QGK-DT200PCMCIA WLAN Card

FCC ID NO: QGK-DT-200 Demarc Technology Group, LLC 40 Fairview Rd – Frenchtown NJ, 08825 Tel: 908-996-7995 Fax: 908-847-0202 Website: http:/// www.demarctech.com Email: [email protected] FCC Notice Demarc Technology Group, LLC wireless equipment described herein complies with FCC radiation exposure limits set forth for an uncontrolled environment when installed as directed. The equipment should be installed and operated as fix- mounted system such that the main lobe(s) of these antennas are located a minimum of 8 feet between the antenna and all persons during normal operation. This device complies with Part 15 of the FCC rules. Operation is subject to the following two conditions: 1. This device may not cause harmful interference. 2. This device must accept any interference received, including interference that may cause undesired operation. Changes or modifications not expressly approved by the manufacturer could void the user’s authority to operate the equipment. Federal Communications Commission (FCC) Statement This Equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to Part 15 of the FCC rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates, uses, and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications. However, there is no guarantee that interference will not occur in a particular installation. FCC Output Power Restrictions The FCC does not require licensing to implement this device. However, the FCC has established restrictions regarding maximum output power and the adjustments required when employing directional gain antennas. These restrictions are detailed in FCC Part 15.247 (b)(1), (b)(3)(i), and (3)(iii). It is the responsibility of the individuals designing and implementing the radio system to assure compliance with these and any other pertinent FCC Rules and Regulations. FCC RF Radiation Exposure Statement: The DT- 200 is designed for 2.4 GHz @ 200mW. This level of RF energy are below the Maximum Permissible Exposure (MPE) levels specified in FCC OET 65:97- 01. This is only approved with the antenna gains as listed in this document with the maximum antenna gain of 18dBi. A separation distance of 33 cm between the antenna and humans must be maintained. The following precautions must be taken during installation of this equipment: • The installed antenna must not be located in a manner that allows exposure of the general population to the direct beam path of the antenna at a distance less than 33cm. Installation on towers, masts, or rooftops not accessible to the general population is recommended; or • Mount the antenna in a manner that prevents any personnel from entering the area within 33 cm from the front of the antenna. • During antenna installation, be sure that power to the DT-200 equipment is turned off in order to prevent any energy presence on the coaxial connector. • During installation and alignment of the antenna, do not stand in front of the antenna assembly. • During installation and alignment of the antenna, do not handle or touch the front of the antenna. These simple precautions must be taken to prevent personnel from exposure to RF energy in excess of specified MPE levels. FCC ID NO: QGK-DT-200 Demarc Technology Group, LLC 40 Fairview Rd – Frenchtown NJ, 08825 Tel: 908-996-7995 Fax: 908-847-0202 Website: http:/// www.demarctech.com Email: [email protected] Feedline Loss Feedline loss is a function of feedline type and length. Feedline loss per 100 feet for several types of coax at 2.4Ghz is detailed in the table below. The RF loss applies to BBP/RFC interconnection, and the RF loss applies to RFC/antenna interconnection. RF Loss per 100 feet at 2.4GHz Cable dB Loss/100 feet LMR-100 40 dB LMR-195 19 dB LMR-200 16.9 dB LMR-240 12.9 dB LMR-300 10.4 dB LMR-400 6.8 dB LMR-500 5.48 dB LMR-600 4.42 dB LMR-900 2.98 dB LMR-1200 2.26 dB LMR-1700 1.71 dB TRANSMITTER POWER The FCC specifies the maximum transmitter power that may be used for antennae of a given gain. FCC rules Part 15, Subpart 247 for a point-to-point system allows for a maximum power of 1 watt into antennae of a gain less than or equal to 6 dBi. For every 3 dB of gain over 6 dBi, the transmitter must be reduced by 1 dB. Authorized Antennas and Antenna Gain Best performance will result from the use of high gain antennas. DT-200 is intended to be coupled with an antenna that is directional and provides signal gain as the FCC provides no recourse in this band in the event of nearby interference, so a highly directional antenna reduces the likelihood of interference in the antenna pattern. A unique style (reverse MMCX) connector is provided on the DT-200 to prevent the use of non-approved antennas. The following table is a list of Demarc antenna models that are approved to be used with this device: All antennas are the same type antenna. Only the panel design is changed between the different models. The Omni directional antennas do not have panels installed. FCC ID NO: QGK-DT-200 Demarc Technology Group, LLC 40 Fairview Rd – Frenchtown NJ, 08825 Tel: 908-996-7995 Fax: 908-847-0202 Website: http:/// www.demarctech.com Email: [email protected] Model No. Frequency Mhz Gain dBi HB/VB Degree Model No. Frequency Mhz Gain dBi HB/VB Degree 180° Sector Panel Base Station Antennas (Vertical) Omni Directional Base Station Antennas (Vertical) SPDG11H 2400-2483 3.5 180/70 SPDG11O 2400-2483 2 360/90 SPDG12H 2400-2483 6 180/40 SPDG12O 2400-2483 4.5 360/55 SPDG13H 2400-2483 7.5 180/24 SPDG13O 2400-2483 5.5 360/30 SPDG14H 2400-2483 8 180/20 SPDG14O 2400-2483 6.5 360/24 SPDG16H 2400-2483 9.5 180/14 SPDG16O 2400-2483 8 360/18 SPDG18H 2400-2483 10.5 180/10 SPDG112H 2400-2483 11.5 180/8 Omni Directional Base Station Antennas (Vertical) (Panel) SPDG12OP 2400-2483 4.5 360/55 …

