Narrative Statement

0014-EX-PL-2016 Text Documents

Broadcom Corporation

2016-01-11ELS_171271

                                                                 Broadcom Corporation
                                                                        FCC Form 442
                                                                     0014-EX-PL-2016


                             NARRATIVE STATEMENT

        Pursuant to Sections 5.51 and 5.53 of the Commission’s rules, 47 C.F.R. §§ 5.51,
5.53 (2014), Broadcom Corporation (“Broadcom”) respectfully requests an experimental
license to operate in the 2500-2570/2620-2690 MHz band for the purpose of conducting
tests and demonstrations in connection with the design and development of long term
evolution (“LTE”) equipment.

     AS DISCUSSED BELOW, BROADCOM RESPECTFULLY REQUESTS
THAT THE COMMISSION REVIEW THIS APPLICATION BUT DEFER THE
GRANT OF THIS NEW LICENSE UNTIL AFTER THE EXPECTED ACQUISITION
OF BROADCOM BY AVAGO TECHNOLOGIES LIMITED (“Avago”) IS
COMPLETED ON OR ABOUT FEBRUARY 1.

        This new experimental license would replace the pre-existing experimental
license issued to Broadcom under call sign WH2XAN. See OET File No. 0031-EX-ML-
2015 modifying OET File No. 0015-EX-PL-2014. With this new license, Broadcom
seeks to conduct experimental tests both within the immediate area of its campus at Irvine,
California, as previously authorized pursuant to license WH2XAN, and at a second
location in Bellevue, Washington. The testing to be conducted at Bellevue, Washington
would be conducted at the same power levels and frequencies as the testing previously
conducted at Matawan, New Jersey, pursuant to license WH2XAN.

       The following provides more details for this request.

A.     Purpose of Operation and Need for Experimental License:

        Broadcom Corporation is a global leader and innovator in semiconductor
solutions for wired and wireless communications and is continually engaged in the design
and development of new and innovative communications equipment. The modification of
its experimental authority requested herein will allow the company to enhance its testing
and demonstration of the performance and functionality of prototype devices.
Specifically, Broadcom seeks to enhance its ability to evaluate cellular base station and
handset characteristics.

B.     Locations of Proposed Operations:

        Broadcom proposes to conduct the tests using up to eight base station transmitters
and antennas that will be installed at temporary fixed locations indoors within the
immediate area of its campus at Irvine, California. Specifically, the stations will be
installed within buildings located at or in the vicinity (i.e., within a radius of one
kilometer) of its office at 5300 California Avenue, Irvine, California. In addition,
Broadcom proposes to conduct additional tests using up to eight base station transmitters
and antennas that will be installed at temporary fixed locations indoors within buildings
located at or in the vicinity (i.e., within a radius of 500 meters) of 2018 156th Ave NE,


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                                                                  Broadcom Corporation
                                                                         FCC Form 442
                                                                      0014-EX-PL-2016

Bellevue, WA 98007. Both locations are further identified in the accompanying
application on FCC Form 442.

       Please note that the requested authority in Irvine, California is identical to that
authorized at that location pursuant to license WH2XAN, and the requested authority in
Bellevue, Washington is consistent with the authority Broadcom received for its
experimental operations in Matawan, New Jersey pursuant to that same license.

C.     Technical Specifications:

       1.      Frequencies Desired

       Broadcom requests authorization to operate in the band 2500-2570/2620-2690
MHz.

       2.      Effective Radiated Power

        All power levels will comply with the limits set forth in the FCC’s rules,
including those relating to human exposure to radiation. The units to be deployed in
Irvine are configured to operate at a power level of 250 mW effective radiated power
(“ERP”), and the units to be deployed in Bellevue are configured to operate at a power
level of 100 mW ERP. Broadcom will vary the actual powers within the maximums
noted above to test coverage results.

        Broadcom has also reviewed the sharing arrangement between Canada and the
United States regarding coordination of use of the frequency bands 2155–2162 MHz and
2500-2690 MHz. Given the distance between Bellevue and the Canadian border and the
low operating ERP of the Bellevue facility, the testing will not produce a power flux
density at ground level anywhere in Canadian territory that exceeds -116 dBW/m2 in any
1 MHz bandwidth, and therefore no further coordination with Canadian authorities or
users to avoid harmful interference will be required pursuant to the terms of Section 3.2
of that arrangement.

        In addition, Broadcom will evaluate environmental considerations to ensure
compliance with Section 1.1307 of the FCC’s rules, 47 C.F.R. § 1.1307 (2014), and, in
particular, the human exposure requirements set forth in FCC OET Bulletin No. 65.

