FCC_Request_Confidentiality_Letter_v1.1

FCC ID: BCG-E3159A

Cover Letter(s)

Download: PDF
FCCID_3542239

                                                                                     
Date: July 18, 2017

Federal Communications Commission
Office of Engineering and Technology Laboratory Division
7435 Oakland Mills Rd.
Columbia MD 21046

Subject:         Request for Confidentiality

Ref: FCC IC numbers

             Model(s)                   FCC ID
           A1863, A1907               BCG-E3159A
              A1906                   BCG-E3171A
              A1905                   BCG-E3172A
           A1864, A1899               BCG-E3160A
              A1898                   BCG-E3173A
              A1897                   BCG-E3174A
           A1865, A1903               BCG-E3161A
              A1902                   BCG-E3176A
              A1901                   BCG-E3175A

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), Apple Inc. hereby requests confidential treatment for documents
filed with the Commission in connection with the application for equipment authorization
referenced above.

Permanent Confidentiality

Apple Inc. requests that the Commission withholds the following documents from public
viewing indefinitely:

       •   Block Diagrams
       •   Electrical Schematic Diagrams
       •   Technical Descriptions, Product Specifications
       •   Antenna Gain, Antenna Locations, Tune-up Procedure
       •   Software Security Description

These documents reveal detailed technical and design information that is protected by
Apple Inc. as confidential and proprietary trade secrets. This information has been


                                                                                  Apple Inc.
                                                                             1 Infinite Loop
                                                                              Cupertino, CA
v1.1                                                                        www.apple.com


                                                                                       
disclosed to those required to maintain its confidentiality, and is not customarily
disclosed to the public even after commercial release of a device. As a result, disclosure
of this information by the Commission would harm Apple Inc. by giving competitors an
unfair advantage even after commercial release of the device.

Short Term Confidentiality

In addition to the above mentioned documents, pursuant to Public Notice DA 04-1705 of
the Commission’s policy, in order to comply with the marketing regulations in 47 CFR
§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, Apple Inc. requests that the Commission withholds the following documents
from public viewing for one hundred eighty days after the date the grant of equipment
authorization is issued:

       •   External Photographs
       •   Internal Photographs
       •   Test Setup Photographs
       •   User Manual

These documents reveal technical and design information that has not been publicly
disclosed in marketing materials and is protected by Apple Inc. as confidential and
proprietary trade secrets. This information has been disclosed to those required to
maintain its confidentiality, and is not customarily disclosed publicly prior to the
commercial release of the device. As a result, disclosure of this information by the
Commission prior to commercial release would harm Apple Inc. by giving competitors
an unfair market advantage. Apple Inc. believes the period of confidentiality requested is
necessary to protect the information until the commercial release of a device.

It is our understanding that measurement test reports and FCC ID label format cannot be
granted as confidential documents and this information will be available for public
review once the grant of equipment authorization is issued.

Sincerely,



____________________
Abhishek Rala
Apple Inc.
Global Certification Manager
arala@apple.com


                                                                                    Apple Inc.
                                                                               1 Infinite Loop
                                                                                Cupertino, CA
v1.1                                                                          www.apple.com



Document Created: 0550-06-23 00:00:00
Document Modified: 0550-06-23 00:00:00

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