ZEH0412WBT Tag

PLUS Location Systems Cummings Research Park 4955 Corporate Drive Huntsville, AL 35805 USA http://www.PLUS-ls.com Tel: +1.256.922.9229 +1.888.826.8378 Fax: +1.256.922.0387 December 2011 P r e c i s i o n L o c a t i o n U l t r a W i d e b a n d S y s t e m ( P L U S ™ ) Precision Real-Time Location System S y s t e m M a n u a l 2 PLUS System Manual Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and the Partner Agreement. Nondisclosure Provisions This manual is confidential and is governed by the terms of the Nondisclosure Agreement and the Partner Agreement currently in effect between the parties. Copyright ©2001-2007 Time Domain Corporation. All rights reserved. Trademarks Time Domain® and PulsON® are registered trademarks of Time Domain Corporation. Ethernet® is a registered trademark of Xerox Corporation. “PulsON Triangle” logo and PLUS™ are trademarks of Time Domain Corporation. Any trademarks, trade names, service marks or service names owned or registered by any other company and used in this manual are the property of its respective company. Rights Rights to use this documentation are set forth in the Terms and Conditions accompanying the PLUS™ hardware. Product Safety Notice This device is listed under the ETL mark as Information Technology Equipment. Regulatory Notice U.S. Operation: This device complies with Part 15 of the FCC Rules. Operation is subject to the following 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. (3) Operation on board an aircraft or a satellite is prohibited. (4) Devices operating under this section may not be employed for the operation of toys. Operation in disregard of these conditions is a violation of 47 U.S.C. 301 and could subject the operator to serious legal penalties. Disassembling or modifying the unit will void FCC compliance and void Time Domain warranty provisions. Non-U.S. Operation: PulsON® technology has not been authorized for use or commercial exploitation under the regulations of any non-US government agency. Please confer with your government’s regulatory agency to ensure proper authorizations are obtained. PLUS System Manual 3 Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and the Partner Agreement. Table of Contents 1. OVERVIEW 9 1.1 Manual Contents ........................................................................... Error! Bookmark not defined. 1.2 PLUS System Products ................................................................ Error! Bookmark not defined. 1.2.1 Synchronization Distribution Panel ...................................... Error! Bookmark not defined. 1.2.2 Reader ..................................................................................... Error! Bookmark not defined. 1.2.3 Tag ........................................................................................... Error! Bookmark not defined. 1.2.4 Antenna ................................................................................... Error! Bookmark not defined. 1.2.5 Location Software .................................................................. Error! Bookmark not defined. 1.3 Additional Components and Peripherals .................................. Error! Bookmark not defined. 1.3.1 Visualizer ................................................................................ Error! Bookmark not defined. 1.3.2 Location Software PC ............................................................ Error! Bookmark not defined. 1.3.3 Ethernet Cable ........................................................................ Error! Bookmark not defined. 1.3.4 PS/2 Serial Adapter Cable ..................................................... Error! Bookmark not defined. 1.3.5 Reader Power Supplies .......................................................... Error! Bookmark not defined. 1.3.6 Ethernet Switch....................................................................... Error! Bookmark not defined. 2. PLUS SYSTEM INSTALLATION 9 2.1 Pre-Installation Site Survey......................................................... Error! Bookmark not defined. 2.2 Reader Placement and Wiring Diagram ................................... Error! Bookmark not defined. 2.3 Installation Overview ................................................................... Error! Bookmark not defined. 2.3.1 Unpacking and Inspecting Hardware .................................... Error! Bookmark not defined. 2.3.2 Installing and Powering the SDP ........................................... Error! Bookmark not defined. 2.3.3 Configuring Reader and Location Engine IP Addresses ..... Error! Bookmark not defined. 2.3.4 Ceiling Installation of Readers and Antennas ...................... Error! Bookmark not defined. 2.3.5 Surveying Readers and Generating Coordinates .................. Error! Bookmark not defined. 2.3.6 PC Setup and Software Installation ....................................... Error! Bookmark not defined. 2.4 System Configuration ................................................................... Error! Bookmark not defined. 2.4.1 Setting Data Input ................................................................... Error! Bookmark not defined. 2.4.2 Check Reader Communications ............................................ Error! Bookmark not defined. 2.4.3 Reader Configuration ............................................................. Error! Bookmark not defined. 2.4.4 Saving Configuration ............................................................. Error! Bookmark not defined. 2.4.5 Entering Floor Plan Data........................................................ Error! Bookmark not defined. 2.5 System Calibration ....................................................................... Error! Bookmark not defined. 2.5.1 Calibration Tag Placement .........…