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Washington Laboratories, Ltd. 7560 LINDBERGH DRIVE GAITHERSBURG, MD 20879 (301) 417 – 0220 FAX # (301) 417 - 9069 July 25, 2003 American TCB 6731 Whittier Avenue, Suite C110 McLean, VA 22101 RE: Request for Confidentiality FCC ID: QGK-DT200 Demarc Technologies Acting as authorized representatives for Demarc Technologies Group, LLC (applicant) and ZCOMAX Technologies, Inc. (vendor), we request that the following exhibits be held confidential: • Schematics • Block Diagram • Operational Description The application contains technical information that Demarc Technologies Group, LLC (applicant) and ZCOMAX Technologies, Inc. (vendor) deems to be trade secrets and proprietary. If made public, the information might be used to the disadvantage of the applicant and vendor in the market place. Thank you for your attention to this matter. Gregory M. Snyder Wireless/Telco Services Manager & Chief EMC Engineer WLL Project: 7384

American Telecommunications Certification Body Inc. 6731 Whittier Ave, McLean, VA 22101 July 1, 2003 RE: FCC ID: QGK-DT200 Attention: Gregory M. Snyder / Brian J. Dettling I have a few comments on this Application. 1. FYI – not action needed. Please note that Direct Sequence and other non Frequency Hopping Spread Spectrum transmitters under 15.247 use an equipment code of DTS not DSS. 2. FYI – no action needed. Please note that DTS WLAN devices are generally 2412 to 2462 MHz as these are the upper and lower channels for the US. 3. Please note that the Zcomax FCC ID requested to be used in the application is not the same FCC ID as that stated as being the same in a previous application. Please verify that the transmitter schematics for M4Y-325H2 to be used with this application is the same as M4Y-325H1 which was used in the precedent application you specified as the same in that application. 4. Please note that confidentiality was not checked on the 731. Also, no request for confidentiality letter was provided. If the block diagram, schematics and operational description for this device are confidential, you will have to provide a confidentiality request letter specifying these exhibits. . 5. Please note that the schematics, block diagram, operational description and internal photos of the card are the same as for the QGK-DT100. However, the power of the previous device is 100Mw while the power for this device is 200 mw. If all of the listed items are the same, I would expect the power to be the same or similar. What components, alignment procedure or other aspects of the device cause this to be 200mw while an apparently identical device previously granted is 100mw? Please explain. 6. Please note that the rf exposure states 15.407. The device operates under 15.247. Please correct your MPE report to reflect this device. 7. Please note, certain documents claim that this device is professionally installed (MPE report). While this device may actually only be sold and installed in this type of configuration, it is after all a PCMCIA card usable in any PCMCIA slot. Professional installation indicates that a one time installation process is involved. Please note that a PCMCIA format card is intended for repetitive or at least multiple installation and reinstallation. What is to prevent the user from using this PCMCIA card a laptop or other non professionally installed applications, etc.? For example, is the PCMCIA card blocked via BIOS (can only certain configurations use this device and all other applications not use the device? – how is this possible?) Please explain how it is possible for this PCMCIA card to be limited to professional installations as indicated. Alternately, while it is may actually be sold and installed in the manner indicated, the grant for the device would not contain a note for professional installation, please correct the MPE report to remove any indication of professional installation. 8. The manual appears to have conflicting MPE distances listed. In the RF exposure statement (Page 1) it states installation of an antenna of 18dBi gain is not to be closer than 35cm yet the next statement (The following precautions must be taken during installation of this equipment) states 25cm separation must be maintained. Please correct the manual to be in line with the reported minimum separation distances. Please note also that my calculations show a 35cm separation would be for an antenna gain of 18.75dBi (numeric gain of 75) while an 18dBi antenna would give 32 cm separation. z Page 2 July 1, 2003 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.

