Confidentiality Request

FCC ID: DGFSSD895

Cover Letter(s)

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FCCID_452974

$Software, Electronic & Mechanical Systems 3M Center Technology Center St. Paul, MN 55144-1000 651 733 8688 3 June 4, 2004 Mr. Yuriy Litvinov TCB Reviewer Intertek Testing Services NA, Inc. 7250 Hudson Blvd. Suite 100 Oakdale, MN 55128 Re: FCC ID No. DGF SSD895 Dear Yuriy: Request for Confidential Treatment 3M Company (3M) requests that the material described below be withheld from public disclosure in accordance with Section 0.459 of the Commission’s Rules, 47 C.F.R. § 0.459 (2002), following the grant of application. In support of this request, 3M submits the following 1. Identification of the specific information for which confidential treatment is sought: Electrical Schematic of the 3M Reader, Drawing # 78-8023-7800-4 Rev. 5 (1 sheet), PWA-3M Reader 78-8023-7800-4 Rev 5{sheet 1}.pdf Electrical Design Document, Document # DOC-EDD-M700 (25 sheets), DOC_EDD_M700.pdf 3M Reader Photographs, 3M Reader Photographs.pdf Parts List, 8210 Parts List.pdf Block Diagram, 8210 Block Diagram.pdf 2. Explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged:$

This material includes circuit diagrams (schematics) and circuit descriptions. As such,
this material is treated as highly confidential business information. The 3M Reader is a
proprietary design that is held in strict confidentiality. This unit is to be worked on
only by 3M personnel. All service personal are trained and authorized by 3M and are
under 3M confidentiality agreement. Even with this precaution, if the unit fails in the
field it is to be replaced with a working reader and the bad unit is to be returned to
the company for repair. No non-3M employees are allowed access to the reader.

3. Explanation of the degree to which the information concerns a service that is subject
to competition:

The material for which confidentiality is sought is employed in the design and
manufacture of radio frequency identification equipment that is offered on a
competitive basis. Customers for this equipment have a variety of competing sources
of supply.

4. Explanation of how disclosure of the information could result in substantial
competitive harm:

Disclosure would, in effect, give away the design efforts of the 3M engineering
personal, who have designed the equipment and manufacturing process. Disclosure
would offer competitors additional unwarranted insight into the state of the product
development that would allow those competitors an advantage that would not be
available to 3M.

5. Identification of any measures taken to the submitting party to prevent unauthorized
disclosure:

The information for which confidential treatment is sought is kept confidential to 3M
and not made available to any third parties except in pursuant to non-disclosure
agreements.

6. Identification of whether the information is available to the public and the extent of
any previous disclosure of the information to third parties:

To the knowledge of those preparing this application, the information has not been
disclosed publicly. While the general theory of the operation of this RFID equipment
has been the subject of numerous disclosures in industry and standards groups as well
as in rule making proceedings at the FCC, the protection sought is narrowly drawn
and pertains to certain specific implementations of RFID Technology.

7. Justification of the period during which the submitting party asserts that material
should not be available for public disclosure:

This material should not be disclosed for at least 5 years. While improvements in
design are made relatively frequently, disclosure of the design information would lead

to insights into both design and manufacturing techniques and could have an adverse
competitive effect for many years to come. This equipment is designed for
commercial, industrial, and government applications. As such, it is important that its
design not be made available to unauthorized persons who might attempt to use this
knowledge of the design to compromise the applications for which the equipment will
be employed.

8. Any other information that the party seeking confidential treatment believes may be
useful in assessing whether its request for confidentiality should be granted:

See item 7 above. Note that the equipment for which approval is being sought will be
employed in applications that inherently carry a premium of security.

If you have any questions or need any further information, please do not hesitate to
contact me at (651) 778-6279 (rdkuhn1@mmm.com).

Respectfully submitted,
Signatory: Roger Kuhn

Roger D. Kuhn
SEMS - EMC Laboratory
Building 76-1-01
St. Paul, MN 55144-1000

Document Created: 2004-07-23 14:33:53
Document Modified: 2004-07-23 14:33:53