Confidential letter

FCC ID: EHA-RM91501X04

Cover Letter(s)

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FCCID_227714

17 December 2001
Federal Communications Commission
Equipment Authorization
7435 Oakland Mills Road
Columbia, MD 21046

RE: Request for Confidential Treatment
FCC ID No: EHA-RM91501X04

Dear Sirs:

Intermec Technologies Corporation requests that the material in the Block diagram,
Schematics, and Operational Description be withheld from public disclosure in accordance with
Section 0.459 of the Commissions Rules, 47 C.F.R. 0.459 (1998), following grant of the
application. In support of this request, Intermec submits the following:

1. Identification of the specific information for which confidential treatment is sought:

The materials set fourth in the Operational Description, Block Diagram, and Schematics,
which are segregated from the non-confidential exhibits of the application, are those for
which confidentiality is sought.

2. Identification of the Commission proceeding in which the information was submitted
or a description of the circumstances giving rise to the submission:

The proceeding is that involving the application for equipment authorization (certification)
under FCC ID No: EHA-RM91501X04

3. Explanation of the degree to which the information is commercial or financial, or
contains a trade secret or is privileged:

This material includes a detailed theory of operation and circuit diagrams, (scdiagrams). As
such this material is treated as highly confidential business information.

4. 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 Location and Monitoring Service transmitting equipment that is offered on a highly
competitive basis. Customers for this equipment have a variety of competing sources.

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

Disclosure would, in effect, give away the fruits of the labors of Intermec’s engineering
personnel, who have designed the equipment and the manufacturing process. Disclosure
would also offer competitors additional unwarranted insight into the state of the product
development, thereby allowing competitors an advantage, not available to Intermec.

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

The information for which confidential treatment is sought is kept confidential by Intermec
and not made available to third parties except pursuant to non-disclosure agreements.

7. 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 heretofore. While the general theory of operation of this equipment has
been the subject of numerous disclosures in industry and standards groups as well as in rule
making proceedings of the FCC, the protection sought is narrowly drawn and pertains to
certain specific implementations of the modulated backscatter radio technology.

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

This material should not be disclosed for at least 25 years. While improvements in design
are made relatively frequently, disclosure of the design information would lead to insights
into both design and manufacturing techniques that could have an adverse competitive
effect for many years to come. Thus equipment is designed for commercial, industrial, and
governmental transportation applications. As such, unlike most consumer equipment, this
equipment will be used for more than a decade in some cases. Moreover, this equipment
will be used in revenue collection (e.g. toll collections) and secure access control
applications (e.g. freight handling facilities). As such, it is important that the design not be
made available to unauthorized persons who might attept to use knowledge of the design
to compromise the applications for which the equipment will be employed.

9. 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 8 above. Note that the equipment for which approval is being sought will be
employed in applications that inherently place a premium on security.

Respectfully,

Intermec Technologies Corporation

Document Created: 2019-11-08 09:46:54
Document Modified: 2019-11-08 09:46:54

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