Request for Withholding Information from Routine Public Disclosure

0582-EX-ST-2007 Text Documents

Intel Corporation

2007-12-05ELS_86472

REQUEST FOR WITHHOLDING INFORMATION FROM ROUTINE PUBLIC DISCLOSURE File No. 0582-EX-ST-2007 Intel Corporation (“Intel”) requests pursuant to Section 0.459 of the Commission’s Rules that certain materials included within the above-referenced application for special temporary authority be withheld from routine public disclosure. In support of that request, Intel provides the following information: Identification of materials to be withheld from routine public disclosure (§0.459(b)(1)): Intel requests that all of the information contained in Exhibits 1 and 3 to the application be withheld from routine public disclosure. Identification of the Commission proceeding in which the information was submitted (§0.459(b)(2)): The material has been submitted in connection with Intel’s request for special temporary authority assigned File No. 0582-EX-ST-2007. Explanation of the degree to which the information is commercial or financial, or contains a trade secret, or is privileged (§0.459(b)(3)): The market for the devices that are the subject of the request for special temporary authority is a highly competitive one, with numerous vendors battling for the business of customers. Were Intel’s competitors to become aware of the facts set forth in the special temporary authorization application at this time, it could have an adverse impact on Intel's competitive standing and deprive Intel of the marketplace benefit it otherwise will achieve by virtue of having product available before other competitors. This is particularly true with respect to the fact that Intel is on the verge of delivering a new product to a potential major customer. If any of the information for which confidential treatment is sought were to be made available, Intel’s competitors could reasonably determine the scope and status of Intel’s activities. Explanation of the degree to which the information concerns a service that is subject to competition (§0.459(b)(4)): As discussed above, the market for the devices that are the subject of the request for special temporary authority is a highly competitive one, with numerous vendors battling for the business of customers. Explanation of how disclosure of the information could result in substantial competitive harm (§0.459(b)(5)): As noted above, were Intel’s competitors to become aware of the facts set forth in the special temporary authorization application at this time (particularly the fact that Intel is on the verge of delivering a new product line to a potential major customer), it could have an adverse impact on Intel's competitive standing and deprive Intel of the marketplace benefit it otherwise will achieve by virtue of having product available before other competitors. Identification of any measures taken by the submitting party to prevent unauthorized disclosure (§0.459(b)(6)): Intel will not be disclosing to the public that it is on the verge of delivering the covered devices for customer evaluation or that it has sought this special temporary authority. The only outside disclosure had been to the customer.

Identification of whether the information is available to the public and the extent of any previous disclosure of the information to third parties (§0.459(b)(7)): The information that Intel requests be maintained as confidential is not available publicly. Some of the details regarding the devices that are the subject of the application have been disclosed to potential customers pursuant to non-disclosure agreements. However, there has been no prior disclosure that Intel is seeking this special temporary authority or is on the verge of delivering the devices to a customer for testing. Justification of the period during which the submitting party asserts that material should not be available for public disclosure (§0.459(b)(7)): Given the competitive nature of the marketplace, any disclosure that Intel is on the verge of delivering the devices would harm Intel’s competitive position.


Document Created: 2007-12-05 16:48:07
Document Modified: 2007-12-05 16:48:07
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