Response to ATCB Comments FCC ID: QGK-DT200 1 Washington Laboratories, Ltd. 7560 LINDBERGH DRIVE GAITHERSBURG, MD 20879 (301) 417 – 0220 FAX # (301) 417 - 9069 July 25, 2003 Mr. Dennis Ward American Telecommunications Certification Body Inc. 6731 Whittier Ave McLean, VA 22101 RE: Comments of July 1, 2003 APPLICATION: FCC ID: QGK-DT200 Demarc Technologies Dear Mr. Ward: Below are the comments that you have provided regarding the application for certification referenced above. Our responses to those comments are in bold italic. Many responses refer you to additional exhibit(s) which has been uploaded to the application folder at the ATCB website. Thank you for your attention. Please feel free to contact us for any additional information that you may require. Regards, Gregory M. Snyder Chief EMC Engineer, Wireless/Telco Services Manager Brian J. Dettling Documentation Specialist WLL Project: 7384 July 1, 2003 RE: Demarc Technologies FCC ID: FCC ID: QGK-DT200 1) Please note that the Zcomax FCC ID requested to be used in the application is not the same FCC ID as that stated as being the same in a previous application. Please verify that the transmitter schematics for M4Y-325H2 to be used with this application is the same as M4Y-325H1 which was used in the precedent application you specified as the same in that application. Response to ATCB Comments FCC ID: QGK-DT200 2 R. Please disregard the ZComax Release Letter. This application uses the ZComax FCC ID: M4Y- 0325H and the appropriate supporting exhibits have been uploaded. 2) Please note that confidentiality was not checked on the 731. Also, no request for confidentiality letter was provided. If the block diagram, schematics and operational description for this device are confidential, you will have to provide a confidentiality request letter specifying these exhibits. R. Please see exhibit “Revised DT200 Form 731.pdf” which confidentiality has been indicated, and exhibit “Req For Confidentiality.pdf” which indicates that the block diagram, schematics, and operational descriptions should be held confidential. 3) Please note that the schematics, block diagram, operational description and internal photos of the card are the same as for the QGK-DT100. However, the power of the previous device is 100Mw while the power for this device is 200 mw. If all of the listed items are the same, I would expect the power to be the same or similar. What components, alignment procedure or other aspects of the device cause this to be 200mw while an apparently identical device previously granted is 100mw? Please explain. R. The QGK-DT200 uses the 200mW unit from ZComax (FCC ID: M4Y-0235H). Please see exhibits “ZCom Theory of operation A.pdf”, “ZCom Theory of Operation B.pdf”, “ZCom XI325H Schematic.pdf”, and “ZCom xi325h_block diagram.pdf”. 4) Please note that the rf exposure states 15.407. The device operates under 15.247. Please correct your MPE report to reflect this device. R. The typographical error has been corrected. Please see exhibit “DT200 Revised MPE Report.pdf”. 5) Please note, certain documents claim that this device is professionally installed (MPE report). While this device may actually only be sold and installed in this type of configuration, it is after all a PCMCIA card usable in any PCMCIA slot. Professional installation indicates that a one time installation process is involved. Please note that a PCMCIA format card is intended for repetitive or at least multiple installation and reinstallation. What is to prevent the user from using this PCMCIA card a laptop or other non professionally installed applications, etc.? For example, is the PCMCIA card blocked via BIOS (can only certain configurations use this device and all other applications not use the device? – how is this possible?) Please explain how it is possible for this PCMCIA card to be limited to professional installations as indicated. Alternately, while it is may actually be sold and installed in the manner indicated, the grant for the device would not contain a note for professional installation, please correct the MPE report to remove any indication of professional installation. R. The MPE report has been revised and the reference to professional installation has been removed. 6) The manual appears to have conflicting MPE distances listed. In the RF exposure statement (Page 1) it states installation of an antenna of 18dBi gain is not to be closer than 35cm yet the next statement (The following precautions must be taken during installation of this equipment) states 25cm separation must be maintained. Please correct the manual to be in line with the reported minimum separation distances. Please note also that my calculations show a 35cm separation would be for an antenna gain of 18.75dBi (numeric gain of 75) while an 18dBi antenna would give 32 cm separation. Response to ATCB Comments FCC ID: QGK-DT200 3 R. The manual has been corrected to indicate the proper separation distance. We concur with the 32 cm as per your calculations. Please see exhibit “DT-200 Revised User Manual.pdf”.

