request for confidentiality

0163-EX-PL-2014 Text Documents

ADC Automotive Distance Control Systems GmbH

2014-02-24ELS_146174

@ntinental *
Date: 07 February 2014



Federal Communications Commission
Office of Engineering and Technology



Confidentiality Request concerning Test License Application — SRR3—B

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 wamning 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 treatment is sought;

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

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

              Application for OET EXPERIMENTAL LICENSE using Form 442

        (     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 concems a service that is subject to competition;

              Not applicable. The functionalities that wetest (blind spot detection, lane change assist and rear cross
              traffic assist are already public), however, a new hardware generation is used.

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




ano                                         Prone +43 sate os000    Commercial registy       Managing Orectrs        Banking account
Autcmstive Distance Control Systems GmBHl   Toltex +49 2020000540   Kemeten                  Friednch Angorbauer     Destsche Bonk AG
PoterDomierSrasso 10                        win:corinontal          meo s1                   Ue Gau                  Friedrctanaten
Bt31 Lindou                                 copenatoncon            useioar. oe arzresise                            Naic eso roone
Gemany                                                              Tmtie o7 t 2078                                  Aecountre 34 non to


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

 (6) Identification of any measures taken by the submitting party to preventunauthorized disclosure;

     Such information and knowledgeare 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 beenpublicized 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 treatmentbelieves may be useful in assessing
     whetherits 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 contributescritically to the overall success of the product launch. Any premature leak of such
     informati       competitors may undercut the competitive advantages that ADC possesses.




      pla .(f .                                                                22 /2
                                                                             ~]{@AX
     Dr. Thomas\Brohm                                                      Dr. Frank Gruson
     Vice President Development                                            System Engineering &‘Frequency
                                                                           Management WW
             *\


@ntinental*
                                                                                                Chassis & Safety




Date: 07 February 2014



Federal Communications Commission
Office of Engineering and Technology



Confidentiality Request concerning Test License Application — SRR3—B

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 ofthe specific information for which confidential treatment is sought;

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

        C     Identification of the Commission proceeding in which theinformation was submitted or a description of
              the circumstancesgiving 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 theinformation concems a servicethat is subject to competition;

              Not applicable. The functionalities that we test (blind spot detection, lane change assist and rear cross
              traffic assist are already public), however, a new hardware generation is used.

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



w00                                        Phone +19 nare oeco0       Conmersal regite:        Managig Drectors        Barking account
Automative Distance Contral Systems GmBH   Taleax +49 0002 9600 548   Kemeten                  Friednch Angorbacer     Deuscho BarkAG
PoterDermiecStrasse 10                     wnncortinontal             wan se                   Uve Grou                Fedicthunaten
satat Lindoo                               comeatoncon                ustibnc be arztesioe                             weic esoroone
Grman                                                                 Tmeale 197 91 20078                              Recountre 24 00060


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

 (6    Identification of any measures taken by the submitting party to preventunauthorized disclosure;

       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 extentof any previous
       disclosure of theinformation to third parties;

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

 (6) 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)

 @ Any other information that the party seeking confidential treatment believes may be useful in assessing
       whetherits 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 advantages that ADC possesses.




                                                                             3e (.
       Dr. Thomas\Brohm                                                     Dr. Frank Gruson ~
       Vice Presidgnt Development                                           System Engineering & Frequency
                                                                            Management WW


                                                                                         Division Chassis & Safety
@ntinentali




February 06, 2014


To
IBRACE — Instituto brasileiro de Certificago



The Company, ADC Automotive Distance Control Systems GmbH, located at Peter—Domier—
Str.10, D—88131 Lindau, Germany as being the manufacturer of product SRR2—A, hereby states
that the above mentioned product — since last certified — has not been altered in any way, not
suffering modification of its project, circuits, schemes, components, technical specifications and
external appearance, except some minor changes in the power supply & CAN circuitry of the
processor board. This was necessary in order to adapt the sensor to different customer
interfaces.

Therefore, in terms of functionality and RF emissions, the actual product that is being sold is
identical to the sample used on the last certification.




Thanks in advance.




Regards,




Dr:Thomas Brohm
Vice President          Development
                                                                                         Engineering & Frequency
                                                                                         Management WW




o                                       Phone +1 382 05000         Commertil regstry     Maragina Dreors       Banking account
Automatve Distance Control Systems GmbH Teletnc+19 8302 9000 510   Kemplen:              Fredch Angortaver     Deutsche Bank AG
PoterDomearSrasse 10                    wincontinontal:            nR oite               Ure Gou               Eredramnaton
8131 Lindou                             Eotroraton com             usto. oe orzresio«                          nelc seo rov e1
Germary                                                            Tmeae tor w21 2ours                         Recsuntre 2s onn to


Continentali
                                                                                       Division Chassis & Safety




February 06, 2014


To
IBRACE — Instituto brasileiro de Certificagao



The Company, ADC Automotive Distance Control Systems GmbH, located at Peter—Domier—
Sir.10, D—88131 Lindau, Germany as being the manufacturer of product SRR2—A, hereby states
that the above mentioned product — since last certified — has not been altered in any way, not
suffering modification ofits project, circuits, schemes, components, technical specifications and
external appearance, except some minor changes in the power supply & CAN circuitry of the
processor board. This was necessary in order to adapt the sensor to different customer
interfaces.

Therefore, in terms of functionality and RF emissions, the actual product that is being sold is
identical to the sample used on the last certification.




Thanks in advance.




Regards,




                                                                                       Engineering & Frequency
                                                                                       Management WW




ano                                   Phone +9 6302 00000       Commercal regsty:      Managing Drectors     Banking account
Astonatve Distance Contal Systems GmeH Telox +49 Bdk Gev0 Saa   Kempten                Freancn Argotbauer    beceas Ban h
PoterDomerStrosse 10                   wane cootinontal:        nR s10e                Use Gou               Frednctstalon
E131 Gnoss                             toportorcon              ustibi. oe orzresis«                         NBlo aso rov ea
Geman                                                           Tmeaie 197 1 20u78                           Aceaunire m conto



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Document Modified: 2019-04-25 08:25:10

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