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DRAFT Model: 1104 Tag User’s Manual (RFID) Tracking System PLUS Location Systems Cummings Research Park 4955 Corporate Drive, Suite 101 Huntsville, AL 35805 USA www.PLUS-LS.com Tel: +1.256.217.4072 Fax: +1.256.922.0387 2 PLUS Tag User’s Manual DRAFT Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase Nondisclosure Provisions This manual contains PLUS Location Systems (PLUS) Proprietary Information. Purchasers of this device are reminded of their obligation to protect PLUS confidential and proprietary information in accordance with the Terms and Conditions (T&C) of sale. Rights Rights to use this documentation are set forth in the Terms and Conditions accompanying the PLUS hardware. Regulatory Notice U.S. Operation. This device complies with Part 15 of the FCC Rules. Operation is subject to the following 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. (3) Operation on board an aircraft or a satellite is prohibited. (4) Devices operating under this section may not be employed for the operation of toys. (5) Except for operation onboard a ship or a terrestrial transportation vehicle, the use of a fixed outdoor infrastructure is prohibited. A fixed infrastructure includes antennas mounted on outdoor structures, e.g., antennas mounted on the outside of a building or on a telephone pole. This outdoor infrastructure prohibition applies to intentional ultra-wideband (UWB) emitters. Operation in disregard of these conditions is a violation of 47 U.S.C. 301 and could subject the operator to serious legal penalties. Disassembling or modifying the unit will void FCC compliance and void PLUS warranty provisions. Non-U.S. Operation: This product has not been authorized for use or commercial exploitation under the regulations of any non- United States government agency. Please confer with your government’s regulatory agency to ensure proper authorizations are obtained. Please consult with PLUS if you have any questions, prior to use. May 2012 DRAFT PLUS Tag User’s Manual 3 Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase Table of Contents 1. INTRODUCTION ..................................................................................................................... 5 2. OVERVIEW ............................................................................................................................. 5 3. SPECIFICATIONS .................................................................................................................. 6 4. BEAM ORIENTATION RECOMMENDATIONS ....................................................................... 6 WARRANTY ........................................................................ ERROR! BOOKMARK NOT DEFINED. 4 PLUS Tag User’s Manual DRAFT Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase Active Change Record Version Comments Release Date Rev X Draft release 3/22/07 DRAFT PLUS Tag User’s Manual 5 Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase 1. Introduction The 1104 Personnel Name Tag is a small, active RFID tag that works as part of a PLUS Real Time Location System. The tag consists of a circuit board with integrated antenna, coin cell battery, and plastic enclosure. The tag is designed to support attachment of a CR80 format ID badge. The tag is worn on a lanyard or clip to enable location information for personnel. 2. Overview Background The 1104 Tag periodically transmits a short (~100 us) packet that is received by a network of PLUS Readers. The Readers generate time of arrival data for the tag, and then send this data across an Ethernet network to a server running the PLUS Location Software. The PLUS software uses the time of arrival from multiple readers to determine an accurate location for the tag. 1104 Tag Each packet transmitted by the 1104 tag consists of pulses transmitted at a 1 MHz pulse repetition frequency (PRF). Data is transmitted using On-Off Keying (OOK) modulation, in which a pulse present in a given timeslot = data value 1, and a missing pulse in the timeslot = data value 0. Each pulse has an RF center frequency of 6.6 GHz.. The tag is ultrasonically welded in its plastic enclosure. There are no user inputs. It is not possible for the user to change RF signal characteristics, PRF, or transmitted data content. The tag antenna is integrated onto the circuit board inside the plastic enclosure and cannot be accessed, removed, or replaced. 6 PLUS Tag User’s Manual DRAFT Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase 3. Specifications The 1104 Tag specifications are listed below. Function: Transmits RF packets Battery Life: 3 Years at 6 Hz Packet Rate Range: 130' typical line of sight Dimensions: 2.28" W x 0.13" D x 3.53" T Weight: 90 oz (25.5g) Temperature: Operating: -4deg F to 131deg F Storage: -22deg F to 140deg F FCC ID: ZEH0412 RF Emissions: FCC 15.250 compliant 4. Beam Orientation Recommendations TBD DRAFT PLUS Tag User’s Manual 7 Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase Warranty Statement and Return Policy WARRANTY PERIOD: Subject to the limitations herein, the warranty period for hardware product to which this warranty applies shall be for one (1) year from the date PLUS Location Systems USA LLC (“PLS”) delivers the product to the shipping carrier. WARRANTY: During the warranty period stated her…

