Request for Confidential Treatment and Exhibit PUBLIC

1751-EX-ST-2018 Text Documents

Google

2018-10-16ELS_218171

                                                                      PUBLIC REDACTED VERSION

                                                                                                 Google
                                                                               File No. 1751­EX­ST­2018


Date:          October 16, 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 extension of Special Temporary Authority (STA Extension) 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 Extension 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 extension of Special Temporary
           Authority (STA Extension) and the compelling reasons why this STA Extension
           should be granted expeditiously.

              Google requests that the STA Extension be granted for a period of 180 days.
           Consistent with Call Sign WL9XFJ (File No. 0622-EX-ST-2018), the STA Extension is
           needed to continue to test the transmission of broadband data from vehicles in Plano
                                                                 Request for Confidential Treatment ­ Page 1


                                                         PUBLIC REDACTED VERSION

                                                                                    Google
                                                                  File No. 1751­EX­ST­2018


and Fort Worth, Texas, to transportable/fixed base stations located nearby.

    As noted, Google has been conducting similar tests under a grant of STA, and no
disruptions have been noted. Should any interference be reported, the proposed
tests will cease immediately unless and until the interference is resolved to the
satisfaction of the complainant. Based on the foregoing, Google requests approval of
this STA Extension.

    Legal Contact                               Technical Contact
    Sybil Anne Strimbu                          Dr. Andrew Clegg
    Legal Specialist                            1875 Explorer Street, 10th Floor
    25 Massachusetts Avenue NW, 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]
    Areas of Operation Operation not to exceed 3 km from the following
                       geographic centerpoints:

                              ●   33° 00’ 33” N, 96° 45’ 34” W
                              ●   33° 02’ 14” N, 97° 16’ 56” W


    Frequency                         Low (MHz)                      High (MHz)
    [REDACTED]                           3400                             3600




                                                    Request for Confidential Treatment ­ Page 2


                                                                         PUBLIC REDACTED VERSION

                                                                                                   Google
                                                                                 File No. 1751­EX­ST­2018


            Antenna Details

                Antennas                              [REDACTED]
                Type                                  Directional panels & omnidirectional
                                                      verticals
                Gain                                  0 - 17 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     Max ERP
                                                Designator  (MHz)               Output    (kW)1
                                                                               Power (W)
                [REDACTED]            LTE        10M0W7D            10               20            0.122
                                    (OFDM)
                [REDACTED]            LTE        20M0W7D            20               40            0.244
                                    (OFDM)
                [REDACTED]            LTE        40M0W7D            40               80            0.487
                                    (OFDM)
                [REDACTED]            LTE        80M0W7D            80              160            0.976
                                    (OFDM)




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.
                                                                   Request for Confidential Treatment ­ Page 3


                                                                         PUBLIC REDACTED VERSION

                                                                                                   Google
                                                                                 File No. 1751­EX­ST­2018


             Transmitter #2: Mobile

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


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
Extension. The Exhibit was filed with the Office of Engineering and Technology on October 16,
2018. For additional information, please see File No. 1751-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 Extension tests/experiments 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.

2 The maximum ERP for the mobile transmitter was calculated based on no antenna gain (0 dBi).
3 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 4


                                                                     PUBLIC REDACTED VERSION

                                                                                                Google
                                                                              File No. 1751­EX­ST­2018


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 Extension 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
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.”).




                                                                Request for Confidential Treatment ­ Page 5


                                                                       PUBLIC REDACTED VERSION

                                                                                                  Google
                                                                                File No. 1751­EX­ST­2018


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 Extension 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,




Sybil Anne Strimbu




                                                                  Request for Confidential Treatment ­ Page 6


                                                                   PUBLIC REDACTED VERSION

                                                                                             Google
                                                                           File No. 1751­EX­ST­2018


                  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 extension of Special Temporary Authority (STA Extension) and the compelling
reasons why this STA Extension should be granted expeditiously.

        Google requests that the STA Extension be granted for a period of 180 days. Consistent
with Call Sign WL9XFJ (File No. 0622-EX-ST-2018), the STA Extension is needed to continue to
test the transmission of broadband data from vehicles in Plano and Fort Worth, Texas, to
transportable/fixed base stations located nearby.

        As noted, Google has been conducting similar tests under a grant of STA, and no
disruptions have been noted. Should any interference be reported, the proposed tests will cease
immediately unless and until the interference is resolved to the satisfaction of the complainant.
Based on the foregoing, Google requests approval of this STA Extension.

    Legal Contact                                Technical Contact
    Sybil Anne Strimbu                           Dr. Andrew Clegg
    Legal Specialist                             1875 Explorer Street, 10th Floor
    25 Massachusetts Avenue NW, 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]
    Areas of Operation             Operation not to exceed 3 km from the following geographic
                                   centerpoints:

                                       ●   33° 00’ 33” N, 96° 45’ 34” W
                                       ●   33° 02’ 14” N, 97° 16’ 56” W


    Frequency                                                 Low (MHz)           High (MHz)
    [REDACTED]                                                   3400                 3600




                                                                           STA Justification ­ Page 1


                                                                       PUBLIC REDACTED VERSION

                                                                                                  Google
                                                                                File No. 1751­EX­ST­2018


 Antenna Details

    Antennas                                [REDACTED]
    Type                                    Directional panels & omnidirectional verticals
    Gain                                    0 - 17 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: 2018-10-30 14:46:11
Document Modified: 2018-10-30 14:46:11

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