Confidentiality Request

FCC ID: A4R-X1

Cover Letter(s)

Download: PDF
FCCID_1939321

1600 Amphitheatre Parkway                                                                      Tel: 650.623.4000
Mountain View, California 94043                                                               Fax: 650.618.1806
                                                                                                www.google.com



           Federal Communications Commission
           Laboratory Division
           7435 Oakland Mills Road
           Columbia, MD 21046

           Date:          April 13, 2013
           Subject:       Request for Idefinite and Short-Term Confidentiality
           FCC ID:        A4R-X1

           To Whom It May Concern:

           Pursuant to the provisions of Sections 0.457 and 0.459 of the Commission’s rules (47 CFR §§
           0.457, 0.459) and Public Notice DA 04-1705, Google Inc. (“Google”) requests that the
           Commission withhold the following attachment associated with the Class II permissive change
           application for the above-referenced FCC ID from public disclosure indefinitely:

           Antenna Specification

           The market for the technology that is the subject of the application is highly competitive, with
           numerous companies competing for the business of potential customers. Were Google’s
           competitors to become aware of the facts set forth in the above-referenced exhibit to the
           application, it could have an adverse impact on Google’s competitive standing and deprive
           Google of the marketplace benefit it otherwise might achieve by virtue of having product
           available before other competitors. If any of the information for which confidential treatment is
           sought were to be made publicly available, Google’s competitors could reasonably determine the
           scope and status of our activities. The information contained in the above-referenced exhibit has
           been strictly controlled by Google, with distribution limited to internal use only and for the
           specific purpose of conducting research, development, and testing of the technology.

           Given the competitive nature of the marketplace, any disclosure that Google has developed the
           technology discussed in the above-reference exhibit to the application would harm Google’s
           competitive position. The information subject to this request for confidentiality should not be
           made available for public disclosure at any time.

           In addition, Google requests that the Commission grant short-term confidential treatment and not
           release the following attachments associated with the Class II permissive change application for
           the above-referenced FCC ID from routine public disclosure until 180 days following the grant
           of this application:

           Internal photo reflecting change
           Test set-up photos

           Google respectfully seeks confidential treatment of the above-referenced attachments for the
           same reasons stated above and in order to comply with the marketing regulations in 47 CFR


1600 Amphitheatre Parkway                                                                      Tel: 650.623.4000
Mountain View, California 94043                                                               Fax: 650.618.1806
                                                                                                www.google.com



           §2.803 and the importation rules in 47 CFR §2.1204, while ensuring that business sensitive
           information remains confidential until the actual marketing of newly authorized devices.

           It is our understanding that all measurement test reports and correspondence during the
           certification review process cannot be granted confidential treatment, and such information will
           be available for public review once the grant of equipment authorization is issued.

           Sincerely yours,




           Warwick Wong
           Regulatory Compliance Specialist
           Google Inc.
           1600 Amphitheatre Parkway
           Mountain View, CA 94043
           Tel: 408-425-6290
           Email: warwickwong@google.com



Document Created: 2013-04-15 10:16:14
Document Modified: 2013-04-15 10:16:14

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