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DRAFT 2 Model: 1104 Tag User’s Manual (RFID) Tracking System PLUS Location Systems Cummings Research Park 4955 Corporate Drive, Suite 101 Huntsville, AL 35805 USA www.PLUS-LS.com Tel: +1.256.217.4072 Fax: +1.256.922.0387 2 PLUS Tag User’s Manual DRAFT Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase Nondisclosure Provisions This manual contains PLUS Location Systems (PLUS) Proprietary Information. Purchasers of this device are reminded of their obligation to protect PLUS confidential and proprietary information in accordance with the Terms and Conditions (T&C) of sale. Rights Rights to use this documentation are set forth in the Terms and Conditions accompanying the PLUS hardware. Regulatory Notice U.S. Operation. This device complies with Part 15 of the FCC Rules. Operation is subject to the following 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. (3) Operation on board an aircraft or a satellite is prohibited. (4) Devices operating under this section may not be employed for the operation of toys. (5) Except for operation onboard a ship or a terrestrial transportation vehicle, the use of a fixed outdoor infrastructure is prohibited. A fixed infrastructure includes antennas mounted on outdoor structures, e.g., antennas mounted on the outside of a building or on a telephone pole. This outdoor infrastructure prohibition applies to intentional ultra-wideband (UWB) emitters. Operation in disregard of these conditions is a violation of 47 U.S.C. 301 and could subject the operator to serious legal penalties. Disassembling or modifying the unit will void FCC compliance and void PLUS warranty provisions. Non-U.S. Operation: This product has not been authorized for use or commercial exploitation under the regulations of any non- United States government agency. Please confer with your government’s regulatory agency to ensure proper authorizations are obtained. Please consult with PLUS if you have any questions, prior to use. Information to User: Caution: Changes or modifications not expressly approved by PLUS Location Systems USA, LLC, may void user’s authority to operate the equipment. NOTE: 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. If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one or more of the following measures: -- Reorient or relocate the receiving antenna. 33 May 2012 DRAFT PLUS Tag User’s Manual 3 Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase -- Increase the separation between the equipment and receiver. -- Connect the equipment into an outlet on a circuit different from that to which the receiver is connected. -- Consult the dealer or an experienced radio/TV technician for help. 4 PLUS Tag User’s Manual DRAFT Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase Table of Contents 1. INTRODUCTION ................................................................................................................... 65 2. OVERVIEW ........................................................................................................................... 65 3. SPECIFICATIONS................................................................................................................. 86 4. BEAM ORIENTATION RECOMMENDATIONS ..................................................................... 86 WARRANTY ...................................................................... ERROR! BOOKMARK NOT DEFINED.7 DRAFT PLUS Tag User’s Manual 5 Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase Active Change Record Version Comments Release Date Rev X Draft release 3/22/07 6 PLUS Tag User’s Manual DRAFT Proprietary Information: Do not disclose unless authorized under a Nondisclosure Agreement and/or the Terms and Conditions signed at time of purchase 1. Introduction The 1104 Personnel Name Tag is a small, active RFID tag that works as part of a PLUS Real Time Location System. The tag consists of a circuit board with integrated antenna, coin cell battery, and plastic enclosure. The tag is designed to support attachment of a CR80 format ID badge. The tag is worn on a lanyard or clip to enable location information for personnel. 2. Overview Background The 1104 Tag periodically transmits a short (~100 us) packet that is received by a network of PLUS Readers. The Readers generate time of arrival data for the tag, and then send this data across an Ethernet network to a server running the PLUS Location Software. The PLUS software uses the time of arrival from multiple readers to determine an accurate location for the tag. 1104 Tag Each packet transmitted by the 1104 tag consists of pulses transmitted at a 1 MHz pulse repetition frequency (PRF). Data is transmitted using On-Off Keying (OOK) modulation, in which a pulse present in a given timeslot = data value 1, and a missing pulse in the timeslot = data value 0. The OOK modulation of the 1 MHz…