Top View Bottom View Interface Side View Antenna Side View

FCCID: QGK-DT200 ThisdevicecomplieswithPart15ofFCCRules. OperationisSubjecttothefollowingconditions: (1)devicemaynotcauseharmfulinterference, and(2)thisdevicemustacceptany thatmaycauseundesiredoperation. interference ! MadeinTaiwan http://www.demarctech.com

Covers Off, Showing Shields In Place Disassembled (Some Shields Removed) PCB Top (Some Shields Removed) Top, All Shields Removed PCB Bottom View

Maximum Permissible Exposure Test Report for Demarc Technologies Group, LLC FCC ID: QGK-DT200 June 26, 2003 Revised: July 25, 2003 WLL PROJECT #: 7384RFFCC This report may not be reproduced, except in full, without the prior written consent of Washington Laboratories, Ltd. Demarc Technologies FCC ID: QGK-DT200 WLL Project #: 7384RFFCC 1 Maximum Permissible Exposure Test Report for Demarc Technologies Group, LLC FCC ID: QGK-DT200 1.0 Introduction This report has been prepared on behalf of Demarc Technologies Group, LLC. to show compliance with the RF exposure requirements of FCC Part 15.247 as defined in FCC Part 1.1307(b)(1) for the Demarc Wireless LAN card. 3.8 Radio Frequency Radiation Exposure In accordance with Section 1.1310 of the FCC rules, the Maximum Permissible Exposure (MPE) limit for this frequency range is 1mW/cm 2 for General Population/Uncontrolled Access. The EUT is designed for telecommunications transmissions and may use high gain antennas (up to 18 dBi) and the transmitter section is designed for mounting on an antenna mast. A unique connector is used on the card to prevent the use of higher gain antennas. Warnings are in the installation manual which limit the exposure to the direct beam during installation and maintenance. These warnings to the installers insure that the general public is not exposed to RF energy. The Demarc Wireless LAN card is designed for a transmit power of 23.1dBm (205mW). Assuming the highest allowable gain antenna is used (18 dBi) the following power density is calculated. S = (PG)/(4πR 2 ) Where, S = Power Density P = Output Power at the Antenna Terminals G = Gain of Transmit Antenna (linear gain) R = Distance from Transmitting Antenna For this device, the calculation is as follows: S = FCC Limit = 1mW/cm 2 P = Output Power = 205mW G = Worst Case Gain = 18 dBi (65 linear gain) Solving for the minimum safe distance: Demarc Technologies FCC ID: QGK-DT200 WLL Project #: 7384RFFCC 2 S GP R ×× × = π4 R = {(205mW)(65)}/{(12.566)(1 mW/cm 2 )} 1/2 = 32.6 cm The calculated 32.6 cm distance is the minimum distance required for installation to ensure the MPE limit of 1 mW/cm 2 is not exceeded. Warnings are provided in the users manual to limit exposure to the direct beam during the installation and maintenance phase and to ensure that the antenna is installed at distances greater than 33 cm from people. These warnings ensure that the device is installed properly and does not expose the general public to RF energy hazards.

