Confidential Statement

0461-EX-PL-2016 Text Documents

Nokia

2016-06-22ELS_178527

June 22, 2016


Nnake Nweke, Ph.D. (Engr.), Esq.
Chief, Experimental Licensing Branch
Office of Engineering and Technology                                     Nokia Solutions and Networks

Federal Communications Commission                                        Address:
445 12th Street, SW                                                      600 Mountain Ave
                                                                         Murray Hill, NJ 07974
Washington, D.C. 20510

RE:    Request for Confidential Treatment - Experimental
       License Service Application, File No. 0461-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,




Glenn Steitz
5G Solutions and Introduction
Nokia
Glenn.steitz@nokia.com

(973) 214-0028



Document Created: 2016-06-22 14:14:25
Document Modified: 2016-06-22 14:14:25

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