Request for confindentiality

0035-EX-CN-2019 Text Documents

Cisco Systems

2019-01-29ELS_222029

01/29/19

Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th St. NW
Washington DC 20554

Re: Request for Confidential Treatme nt of Material Filed
Application : 0035-EX-CN-2019

FILED ELECTRONICALLY

Dear Ms. Dortch:

    Cisco Systems requests, per Section 0.459 of the Commission’s rules, confidential
treatment of material filed in support of the above-referenced application. Cisco submits
the following in conformance with the requirements of Section 0.459(b) of the
Commission’s rules:


   1. Identification of the specific information for which confidential treatment is
      sought.
          • Description of radio system
          • Name of vendor of product

   2. Identification of the Commission proceeding in which the information was
      submitted.
          • OET Experimental License Application File



   3. Explanation of the degree to which the information is commercial or financial, or
      contains a trade secret or is privileged.
          • The information is a commercial trade secret.



   4. Explanation of the degree to which the information concerns a service that is
      subject to competition.
          • Ground surveillance radar is available from a number of vendors


5. Explanation for how disclosure of the information could result in substantial
   competitive harm.
      • The information contained in the document presents information about a
          conceptual product that is being evaluated for possible commercial
          development. If competitors were to have access to this document, they
          would have knowledge of Cisco’s pending business plans, and potentially
          would be able to use this advance knowledge to their advantage. This
          could result in substantial competitive harm to Cisco’s ability to bring a
          product to market, should that decision be made.


6. Identification of any measures taken by the submitting party to prevent
   unauthorized disclosure.
       • Cisco manages its product development to ensure that competitors do not
            get early access to details about forthcoming products. Information about
            Cisco’s products under development including engineering development
            or demonstration tools is considered by the company to be commercially
            sensitive information that employees are not permitted to discuss outside
            the company.

7. Identification of whether the information is available to the public and the extent
   of any previous disclosure of information to third parties.
       • Information about product development is not routinely provided to the
            public, and is not available on Cisco’s website. No information about this
            product has been disclosed.

8. Justification of the period during which the submitting party asserts that material
   should not be available for public disclosure.
       • Cisco requests that the above-identified material not be disclosed for 1
            year. This period should provide sufficient time for Cisco to make its
            evaluation of the product.

9. Any other information that the party seeking confidential treatment believes may
   be useful in assessing whether its request for confidentiality should be granted.
       • Cisco has not offered a comparable solution in the marketplace in the past.
          Even the knowledge that Cisco is evaluating market entry, and has
          obtained a Experimental License, would be valuable market information
          for existing solution providers.


                                                         Sincerely,



                                                         David Case





Document Created: 2019-01-29 13:03:07
Document Modified: 2019-01-29 13:03:07

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