       3.      Modulation and Emissions

       The primary emission designator for operations in Irvine is 10M0D7D. The
primary emission designator for operations in Bellevue is 15M0D7D. Other emission
modes may be utilized, but in no event will the emissions extend beyond the frequency
bands requested.




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                                                                  Broadcom Corporation
                                                                         FCC Form 442
                                                                      0014-EX-PL-2016

       4.      Antenna Information

        The fixed base station transmitter antennas will be located indoors at both
locations. The antenna elevations above ground level will not be greater than 63 feet.
Moreover, no antennas will be mounted in a fashion that will require approval under
FAA and FCC rules and regulations.

       5.      Equipment To Be Used

       Broadcom expects that it will be able to conduct its tests and evaluations with a
maximum of eight base stations and twenty five mobile/portable units. In addition, as
noted above, Broadcom will limit the power, area of operation, and transmitting times to
the minimum necessary to evaluate the equipment.

D.     Restrictions on Operation:

        Broadcom is not seeking authority to perform a market study under this
experimental license. Moreover, no fees will be charged to entities using the equipment
during this test. After the test is completed, Broadcom will recall and recover all devices
that do not comply with FCC regulations.

        Broadcom also recognizes that the operation of any equipment under an
experimental authority must not cause harmful interference to authorized facilities.
Should interference occur, Broadcom will take immediate steps to resolve the
interference, including if necessary arranging for the discontinuance of operation.

        In addition, Broadcom will advise entities using the equipment that permission to
operate has been granted under experimental authority issued to Broadcom, that such
operation is strictly temporary, and that the equipment may not cause harmful
interference. Entities will also be advised in accordance with Section 2.803 of the
Commission’s rules, 47 C.F.R. §2.803 (2014), that any unapproved devices have not been
authorized as required by the rules of the FCC and are not being offered for sale or lease,
or sold or leased, until authorization is obtained.

E.     Public Interest Statement:

        Broadcom submits that issuance of an experimental license as requested is in the
public interest, convenience, and necessity. Grant of an experimental license will permit
Broadcom to develop innovative equipment that will accommodate the communications
needs of users.

F.     Deferral Request:

        Broadcom has entered into an agreement with Avago Technologies Limited
through which Broadcom will be acquired by Avago. Upon the completion of that
acquisition, Broadcom will become a direct subsidiary of BC Luxembourg S.a r.l. (FRN
0025177627) and an indirect subsidiary of Pavonia Limited (FRN 0025177593). Pavonia


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                                                                Broadcom Corporation
                                                                       FCC Form 442
                                                                    0014-EX-PL-2016

Limited is a new entity formed by Avago in connection with the planned acquisition and
will serve as the ultimate parent of Broadcom after the acquisition is completed.

        In order to streamline the Commission's review of this license application in the
context of the expected acquisition, Broadcom respectfully requests that the Commission
review this application but defer the grant of this new license until the acquisition of
Broadcom has been completed. At that point, Broadcom’s counsel would contact the
FCC Office of Engineering and Technology Experimental Licensing Branch to notify the
office of the completion of the transaction and request the grant of the license.

       Broadcom expects to maintain its ongoing testing operations under its existing
experimental license (Call Sign WH2XAN) until immediately before the acquisition is
completed, at which time that license would be surrendered.

G.     Contact Information:

       For questions about this application, please contact:

           Company Contact:                         Legal Contact:

           Kevin Boyd                               Joshua Gruenspecht
           Director, Systems Design                 Skadden, Arps, Slate, Meagher &
             Engineering                               Flom LLP
           Redmond Center                           1440 New York Avenue, N.W.
           2018 156th Ave. NE, Suite 100,           Washington, D.C. 20005
             Building F                             (202) 371-7316
           Bellevue, WA, 98007                      joshua.gruenspecht@skadden.com
           (425) 748-5029
           kboyd@broadcom.com


           “Stop Buzzer” Contacts:

           At Bellevue, WA Site:                    At Irvine, CA Site:
           Kevin Boyd                               David Hoemberg
           2018 156th Ave. NE, Suite 100,           5300 California Avenue
             Building F                             Irvine, CA 92617
           Bellevue, WA, 98007                      (949) 926-6350
           (425) 748-5029                           hoemberg@broadcom.com
           kboyd@broadcom.com




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Document Created: 2016-01-11 11:42:24
Document Modified: 2016-01-11 11:42:24

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