Request for Confidential Treatment and Exhibit PUBLIC

1960-EX-ST-2018 Text Documents

Google LLC

2018-12-13ELS_221137

                                                                      PUBLIC REDACTED VERSION

                                                                                                 Google
                                                                               File No. 1960­EX­ST­2018


Date:          December 13, 2018

Subject:       Public and Redacted Versions of Request for Confidential Treatment and
               Complementary Exhibit



To Whom It May Concern:

       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 Application) 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 Application and complementary exhibit (Exhibit). 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 - Special Temporary Authority Justification:

        Google requests confidential treatment of the following underlined text that contains
        confidential and proprietary information regarding the proposed tests/experiments:

           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 outlines below its need for the requested Special Temporary
               Authority (STA Application) and the compelling reasons why this request should
               be granted expeditiously.




                                                                 Request for Confidential Treatment ­ Page 1


                                                          PUBLIC REDACTED VERSION

                                                                                     Google
                                                                   File No. 1960­EX­ST­2018


           The STA is needed to test the transmission of broadband data from
   vehicles to transportable/fixed base stations located nearby. The dates and
   location of the proposed testing are as follows:

       Dates                                   Location
       January 19 - February 19, 2019          Daytona Beach, Florida

         Should any interference be reported, the proposed tests will cease
   immediately unless and until the interference is resolved to the satisfaction of the
   complainant.

          The proposed experimental operations accordingly will be conducted
   without harmful interference to other authorized users. For the foregoing reasons,
   Google requests approval of this STA Application.

       Legal Contact                           Technical Contact
       Sybil Anne Strimbu                      Dr. Andrew Clegg
       Legal Specialist                        1875 Explorer Street
       25 Massachusetts Avenue NW              10th Floor
       9th Floor                               Reston, VA 20190
       Washington, DC 20001                    (202) 370-5644
       sybil@google.com                        aclegg@google.com


Transmitter Equipment and Station Details
 Radio Information

       Equipment               [REDACTED]
       Quantity                [REDACTED]
       Area of Operation       Operation not to exceed 3 km from the following
                               geographic centerpoint:

                                   ●   29° 11’ 07” N, 81° 04’ 14” W


       Frequency                         Low (MHz)                     High (MHz)
       [REDACTED]                           3400                           3500




                                                     Request for Confidential Treatment ­ Page 2


                                                                        PUBLIC REDACTED VERSION

                                                                                                   Google
                                                                                 File No. 1960­EX­ST­2018


             Antenna Details

                    Antennas                [REDACTED]
                    Type                    Directional panels & omnidirectional verticals
                    Gain                    0 - 17.5 dBi
                    Beam Width at           30 - 360
                    Half-Power Point
                    Orientation in          Various (0-360 azimuth)
                    Horizontal Plane
                    Orientation in          Various (+10 to -45)
                    Vertical Plane

             Transmitter #1: Transportable/Fixed

                    Radio             Modulation     Emission Bandwidth               Max      Max
                                                    Designator  (MHz)                Output    ERP
                                                                                    Power (W) (kW)1
                    [REDACTED]        LTE (OFDM) 10M0W7D                 10              20          0.122
                    [REDACTED]        LTE (OFDM) 20M0W7D                 20              40          0.244
                    [REDACTED]        LTE (OFDM) 40M0W7D                 40              80          0.487
                    [REDACTED]        LTE (OFDM) 80M0W7D                 80             160          0.976

             Transmitter #2: Mobile

                    Radio             Modulation     Emission Bandwidth               Max      Max
                                                    Designator  (MHz)                Output    ERP
                                                                                    Power (W) (kW)2
                    [REDACTED]        LTE (OFDM) 10M0F9W                 10               2         0.0012
                    [REDACTED]        LTE (OFDM) 20M0F9W                 20               4         0.0024
                    [REDACTED]        LTE (OFDM) 40M0F9W                 40               8         0.0049
                    [REDACTED]        LTE (OFDM) 80M0F9W                 80              16         0.0098




1 Because the proposed testing will not involve using the maximum output power combined with the
maximum antenna gain, the maximum ERP for the transportable/fixed transmitter was calculated based
on the maximum output power and a 10 dBi antenna gain.
2 The maximum ERP for the mobile transmitter was calculated based on no antenna gain (0 dBi).

                                                                   Request for Confidential Treatment ­ Page 3


                                                                         PUBLIC REDACTED VERSION

                                                                                                    Google
                                                                                  File No. 1960­EX­ST­2018


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 Exhibit was submitted to the Commission in support of the STA
Application. The Exhibit was filed with the Office of Engineering and Technology on December
13, 2018. For additional information, please see File No. 1960-EX-ST-2018.



