Confidentiality Request Letter

FCC ID: BCGA2198

Cover Letter(s)

Download: PDF
FCCID_4408800

                                                                                         
Date: June 10, 2019

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
                A2197                        BCGA2197
                A2200                        BCGA2200
             A2198, A2199                    BCGA2198

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
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.



                                                                                      Apple Inc.
                                                                             One Apple Park Way
                                                                                   Cupertino, CA
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,



____________________
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: 2019-09-11 07:08:40
Document Modified: 2019-09-11 07:08:40

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