Request for Confidential Treatment

0408-EX-PL-2015 Text Documents

COUNTY INFORMATION SERVICES, LLC

2015-06-22ELS_163882

COUNTY INFORMATION SERVICES 500 N. Capital of Texas Hwy, Building 4-100 Austin, Texas 78746 June 22, 2015 By Electronic Filing Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 Attention: Office of Engineering and Technology Experimental Licensing Branch Re: County Information Services Application File No.: 0408-EX-PL-2015 Request for Confidential Treatment On June 22, 2015, County Information Services (“CIS”) filed the above-referenced application for experimental license with the Commission. CIS requests confidential treatment of the attached Narrative Statement, Drawing of the Transmit Facility, Necessary Bandwidth Description, Antenna Information Exhibit, and Antenna Vertical Profile Sketch (the “Confidential Information”) pursuant to Section 0.459 of the Commission’s rules. 1. Information Subject to this Request for Confidential Treatment CIS requests confidential treatment for the Narrative Statement and its attachments associated with the above-cited experimental license application. These materials contain specific information about the technical parameters to be used in CIS’s experiment, including the experimental design, antenna specifications, and trade secrets belonging to CIS or its technical consultants. CIS does not seek confidential treatment for elements of the application that have been filed without a request for confidentiality using the Experimental Licensing System or the emergency contact information provided with the application. 2. Relevant Commission Proceeding This information is submitted in support of the application for experimental license that CIS has filed on this date with the Commission. 3. Explanation of the Nature of the Confidential Information Certain designs, practices, and techniques described in the Narrative Statement constitute trade secrets of CIS and its contractors. 4. Competition in the Relevant Service The business of wireless data transmission has become extremely competitive and a successful experiment would provide a significant benefit for CIS. 5. Substantial Competitive Harm Disclosure of the information in the materials could give CIS’s competitors an unfair advantage and discourage the investment of time, effort, and expense in the potential discovery and development of communications processes and technology.

6. CIS Has Taken Substantial Measures to Prevent Unauthorized Disclosures CIS has disclosed the Confidential Information only to its personnel, its attorneys, its technical consultants, and Commission Staff at a meeting for which confidential treatment of the information was requested. These parties have agreed to prevent unauthorized disclosure of the information or are bound by professional confidentiality requirements. CIS has requested that all documents containing its confidential information be encrypted and password-protected by its employees, contractors, and consultants. 7. Prior Disclosure of the Confidential Information CIS has not made the information in the Narrative Statement and its attachments available to the public and it is not generally available from any other source. 8. Justification of the Protection Period CIS requests that its Confidential Information be withheld from public inspection indefinitely because CIS should be entitled to the benefits of its experimental designs and conclusions until such time as CIS has developed a business plan that requires disclosure. 9. Additional Information The Commission should encourage the development of more efficient and cost-effective methods of data transmission. Providing experimenters with the protection of their proprietary information during the course of experiments supports that goal. Additionally, the public interest is not served by disclosure of the Confidential Information. Accordingly, this material qualifies for confidential treatment under the Commission’s rules. CIS requests that the material be withheld from public inspection and asks that the Commission process any request for disclosure pursuant to the terms of Section 0.461 of the Commission’s rules. Respectfully submitted, /s/ Richard Reeuwijk Director COUNTY INFORMATION SERVICES 2


Document Created: 2015-06-22 16:34:02
Document Modified: 2015-06-22 16:34:02
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