Request for Confidential Treatment and Exhibits A and B PUBLIC

0379-EX-ST-2017 Text Documents

Google Inc.

2017-04-05ELS_190130

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 Date: April 5, 2017 Subject: Public and Redacted Versions of Request for Confidential Treatment and Complementary Exhibits To Whom It May Concern: Google Inc. (Google), pursuant to 5 U.S.C. § 552 and Sections 0.457 and 0.459 of the Commission's Rules, 47 C.F.R. §§ 0.457, 0.459, hereby requests that certain information complementary to its above-referenced application for Special Temporary Authority (STA) be treated as confidential and not subject to public inspection. The designated information constitutes confidential and proprietary information that, if subject to public disclosure, would cause significant commercial, economic, and competitive harm. As described below, Google’s request satisfies the standards for grant of such requests set forth in Sections 0.457 and 0.459 of the Commission’s Rules. In accordance with Section 0.459(b) and in support of this request, Google provides the following information: 1. Identification of the Information for Which Confidential Treatment is Sought: Google’s request for confidential treatment is limited to the following information that has been redacted from the STA and complementary exhibits. Google does not seek to withhold from public inspection information necessary for interference mitigation, including applicant name, contact information, test location, frequency, output power, effective radiated power, emission characteristics and modulation. Exhibit A - Narrative Statement: Google requests confidential treatment of the following underlined text from Exhibit A that contains confidential and proprietary information regarding the proposed tests/experiments: Consistent with the standards set forth in Section 5.61 of the Federal Communications Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.61, Google Inc. (Google) outlines below its need for the requested Special Temporary Authority (STA) and the compelling reasons why 0379-EX-ST-2017 should be granted expeditiously. Google requests that the STA be granted for a period of 180 days. The STA is needed for the demonstration and testing of a prototype device (Device) that is expected to enhance the development, application, and use of [REDACTED]. Request for Confidential Treatment - Page 1

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 The Device consists of a [REDACTED] and a [REDACTED] to enable [REDACTED]. The Device utilizes [REDACTED] to enable [REDACTED], as needed and consistent with [REDACTED]. The users of the Device will be professional Google employees and contractors, and also potentially external trusted professional developers [REDACTED]. The Device is not intended to be used by general public. The requested authorization will not be used to conduct any commercial operations, and all Devices will be collected or destroyed at the end of the experimentation period. No material risk of harmful interference will be generated by the proposed testing. The Device meets all Part 15 Class A and nearly all Class B device limits for electromagnetic compatibility and radio operations.1 During unintentional radiated emission tests conducted by Underwriters Laboratories (UL) at a distance of three meters, the Device exceeded Part 15 Class B device limits2 at two frequencies—43.4 MHz (5.9 dB deviation) and 639.0 MHz (7.0 dB deviation). The unintentional radiated emission of the Device meets Class A device limits. Because most residential digital devices are immune by design to electromagnetic interference at a much higher level as part of European Union EMC requirements,3 the risk of generating harmful interference to other devices operating on these frequencies is minimal. Moreover, the Device’s electrical, mechanical, thermal, optical and RF exposure (SAR) safety have been confirmed by tests and evaluations conducted by UL. For these reasons, Google requests approval of this STA request. Exhibit B - Technical Information: Google requests confidential treatment of the following underlined text from Exhibit B that contains confidential and proprietary information regarding the proposed tests/experiments: Applicant Name: Google Inc. Applicant FRN: 0016069502 1 See 47 C.F.R. §15 Subparts B, C, and E. 2 47 C.F.R. §15.109(a). 3 See IEC System of Conformity Assessment Schemes for Electrotechnical Equipment and Components (IECEE), Information Technology Equipment – Immunity Characteristics – Limits and Methods of Measurement, CISPR 24:2010+A1:2015 (3V/m for this frequency range). Request for Confidential Treatment - Page 2

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 Legal Contact Details Name of Contact Megan Anne Stull Contact Details Counsel 25 Massachusetts Avenue NW, Ninth Floor Washington DC 20001 Technical Contact Details Name of Contact Tim Lee Contact Details 1600 Amphitheatre Parkway Mountain View, CA 94043 Phone: 415-736-5150 Email: timklee@google.com Transmitter #1 Information Equipment [REDACTED] Quantity [REDACTED] Area of Operation Nationwide Frequency Ranges4 Low (GHz) High (GHz) [REDACTED] 2.402 2.480 2.412 2.462 5.180 5.240 5.260 5.320 5.500 5.580 5.660 5.700 4 Transmitter #1 has two different portions, each operating in different ranges: the first portion operates in the 2412-2462 MHz range, while the second portion operates in the 2402-2480 MHz range. Request for Confidential Treatment - Page 3