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 Application may include trade secret information. The Commission has
clarified that confidential treatment should be afforded to trade secrets.3 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.



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 Application 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



3 In the Matter of Examination of Current Policy Concerning the Treatment of Confidential Information
Submitted to the Commission, Report and Order, 13 FCC Rcd. 24816, ¶ 3 (1998) (defining “trade secrets”
for purpose of Commission rules on confidential treatment).
                                                                    Request for Confidential Treatment ­ Page 4


                                                                       PUBLIC REDACTED VERSION

                                                                                                  Google
                                                                                File No. 1960­EX­ST­2018


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
Exhibit 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 Exhibit 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.”).



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 Exhibit to the
STA Application after the Commission has ruled on the Request for Confidentiality is not
necessary for the Commission to fulfill its regulatory responsibilities.


                                                                  Request for Confidential Treatment ­ Page 5


                                                                     PUBLIC REDACTED VERSION

                                                                                                Google
                                                                              File No. 1960­EX­ST­2018


       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,




Sybil Anne Strimbu




                                                                Request for Confidential Treatment ­ Page 6


                                                                  PUBLIC REDACTED VERSION

                                                                                        Google LLC
                                                                          File No. 1960­EX­ST­2018


                   EXHIBIT - SPECIAL TEMPORARY AUTHORITY JUSTIFICATION

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 outlines below its need
for the requested Special Temporary Authority (STA Application) and the compelling reasons
why this request should be granted expeditiously.

        The STA is needed to test the transmission of broadband data from vehicles to
transportable/fixed base stations located nearby. The dates and location of the proposed testing
are as follows:

           Dates                                Location
           January 19 - February 19, 2019       Daytona Beach, Florida

       Should any interference be reported, the proposed tests will cease immediately unless
and until the interference is resolved to the satisfaction of the complainant.

        The proposed experimental operations accordingly will be conducted without harmful
interference to other authorized users. For the foregoing reasons, Google requests approval of
this STA Application.

           Legal Contact                        Technical Contact
           Sybil Anne Strimbu                   Dr. Andrew Clegg
           Legal Specialist                     1875 Explorer Street
           25 Massachusetts Avenue NW           10th Floor
           9th Floor                            Reston, VA 20190
           Washington, DC 20001                 (202) 370-5644
           sybil@google.com                     aclegg@google.com


Transmitter Equipment and Station Details
 Radio Information

    Equipment              [REDACTED]
    Quantity               [REDACTED]
    Area of Operation      Operation not to exceed 3 km from the following geographic
                           centerpoint:

                              ●   29° 11’ 07” N, 81° 04’ 14” W




                                                                          STA Justification ­ Page 1


                                                                      PUBLIC REDACTED VERSION

                                                                                               Google LLC
                                                                                 File No. 1960­EX­ST­2018


    Frequency                                                   Low (MHz)              High (MHz)
    [REDACTED]                                                    3400                     3500

 Antenna Details

    Antennas                              [REDACTED]
    Type                                  Directional panels & omnidirectional verticals
    Gain                                  0 - 17.5 dBi
    Beam Width at Half-Power Point 30 - 360
    Orientation in Horizontal Plane       Various (0-360 azimuth)
    Orientation in Vertical Plane         Various (+10 to -45)

 Transmitter #1: Transportable/Fixed

    Radio              Modulation     Emission        Bandwidth       Max Output           Max ERP
                                      Designator        (MHz)         Power (W)             (kW)1
    [REDACTED]         LTE (OFDM)      10M0W7D             10               20                0.122
    [REDACTED]         LTE (OFDM)      20M0W7D             20               40                0.244
    [REDACTED]         LTE (OFDM)      40M0W7D             40               80                0.487
    [REDACTED]         LTE (OFDM)      80M0W7D             80             160                 0.976

 Transmitter #2: Mobile

    Radio              Modulation     Emission        Bandwidth       Max Output           Max ERP
                                      Designator        (MHz)         Power (W)             (kW)2
    [REDACTED]         LTE (OFDM)      10M0F9W             10               2                0.0012
    [REDACTED]         LTE (OFDM)      20M0F9W             20               4                0.0024
    [REDACTED]         LTE (OFDM)      40M0F9W             40               8                0.0049
    [REDACTED]         LTE (OFDM)      80M0F9W             80               16               0.0098




1 Because the proposed testing will not involve using the maximum output power combined with the
maximum antenna gain, the maximum ERP for the transportable/fixed transmitter was calculated based
on the maximum output power and a 10 dBi antenna gain.
2 The maximum ERP for the mobile transmitter was calculated based on no antenna gain (0 dBi).

                                                                                 STA Justification ­ Page 2



Document Created: 2018-12-14 06:04:12
Document Modified: 2018-12-14 06:04:12

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