Request for confidentiality

FCC ID: BCG-E3219A

Cover Letter(s)

Download: PDF
FCCID_3974812

                                                                                      
Date: July 2, 2018

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

Subject:         Request for Confidentiality

Ref: FCC ID numbers

            Model(s)                    FCC ID
       A1920, A2100, A2099        FCC ID # BCG-E3218A
              A2098               FCC ID # BCG-E3233A
              A2097               FCC ID # BCG-E3232A
       A1921, A2104, A2103        FCC ID # BCG-E3219A
              A2102               FCC ID # BCG-E3235A
              A2101               FCC ID # BCG-E3234A
       A1984, A2108, A2107        FCC ID # BCG-E3220A
              A2106               FCC ID # BCG-E3238A
              A2105               FCC ID # BCG-E3237A

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.
                                                                         One Apple Park Way
                                                                               Cupertino, CA
v1.0                                                                         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.
                                                                             One Apple Park Way
                                                                                   Cupertino, CA
v1.0                                                                             www.apple.com



Document Created: 2018-07-05 19:49:38
Document Modified: 2018-07-05 19:49:38

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