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55 44 33 22 11 D D C C B B A A SEAN MINER BLOCK DIAGRAM 4/15/20124/15/2012 SEAN MINER OOK MODULATED 50 Ohm Feed FET POWERCONTROL PIC16F689MICRO-CONTROLLER PROGRAMMING PINS ULPWUTIMER 3 VOLTBATTERY USART DATACLK LOGIC TOCOMBINEDATA & CLK BURST OSCILLATOR TransmitterControl EncodedData/Clk UWBANTENNA 6 Hz 1 MHz Pulse Rate PULSE SHAPING NETWORK 8 MHzCRYSTAL Revision History Date REV Initial Release 4/15/12 A Wednesday, May 15, 2012 Project Size Document Number Rev Date: Sheet of ORIGINATORENGINEERAPPROVEDRELEASED THIS DESIGN AND PRINT IS THE PROPERTY OF PLUS LOCATION SYSTEMS THIS DOCUMENT CONTAINS PROPRIETARY INFORMATION ANDIS LOANED IN CONFIDENCE. THIS DOCUMENTIS SUBJECT TO RETURN UPON DEMAND ON THE EXPRESSCONDITION THAT IT WILL NOT BE USED IN ANY WAY NOTAUTHORIZED BY TIME DOMAIN CORPORATION. APPROVALS DATE Sheet Title 200-0234 A PLUS REGION 1 CR80 VERTICAL TAG B 1 2 4955 CORPORATE DRIVE SUITE 101 Huntsville, AL 35805 Project Size Document Number Rev Date: Sheet of ORIGINATORENGINEERAPPROVEDRELEASED THIS DESIGN AND PRINT IS THE PROPERTY OF PLUS LOCATION SYSTEMS THIS DOCUMENT CONTAINS PROPRIETARY INFORMATION ANDIS LOANED IN CONFIDENCE. THIS DOCUMENTIS SUBJECT TO RETURN UPON DEMAND ON THE EXPRESSCONDITION THAT IT WILL NOT BE USED IN ANY WAY NOTAUTHORIZED BY TIME DOMAIN CORPORATION. APPROVALS DATE Sheet Title 200-0234 A PLUS REGION 1 CR80 VERTICAL TAG B 1 2 4955 CORPORATE DRIVE SUITE 101 Huntsville, AL 35805 Project Size Document Number Rev Date: Sheet of ORIGINATORENGINEERAPPROVEDRELEASED THIS DESIGN AND PRINT IS THE PROPERTY OF PLUS LOCATION SYSTEMS THIS DOCUMENT CONTAINS PROPRIETARY INFORMATION ANDIS LOANED IN CONFIDENCE. THIS DOCUMENTIS SUBJECT TO RETURN UPON DEMAND ON THE EXPRESSCONDITION THAT IT WILL NOT BE USED IN ANY WAY NOTAUTHORIZED BY TIME DOMAIN CORPORATION. APPROVALS DATE Sheet Title 200-0234 A PLUS REGION 1 CR80 VERTICAL TAG B 1 2 4955 CORPORATE DRIVE SUITE 101 Huntsville, AL 35805