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 Equipment Modulation Emission Bandwidth Output ERP Designator (MHz) Power (Watts) (Watts)5 [REDACTED] Digital 13M1F1D 13.1 0.1490 0.2110 16M3F1D 16.3 17M4D2D 17.4 36M2D2D 36.2 [REDACTED] Digital 980KF1D 0.98 0.0019 0.0024 1M21F1D 1.21 1M10F1D 1.10 Transmitter #1 Antenna Type [REDACTED] Quantity [REDACTED] Gain 5.4 dBi max Beam Width at Half-Power Point Not applicable Orientation in Horizontal Plane Not applicable Orientation in Vertical Plane Not applicable Transmitter #2 Information Equipment [REDACTED] Quantity [REDACTED] Area of Operation Nationwide Frequency Range Low (GHz) High (GHz) [REDACTED] 2.402 2.480 Equipment Modulation Emission Bandwidth Output ERP Designator (MHz) Power (Watts) (Watts) [REDACTED] Digital 1M27F1D 1.27 0.0027 0.0042 5 The power levels indicate the maximum output power as measured at specific frequency range for a given mode as a worst case scenario. Request for Confidential Treatment - Page 4

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 Transmitter #2 Antenna Type [REDACTED] Quantity [REDACTED] Gain 4.1 dBi max Beam Width at Half-Power Point Not applicable Orientation in Horizontal Plane Not applicable Orientation in Vertical Plane Not applicable 2. Identification of the Commission proceeding in which the information was submitted or a description of the circumstances giving rise to the submission. The above-referenced Exhibits were submitted to the Commission in support of the STA. These Exhibits were filed with the Office of Engineering and Technology on April 5, 2017. For additional information, please see File No. 0379-EX-ST-2017. 3. Explanation of the degree to which the information is commercial or financial or contains a trade secret or is privileged. The information requested to be kept confidential has significant commercial value. The details of the STA tests/experiments may include trade secret information. The Commission 6 has clarified that confidential treatment should be afforded to trade secrets. Google’s tests/experiments and proprietary wireless applications using particular radio frequency equipment represent a “secret commercially valuable plan” within the meaning of a trade secret as recognized by the Commission. In addition, agreements entered into between Google and any parties that provided equipment for testing or will provide analysis of test results require that confidential information of the parties be held in strict confidence, and that such information not be disclosed to any third party (with limited exceptions not applicable to this request). The manufacturer name and model number constitutes confidential trade secrets, technical information, and business information under the agreements. 6 Examination of Current Policy Concerning the Treatment of Confidential Information Submitted to the Commission, Report and Order, GC Docket No. 96-55, at para. 3, (released Aug. 4, 1998) (defining “trade secrets” for purpose of Commission rules on confidential treatment). Request for Confidential Treatment - Page 5

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 4. Explanation of the degree to which the information concerns a service that is competitive. The services and technologies that are the subject of this STA have not yet been fully developed but are expected to lead to material developments in markets subject to competition from multiple U.S. and non-U.S. third parties. 5. Explanation of how disclosure of the information could result in substantial competitive harm. The technology under development is highly sensitive and confidential in nature. The release of such information would provide valuable insight into Google’s technology innovations and potential business plans and strategies. Public disclosure would jeopardize the value of the technology under examination by enabling others to utilize Google’s information to develop similar products in a similar time frame. 6. Identification of any measures taken by the requesting party to prevent unauthorized disclosure. Google has taken steps to keep confidential the information set forth in the confidential exhibits by limiting the number of people involved in the tests/experiments to only those on a “need to know” basis, and by requiring any third parties involved in the testing process to execute robust nondisclosure agreements. 7. Identification of whether the information is available to the public and the extent of any previous disclosures of the information to any third parties. The information contained in the confidential exhibits is not available to the public, and has only been disclosed to third parties pursuant to restrictive safeguards. Google voluntarily provides the information to the Commission at this time with the expectation that it will be treated confidentially in accordance with the Commission's rules. See Critical Mass Energy Project v. Nuclear Regulatory Comm’n, 975 F.2d 871, 879 (D.C. Cir. 1992) (commercial information provided on a voluntary basis “is ‘confidential’ for the purpose of Freedom of Information Act (FOIA) Exemption 4 if it is of a kind that would customarily not be released to the public by the person from whom it was obtained.”). Request for Confidential Treatment - Page 6

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 8. Justification of the requested period of confidentiality. Google expects that confidential treatment will be necessary for the length of the proposed experiment and thereafter in order to protect its evolving business and technology strategies. 9. Any other information that would be useful in assessing whether this request should be submitted. The information subject to this request for confidentiality should not be made available for public disclosure at any time. There is nothing material that public review of this information would add to the Commission’s analysis of Google’s request for an experimental authorization. Moreover, public disclosure of the sensitive information in the confidential exhibits to the STA after the Commission has ruled on the Request for Confidentiality is not necessary for the Commission to fulfill its regulatory responsibilities. Consistent with 47 C.F.R. § 0.459(d)(l), Google requests notification if release of the information subject to this request is requested pursuant to the FOIA or otherwise, so that Google may have an opportunity to oppose grant of any such request. Sincerely yours, Megan Anne Stull Request for Confidential Treatment - Page 7

