Request for confidential treatment

0735-EX-ST-2019 Text Documents

Sony Corporation R&D; Center

2019-04-26ELS_228591

soOoONY Sony Corporation April 26, 2019 VIA OET EXPERIMENTAL LICENSING SYSTEM Office of Engineering Technology Federal Communications Commuission 441 12Street, SW Washington, DC 20006 Re: Sony Corporation R&D Center Application for Special Temporary Authority File Number 0735—EX—ST—2019 Request for Confidential Treatment To whom it may concern: Pursuant to Sections 0.457 and 0.459 of the Commussion‘s rules, Sony Corporation R&D Center ("Sony") respectfully requests confidential treatment for portions of its Application for Special Temporary Authority ("STA"), to which this letter is submitted as an exhibit, as more fully described below. As required by Section 0.459(b) of the Commission‘s rules, Sony submits the following statement of the reasons for withholding the materials from public inspection: (1) Identification of the s pecific information for which confidential treatment is sought Sony requests confidential treatment for Attachment A to the document titled "Request for Confidential Treatment and Exhibit," which was submitted to this file on April 23, 2019. (2) Identification of the Commission proceeding in which the information was submitted or a description of the cirecumstances giving rise to the submission Sony is submitting this information in connection with its participation in GN Docket No. 15—319. Sony has requested an STA in order to conduct an Initial Commercial Deployment (‘TICD") of its Spectrum Access Service ("SAS"). Sony has received a conditional authorization from the Commussion to serve as a SAS Administrator for wireless operations in the 3550—3700 MHz band, and an ICD is required before the Commission will issue a final authorization. (3) Explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged This exhibit includes commercial information and trade secrets regarding the implementation details of Sony‘s ICD proposal.

(4) Explanation of the degree to which the information concerns aservice that is subject to competition Sony is one of five entities that have received conditional authorization to serve as a SAS administrator and are currently in the process of conducting lab testing in preparation for ICD. Upon receiving final authorization, these SAS administrators will compete to provide service for wireless operations in the 3.5 GHz band. (5) Explanation of how disclosure ofthe information could res ult in substantial competitive harm Disclosure of this confidential material could result in substantial competitive harm because it includes commercial information and trade secrets regarding the implementation details of Sony‘s ICD proposal, and public disclosure would undermine Sony‘s ability to offer a competitive SAS. (6) Identification of any measures taken by the submitting party to prevent unauthorized disclosure Sony uses all commercially reasonable methods to prevent unauthorized disclosure of confidential material, and has submitted redacted versions of its filings in GN Docket No. 15— 319, with corresponding requests for confidential treatment. (7) Identification of whether the information is available to the public and the extent of any previous disclosure ofthe information to third parties Except for the confidential submission of its ICD proposal to Commission staff on April 12, 2019, this mformation has not previously been shared outside of Sony, including to the public or to third parties. (8) Justification of the period during which the submitting party as serts that material should not be available for public disclosure Sony asks that this information remain confidential until its ICD proposal has been approved and implemented, at which point any potential for competitive harm will no longer exist. Please contact the undersigned with any questions about this request. %spectfully submitted, Ja organ ector and Cor Sony Electronics moroan SOHV mes. & com


Document Created: 0200-05-03 00:00:00
Document Modified: 0200-05-03 00:00:00
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