Cummings Research Park 4955 Corporate Drive, Suite 101 Huntsville AL 35805 WWW.PLUS-LS.COM +1.256.217.4072 Main +1.256.217.4775 FAX Letter of Agency I appoint SGS North America Inc. to act on our behalf in front of the Federal Communications Commission with respect to all matters relating to certification of equipment under the FCC rules until further notice. I further certify that no party (as defined in 1.2002 of CFR 47, 1995) to this application, including myself, is subject to denial of federal benefits, that includes FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C.,862. Respectfully: Keven Trach Project Manager PLUS Location Systems 4955 Corporate Drive Suite 101 Huntsville, AL 35805

SGS North America Inc. Consumer Testing Services 620 Old Peachtree Road NW, Suite 100, Suwanee, GA 30024 t (770) 570-1800 www.us.sgs.com/cts Member of the SGS Group (SGS SA) Request for Confidential Treatment FCC ID ZEH0412 SGS North America, agent for PLUS Location Systems (PLUS), requests that all schematics be withheld from public disclosure in accordance with Section 0.459 of the Commission’s Rules, 47 C.F.R. § 0.459 (2000), following grant of the application. In support of this request, PLUS submits the following: (1) identification of the specific information for which confidential treatment is sought: PLUS Location Systems seeks confidentiality for all schematics of the device. These exhibits are segregated from the non-confidential exhibits of the application. (2) identification of the Commission proceeding in which the information was submitted or a description of the circumstances giving rise to the submission: The proceeding is that involving the application for equipment authorization (certification) under FCC ID ZEH0412. (3) explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged: This material includes circuit diagrams and board layout information for the system. As such, this material is treated as highly confidential business information. (4) explanation of the degree to which the information concerns a service that is subject to competition: The material for which confidentiality is sought is employed in the design and manufacture of ultra-wideband tracking systems that are offered on a highly competitive basis. Customers for this equipment have a variety of competing sources of supply. (5) explanation of how disclosure of the information could result in substantial competitive harm: Disclosure would, in effect, give away the fruits of the labors of the engineering department, who have designed the equipment and the manufacturing processes. Disclosure would also offer competitors additional unwarranted insight into the state of product development thereby allowing such competitors an advantage that would not be available to them unless they were working with PLUS and had a non-disclosure agreement with PLUS. (6) identification of any measures taken by the submitting party to prevent unauthorized disclosure: The information for which confidential treatment is sought is kept confidential by PLUS and not made available to third parties except pursuant to non-disclosure agreements. 2/2 (7) identification of whether the information is available to the public and the extent of any previous disclosure of the information to third parties: To the knowledge of those preparing this application, the information has not been disclosed publicly heretofore. The protection sought is narrowly drawn and pertains to certain specific implementations of ultra- wideband technology. (8) justification of the period during which the submitting party asserts that material should not be available for public disclosure: This material should not be disclosed for at least five years. Disclosure of the design information would lead to insights into both designs and manufacturing techniques and could have an adverse competitive effect for many years to come. (PLUS is aware, for example, of overseas competitors for this application.) As this is industrial equipment, we expect the equipment to be used for more than five years in some cases. (9) any other information that the party seeking confidential treatment believes may be useful in assessing whether its request for confidentiality should be granted: See item 8 above. Note that the equipment for which approval is being sought will be employed in applications that inherently carry a premium on security.