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 EXHIBIT A – NARRATIVE STATEMENT Consistent with the standards set forth in Section 5.61 of the Federal Communications Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.61, Google Inc. (Google) outlines below its need for the requested Special Temporary Authority (STA) and the compelling reasons why 0379-EX-ST-2017 should be granted expeditiously. Google requests that the STA be granted for a period of 180 days. The STA is needed for the demonstration and testing of a prototype device (Device) that is expected to enhance the development, application, and use of [REDACTED]. The Device consists of a [REDACTED] and a [REDACTED] to enable [REDACTED]. The Device utilizes [REDACTED] to enable [REDACTED], as needed and consistent with [REDACTED]. The users of the Device will be professional Google employees and contractors, and also potentially external trusted professional developers [REDACTED]. The Device is not intended to be used by general public. The requested authorization will not be used to conduct any commercial operations, and all Devices will be collected or destroyed at the end of the experimentation period. No material risk of harmful interference will be generated by the proposed testing. The Device meets all Part 15 Class A and nearly all Class B device limits for electromagnetic compatibility and radio operations.1 During unintentional radiated emission tests conducted by Underwriters Laboratories (UL) at a distance of three meters, the Device exceeded Part 15 Class B device limits2 at two frequencies—43.4 MHz (5.9 dB deviation) and 639.0 MHz (7.0 dB deviation). The unintentional radiated emission of the Device meets Class A device limits. Because most residential digital devices are immune by design to electromagnetic interference at a much higher level as part of European Union EMC requirements,3 the risk of generating harmful interference to other devices operating on these frequencies is minimal. Moreover, the Device’s electrical, mechanical, thermal, optical and RF exposure (SAR) safety have been confirmed by tests and evaluations conducted by UL. For these reasons, Google requests approval of this STA request. 1 See 47 C.F.R. §15 Subparts B, C, and E. 2 47 C.F.R. §15.109(a). 3 See IEC System of Conformity Assessment Schemes for Electrotechnical Equipment and Components (IECEE), Information Technology Equipment – Immunity Characteristics – Limits and Methods of Measurement, CISPR 24:2010+A1:2015 (3V/m for this frequency range). Exhibit A - 1

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 EXHIBIT B - TECHNICAL INFORMATION Applicant Name: Google Inc. Applicant FRN: 0016069502 Legal Contact Details Name of Contact Megan Anne Stull Contact Details Counsel 25 Massachusetts Avenue NW, Ninth Floor Washington DC 20001 Technical Contact Details Name of Contact Tim Lee Contact Details 1600 Amphitheatre Parkway Mountain View, CA 94043 Phone: 415-736-5150 Email: timklee@google.com Transmitter #1 Information Equipment [REDACTED] Quantity [REDACTED] Area of Operation Nationwide Frequency Ranges1 Low (GHz) High (GHz) [REDACTED] 2.402 2.480 2.412 2.462 5.180 5.240 5.260 5.320 5.500 5.580 5.660 5.700 1 Transmitter #1 has two different portions, each operating in different ranges: the first portion operates in the 2412-2462 MHz range, while the second portion operates in the 2402-2480 MHz range. Exhibit B - 1

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 Equipment Modulation Emission Bandwidth Output Power ERP Designator (MHz) (Watts)2 (Watts) [REDACTED] Digital 13M1F1D 13.1 0.1490 0.2110 16M3F1D 16.3 17M4D2D 17.4 36M2D2D 36.2 [REDACTED] Digital 980KF1D 0.98 0.0019 0.0024 1M21F1D 1.21 1M10F1D 1.10 Transmitter #1 Antenna Type [REDACTED] Quantity [REDACTED] Gain 5.4 dBi max Beam Width at Half-Power Point Not applicable Orientation in Horizontal Plane Not applicable Orientation in Vertical Plane Not applicable Transmitter #2 Information Equipment [REDACTED] Quantity [REDACTED] Area of Operation Nationwide Frequency Range Low (GHz) High (GHz) [REDACTED] 2.402 2.480 Equipment Modulation Emission Bandwidth Output Power ERP Designator (MHz) (Watts) (Watts) [REDACTED] Digital 1M27F1D 1.27 0.0027 0.0042 2 The power levels indicate the maximum output power as measured at specific frequency range for a given mode as a worst case scenario. Exhibit B - 2

PUBLIC REDACTED VERSION Google Inc. File No. 0379-EX-ST-2017 Transmitter #2 Antenna Type [REDACTED] Quantity [REDACTED] Gain 4.1 dBi max Beam Width at Half-Power Point Not applicable Orientation in Horizontal Plane Not applicable Orientation in Vertical Plane Not applicable Exhibit B - 3


Document Created: 2019-05-11 20:01:13
Document Modified: 2019-05-11 20:01:13
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