Confidentiality letter

0121-EX-PL-2016 Text Documents

Nokia Solutions and Networks US LLC

2016-03-03ELS_173600

February 17th, 2016


Nnake Nweke, Ph.D. (Engr.), Esq.
Chief, Experimental Licensing Branch
Office of Engineering and Technology                                     Nokia Solutions and Networks
                                                                         US LLC
Federal Communications Commission
445 12th Street, SW                                                      Address:
                                                                         6000 Connection Dr
Washington, D.C. 20510                                                   Irving, TX 75039

RE:    Request for Confidential Treatment - Experimental
       License Service Application, File No. 0121-EX-PL-2016

Dear Chief Nweke,

Nokia Solutions and Networks US LLC (“Nokia Networks”) submits this request for confidential
treatment under Commission Rule Sections 0.457 and 0.459 (47 C.F.R. §§ 0.457, 0.459).

The rationale for this request is that Nokia Networks is making considerable investment in the
development of the novel wireless communications system that is the subject of the
experimental license application. Disclosure of the confidential portions of the license
application to competitors could cause Nokia Networks to lose a competitive edge in the
market and provide its competitors with an undue advantage in developing similar
technologies.

Accordingly, Nokia Networks provides the following responses as directed by Section 0.459(b)
of the Commission’s Rules:

(1) Identification of the specific information for which confidential treatment is sought

Nokia Networks seeks confidential treatment for the information released in the “Question 7:
Experimentation Description/Purpose of Experiment” and “Antenna Registration, especially
the directional antenna data“ sections of the application.

 (2) Identification of the Commission proceeding in which the information was submitted or a
description of the circumstances giving rise to the submission

In the referenced application for an experimental license, Nokia Networks seeks to conduct
field testing and evaluation of a novel communication technology that it is developing.

(3) Explanation of the degree to which the information is commercial or financial, or contains
a trade secret or is privileged

This technology contains intellectual property owned by Nokia Networks and is being
developed towards the goal of producing a commercial product.

(4) Explanation of the degree to which the information concerns a service that is subject to
competition

There are a number of companies developing, or that will develop, similar or competing
technology.


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(5) Explanation of how disclosure of the information could result in substantial competitive
harm

Disclosure of information about the system, including the operating band, would provide Nokia
Networks’ competitors an undue advantage in developing similar products.

(6) Identification of any measures taken by the submitting party to prevent unauthorized
disclosure

Nokia Networks is not disclosing information to the public.

(7) Identification of whether the information is available to the public and the extent of any
previous disclosure of the information to third parties

Information is not available to the public. Any disclosure of the information to third parties is
subject to executed Non Disclosure Agreements.

(8) Justification of the period during which the submitting party asserts that material should
not be available for public disclosure

Nokia Networks request confidential treatment of the material at least for the duration of the
experimental license terms. The technology development is part of an ongoing effort to
develop a novel wireless communication system. Disclosure of information pertaining to the
system during this stage would give Nokia Networks’ competitors an advantage in developing
similar products and potentially bringing them to the market before Nokia Networks.

(9) Any other information that the party seeking confidential treatment believes may be useful
in assessing whether its request for confidentiality should be granted.

It is of upmost importance to Nokia Networks that it maintains control over the public release
of details regarding its prototype system at trade shows, symposiums, conferences, etc. and
be able to manage the risks of early disclosures.

Nokia Networks appreciates your attention to this matter. If you have questions or need further
information, please contact the undersigned.

Yours sincerely,




Monisha Jain
5G Product Development
Nokia Solutions and Networks
monisha.1.jain@nokia.com
(480) 323-6705



Document Created: 2016-03-03 16:41:58
Document Modified: 2016-03-03 16:41:58

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