Request for Confidential Treatment

0268-EX-PL-2010 Text Documents

Commlabs, Inc.

2010-06-14ELS_107987

SQUIRE, SANDERS & DEMPSEY L.L.P. Suite 500 I IEJAL 1201 Pennsylvania Avenue, N.W. I Washington.D.C. 20004 I ± \VORLPWIDE Office: 1.202.626.6600 Fax: 41.202.626.6780 Direct: +1.202.626.6615 bo1cottssd.coni June 14. 2010 ElECTRONiC FILING James Burtle Experimental Licensing Branch Office of Engineering and Technology Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Commiabs, inc. Request for Confidential Treatment; Application for Experimental Authorization EIS File No. 0268-EX-PL-2010 Dear Mr. Burtle: Commlabs, Inc. (“Commiabs”), through its attorneys, hereby requests that the included exhibits to its experimental application for authorization be confidential treatment and withheld from public given inspection pursuant to Section 0.459 of the Commission’s Rules, 47 C.F.R. § 0.459. Pursuant to the Freedom of Information Act (“FOIA”), public disclosure is not required for “trade secrets, commercial or financial information obtained from a person and privileged and confidential.” 1 The commercial infonnation contained herein falls squarely within this exemption from public disclosure. Pursuant to Section 0.459(b) of the Commission’s Rules, 47 C.F.R. § 0.459(b), the following information is provided in support of the request for confidential treatment. The information for which confidential treatment is sought is a description of Commiab’s specific efforts to develop and test xireless location iechnolog filed as an attachment to the Commlabs’ experimental application. ELS File No. 026$-EN-PL-20lU. This information is proprietary trade secrets and commercial information of - Cornmlabs.’ [he market for development of wireless location technologies is a \ cry competitl e one. 5 S.C. 552(hH1F ce a! 4 (FR, § O.45d). 2 See 47 C.F.R. ().459(b)( 1). (2). See 47 C.F.R. O.459(h)(3). See 47 C.F.R. 0.459(b)(4).

SQuIRE, SANDERS & DEMPsEY L.L.P. James Burtle June 14, 2010 Page 2 Due to the competitive environment for such services, release of this information could harm Cornmlabs. 5 This is especially true due to the fact that equipment has not yet been developed to provide cost effective and reliable terrestrial-based wireless location monitoring services and competing efforts are ongoing to develop and deploy such equipment. It is customary for companies such as Commiabs not to disclose the details of its technologies and methods. The commercial information contained in the exhibit has been strictly controlled by Commiabs, with distribution limited to internal use only and to other parties (pursuant to appropriate non-disclosure agreements) only for the specific purpose of conducting research, development, and testing of the 6 Commlabs has not disclosed this commercial information to the public and disclosure to any technology. other party has been only as described herein.’ Commlabs requests that the subject information not be 8 The competitive technical and commercial made routinely available for public inspection at any time. information contained in the exhibit would benefit Commiabs’ competitors and harm Commlabs if it is released for public inspection at any time. Finally, the public interest will be served by the granting of this request for confidential treatment. It is in the public interest that equipment and technologies be developed to provide wireless location monitoring services to facilitate competition in the provision of such services. 9 Sincerely, COMA LABS, INC. Bie A. Olcott Joshua T. Guyan Squire, Sanders & Dempsey L.L.P. 1201 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Its Attorneys See 47 CFR. 0459(b)(5). 6 See 47 CFR. 0459(b)(6). See 47 CF.R. 0459(b)(7). See 47 C.F.R. 0.459(b)(S). “See 47 C.F.R. O.459(b)(9).


Document Created: 2010-06-14 15:56:07
Document Modified: 2010-06-14 15:56:07
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