Document 7384-01, Rev. 1 FCC Certification Test Report Washington Laboratories, Ltd June 2003 FCC Certification Test Report for Demarc Technologies Group, LLC QGK-DT200 June 30, 2003 Prepared for: Demarc Technologies Group, LLC 40 Fairview Road Frenchtown, NJ 08825 Prepared By: Washington Laboratories, Ltd. 7560 Lindbergh Drive Gaithersburg, Maryland 20879 FCC Certification Test Report Document 7384-01, Rev. 1 FCC Certification Test Report Washington Laboratories, Ltd June 2003 FCC Certification Test Report for the Demarc Technologies Group, LLC DT-ZM-200mW-WC 2.4 GHz DSSS QGK-DT200 WLL JOB# 7384 Prepared by: Brian J. Dettling Documentation Specialist Reviewed by: Michael Violette President Document 7384-01, Rev. 1 FCC ID: QGK-DT200 FCC Certification Test Report Washington Laboratories, Ltd June 2003 ii Abstract This report has been prepared on behalf of Demarc Technologies Group, LLC to support the attached Application for Equipment Authorization. The test report and application are submitted for a Spread Spectrum Transceiver under Part 15.247 of the FCC Rules and Regulations. This Federal Communication Commission (FCC) Certification Test Report documents the test configuration and test results for a Demarc Technologies Group, LLC DT-ZM-200mW-WC 2.4 GHz DSSS. Testing was performed on an Open Area Test Site (OATS) of Washington Laboratories, Ltd, 7560 Lindbergh Drive, Gaithersburg, MD 20879. Site description and site attenuation data have been placed on file with the FCC's Sampling and Measurements Branch at the FCC laboratory in Columbia, MD. Washington Laboratories, Ltd. has been accepted by the FCC and approved by NIST NVLAP (NVLAP Lab Code: 200066-0) as an independent FCC test laboratory. The Demarc Technologies Group, LLC DT-ZM-200mW-WC 2.4 GHz DSSS complies with the limits for a Spread Spectrum Transceiver device under Part 15.247 of the FCC Rules and Regulations. Document 7384-01, Rev. 1 FCC ID: QGK-DT200 FCC Certification Test Report Washington Laboratories, Ltd June 2003 iii Table of Contents Abstract......................................................................................................ii 1 Introduction...................................................................................................................1 1.1 Compliance Statement............................................................................................1 1.2 Test Scope............................................................................................................1 1.3 Contract Information..............................................................................................1 1.4 Test Dates.............................................................................................................1 1.5 Test and Support Personnel....................................................................................1 1.6 Abbreviations.........................................................................................................2 2 Equipment Under Test....................................................................................................3 2.1 EUT Identification & Description............................................................................3 2.2 Test Configuration..................................................................................................3 2.3 Testing Algorithm...................................................................................................4 2.4 Test Location.........................................................................................................4 2.5 Measurements........................................................................................................4 2.5.1 References.....................................................................................................4 2.6 Measurement Uncertainty.......................................................................................5 3 Test Equipment..............................................................................................................6 4 Test Results...................................................................................................................7 4.1 RF Power Output..................................................................................................7 4.2 Power Spectral Density..........................................................................................7 4.3 Occupied Bandwidth..............................................................................................8 4.4 Spurious Emissions at Antenna Terminals (FCC Part §15.247(b)).........................10 4.5 Radiated Spurious Emissions: (FCC Part §15.247(c))...........................................21 4.5.1 Test Procedure............................................................................................21 4.6 AC Powerline Conducted Emissions: (FCC Part §15.207)...................................29 List of Tables Table 1. Device Summary....................................................................................................3 Table 2. Test Equipment List................................................................................................6 Table 3. RF Power Output...................................................................................................7 Table 4. Power Spectral Density..........................................................................................7 Table 5. Occupied Bandwidth Results................................................................................10 Table 6. Radiated Emission Test Data (§15.205 Restricted Bands).....................................23 Table 7. Radiated Emission Test Data (§15.205 Restricted Bands).....................................24 Table 8. Radiated Emission Test Data (§15.205 Restricted Bands).....................................25 Table 9. Radiated Emission Test Data (§15.205 Restricted Bands).........…

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Emissions Testing Configuration SPDG17E Antenna, Front SPDG17E Antenna, Back DTFPG18 Antenna, Front DTFPG18 Antenna, Back