.A., ERU,PCS. 01 INITIAL RELEASE PER ECO-01221 SEE ECO MInden 04/16/2002 INCORP. - 2:1 SEE ECO 04/16/2002 MInden 1. MARK VENDOR NAME, LABEL DESIGNATION, AND SOMA NETWORKS PART NUMBER ON EACH SHEET OF LABELS. 2. BACKGROUND TO BE DARK GRAY (PANTONE COLOR 432C) LETTERING AND GRAPHICS TO BE SILVER. 3. REFER TO APPROPRIATE AGENCY LISTING MARK INFORMATION TO REPLACE REFERENCE SYMBOLS WITH APPROPRIATE REGISTERED MARKS. 4. FONT: ARIAL 28 POINT 5. FONT: ARIAL NARROW 28 POINT 6. FONT: ARIAL 13 POINT 7. FONT: ARIAL 9 POINT 8. FONT: ARIAL 8 POINT 9. FONT: ARIAL 6 POINT 10. FONT: ARIAL 5 POINT 11. LABEL CONSTRUCTION TO CONSIST OF A 0.010" THICK POLYCARBONATE LABEL STOCK WITH A 0.002" THICK 3M #467 PRESSURE SENSITIVE ADHESIVE. LABEL MUST BE A COMPONENT MARKING AND LABELING SYSTEM APPROVED BY UL AND CSA FOR THE FOLLOWING CONDITIONS: A) OUTDOOR B) TEMPERATURE RANGE: -40C TO +55C WHEN AFFIXED TO GE CYCOLOY C6200 (PC/ABS BLEND) 12. APPROVED SOURCES OF SUPPLY: BAY AREA LABELS 13. PRINT “PENDING FCC APPROVAL” AT NOTED LOCATION. 14. PLACE FCC LOGO (FCCEMBLM.GIF) IN NOTED LOCATION. D C A A B C D 1 2 3 4 5 678 8 7 65 4 3 2 1 THE INFORMATION CONTAINED IN THIS DRAWING IS THE SOLE PROPERTY OF SOMA NETWORKS, INC. ANY REPRODUCTION IN PART OR AS A WHOLE WITHOUT THE WRITTEN PERMISSION OF SOMA NETWORKS IS PROHIBITED. PROPRIETARY AND CONFIDENTIAL MATERIAL FINISH DRAWN CHECKED ENG APPR. MFG APPR. Q.A. DATE NAME TITLE: SIZE B DWG. NO. REV SHEET 1 OF 1WEIGHT: SCALE: 1:1 REVISIONS REV. DESCRIPTION DATE APPROVED ZONE UNLESS OTHERWISE SPECIFIED: DO NOT SCALE DRAWING ASSY DWG,BASE, ERU,SP,PCS AD-002584 01 MInden DIMENSIONS ARE IN INCHES TOLERANCES: ANGULAR: MACH1 BEND 1 TWO PLACE DECIMAL .01 THREE PLACE DECIMAL .005 DWG. NO. REV SH AD-002584 01 1 04/22/2002 ITEMQTYPART NO.DESCRIPTIONMATERIAL PARTS LIST

MPE Calculations FCC part 1.1310, Table 1 limits the power density for uncontrolled exposure to 1mW/ cm 2 for systems operating in the PCS bands. The distance, d(cm) from the antenna at which the power density, P d (mW/cm 2 ) is below this limit is calculated from the maximum EIRP, P t (mW) using the equation: P d = P t #q 2 ) Re-arranging for the distance at which the power density is 1mW/cm2 gives: d = √ (P t # The device under test is designed to use an integral antenna with a gain of 11 dBi. The maximum output power for the two modes and all channels is 26 dBm. The maximum EIRP is, therefore, 26 dBm + 11 dBi = 37 dBm (5012mW): Refer to Excel Spreadsheet for MPE calculated distance The distance from the antenna that the power density is 1mW/ cm 2 . The users guide instructs the user to install the device such that it has a separation of at least 20cm from persons (see text below) to comply with the FCC’s requirements. This separation of 20cm more than meets the FCC’s and Industry Canada RF exposure requirements. RF Exposure Requirements To ensure compliance with FCC RF exposure requirements, the antenna used for this device must be installed to provide a separation distance of at least 20 cm from all persons and must not be co-located or operating in conjunction with any other antenna or radio transmitter. Installers and end- users must follow the installation instructions provided in this user guide. Extract Of Text From The User’s Manual The following pages contain the RF exposure warning statement in the installation manual: Page 13, 18 ERU, with a 11 dBi internal antenna LogLinear Gain (dBi/linear)10.511.2 Power (dBm/mW) 26.8478.6 EIRP (dBm/mW) 37.35370.3 Limit 1.000 mW/cm 2 MPE Distance: 20.7cm ERP (mW)35.163274.6