Confidentiality Letter

FCC ID: BCGA1991

Cover Letter(s)

Download: PDF
FCCID_4492782

                                                                                        
Date: 5 September 2019

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

Subject:          Request for Confidentiality

FCC ID:           BCGA1991, Model A1991


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
       •   Schematics
       •   Operational Description
       •   Software Security Description
       •   Tune Up Procedure

These documents reveal detailed technical and design information that 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 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.




                                                                           One Apple Park Way
                                                                                     Cupertino,
                                                                              California 95014
                                                                                           USA
v1.0                                                                           www.apple.com


                                                                                        

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,




____________________
Stuart Thomas
Apple Inc.
EMEIA Engineering Manager
Sthomas5@apple.com



                                                                           One Apple Park Way
                                                                                     Cupertino,
                                                                              California 95014
                                                                                           USA
v1.0                                                                           www.apple.com



Document Created: 0650-10-30 00:00:00
Document Modified: 0650-10-30 00:00:00

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