1. Please clarify whether you would like the schematics to be held permanently confidential, temporarily confidential or non-confidential. Even if an exhibit is marked non- confidential, by default all information is not accessible by the public before the application is approved. After the grant is issued, all non-confidential information would be viewable by the public. The schematics file should have been marked as confidential when submitted since you requested so in the confidentiality request letter. I will mark the file permanently confidential per your 5/21 request. If this is not your intention, please let me know. The intention is to keep the schematics confidential. 2. Application Form 731, User’s Manual, and test report all refer to the EUT device as UWB (Ultra Wide Band). However, the EUT is actually applying for equipment authorization under Part 15C, and in particular 15.250, as a Wideband Transmitter with the equipment type of WBT, not UWB (Part 15, Subpart F). Please remove reference to UWB to avoid misleading consumers. Once the Form 731 has been submitted, I cannot return to it to make corrections. When I filed, I realized my mistake and tried to correct to WBT instead of UWB. The system locked up, but I thought the change was made successfully. Would you kindly make the change from your end? Or if you can put the application in a mode where I can modify the Form 731, I will be glad to handle that myself. 3. User’s Manual should include information to user specified in Part 15.21 (mandatory) and 15.105 (if applicable). Please find attached the revised draft manual. The Part 15.21 and Part 15.105 information can be found on page 2 4. Please include in the operational description the following information important for the reviewer to assess the EUT’s RF characteristics and test data: a. source data rate; b. all intermediate frequencies used in up-converting 1 MHz pulse train to the carrier frequency (block diagram should include such information as well); c. describe any channel coding, frequency hopping, pulse shaping, spectrum spreading, channel step, number of channels, if applicable; d. antenna gain and antenna pattern; e. since there is a programming interface, please describe what can be programmed and how. This information has been provided in the updated User Manual and operational description. 5. Frequency stability test should have been included in the test report per 15.250(a), over the advertised temperature range in the user’s manual (-4 - 131 degree F) as well as battery voltage fluctuation as specified in 2.1055. This information has been provided in the updated User Manual and operational description. 6. Since 15.250 rules on radiated emission and peak power are all specified in power, please present raw field strength measurement data as well power level data in Sections 4-7. Sections 4 and 5 have been updated to show the data in power. Please note that Section 6 already had the emissions levels reported as power. Please note that Section 7 does not specify limits as power, so there is no need to report values in this section as power. 7. The test setup photos show that tests were conducted in an anechoic chamber. However, strong background WiFi signals can be seen on several of the spectrum plots. Please explain. Please not that this is not a strong WiFi signal. It is roughly 40 dB below the FCC Class B limit at 1 meter. It is also more than 15 dB below the UWB limit. The source for this emission was a cable that was penetrating the absorber lined shielded enclosure. Due to the length of time it takes to re-measure these tests and the very large margin of the peak ambient signal to the RMS noise floor, it was deemed unnecessary to retest with the offending cable removed. Also, there is only a requirement that ambient noise levels be more than 6 dB below the limit, which is demonstrated in these plots.

SGS North America Inc. Consumer Testing Services 620 Old Peachtree Road NW, Suite 100, Suwanee, GA 30024 t (770) 570-1800 www.us.sgs.com/cts Member of the SGS Group (SGS SA) Request for Confidentiality Date: 6/8/2012 Subject: Confidentiality Request for: ZEH0412 Pursuant to FCC 47 CRF 0.457(d) and 0.459 and IC RSP-100, Section 10, the applicant requests that a part of the subject FCC application be held confidential. Type of Confidentiality Requested Exhibit Short Term Permanent Block Diagrams Short Term External Photos Short Term Permanent* Internal Photos Short Term Permanent Operation Description/Theory of Operation Short Term Permanent Schematics Short Term Test Setup Photos Short Term Permanent User’s Manual Plus Location Systems has spent substantial effort in developing this product and it is one of the first of its kind in industry. Having the subject information easily available to "competition" would negate the advantage they have achieved by developing this product. Not protecting the details of the design will result in financial hardship. Permanent Confidentiality: The applicant requests the exhibits listed above as permanently confidential be permanently withheld from public review due to materials that contain trade secrets and proprietary information not customarily released to the public. Sincerely, By:__________________________ __David J. Schramm______________ SGS EMC Manager Agent for Plus Location Systems

EXTERNAL PHOTOGRAPHSPlus Location Systems 2 3 4 5 6

FCC ID LABELPlus Location Systems 2

FCC ID LABEL LOCATIONPlus Location Systems 2

INTERNAL PHOTOGRAPHSPlus Location Systems 2 3 4

The CR80 Vertical Tag is a small, act…

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