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, 1

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. 2

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 3

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 4


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