request for confidentiality

0050-EX-PL-2014 Text Documents

ADC Automotive Distance Control Systems GmbH

2014-01-17ELS_144887

                                                                                            Chassis & Safety
                         e     ntali
@ntin




Date: 14 January 2014



Federal Communications Commission
Office of Engineering and Technology



Confidentiality Request concerning Test License Application for ARS4—A


ADC Automotive Distance Control Systems GmbH is a 100% subsidiary of Conti Temic microelectronic GmbH
(‘Conti Temic‘) and is registered with the objective of development, manufacture, distribution and servicing of
distance warning and control systems for the automotive industry at the local court of Kempten/Germany.
Conti Temic is in turn a 100% subsidiary of UMB Beteiligungs GmbH, which is a 100% subsidiary of Continental
AG.

Pursuant to Sections 0.457 and 0.459 of the Commission‘s Rules, we hereby request confidential treatment of
information accompanying this application as outlined below.


Exhibit Type                                                             File Name
Scope and Objective of FCC Test License Application                      Scope and Objective of FCC Test License
                                                                         Application.pdf



According to §0.459(b), we make our request based on the following reasons for withholding the materials from
inspection:

          (1) Identification of the specific information for which confidential treatmentis sought;

               The entire scope and objectives of thetest experiment to be conducted under this application, as
               indicated in the above mentioned exhibit

          (2   Identification of the Commission proceeding in which the information was submitted or a description of
               the circumstances giving rise to the submission;

               Application for OET EXPERIMENTAL LICENSE using Form 442

          (3) Explanation of the degree to which the information is commercial or financial, or contains a trade secret
              or is privileged;

               The knowledge and information are privileged and restricted to solely ADC and its customers

          (4) Explanation of the degree to which the information concerns a service thatis subject to competition;

               Not applicable. The functionalities that we test (emergency braking and adaptive cruise control) are
               already public, however, a new hardware generation is used

          (5) Explanation of how disclosureof the information could result in substantial competitive harm;



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Atmetve Dstance Control Systems GmoH   Teltax »49 ed62 9500 548   Kemplen                  Fredrch Angorauer       Destsche Bank AG
PoterDomerStrasse 10                   ww continontal             Hee sios                 Ue Grau                 Fredrchanaten
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Germany                                                           Tachc 127 t2t 20178                              Accaunt w 34 000 2


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     It provides privileged knowledge to our competitors of our research and development progress and plans,
     thereby giving them a competitive advantage.

     Identification of any measures taken by the submitting party to prevent unauthorized disclosure;
 0




     Such information and knowledge are strictly protected and limited to employees and customers.

 (7)_ Identification of whether the information is available to the public and the extent of any previous
      disclosure of the information to third parties;

     Information has not been publicized and contracted third parties are bound by Non—Disclosure
     Agreements. For customers involved, development contracts exist

 (8) Justification of the period during which the submitting party asserts that material should not be available
     for public disclosure; and

     The duration of the entire experimental license shall cover the time until the market introduction (end of
     2015)

 (9) Any other information that the party seeking confidential treatment believes may be useful in assessing
     whether its request for confidentiality should be granted.

     The Advanced Driver Assistance Systems market is attractive and a fast growing one. Hence, the timing
     and progress of our product research and development (R&D) process, and its discretion in making it
     public contributes critically to the overall success of the product launch. Any premature leak of such
     information to competitors may undercut the competitive advantagesthat ADC possesses
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     Christian Zeiger                                                      Dr. Frank Gruson
     Head of System Engineering                                            Manager Radar          m rchitecture



Document Created: 2019-04-25 23:18:10
Document Modified: 2019-04-25 23:18:10

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