Request for Confidentiality

FCC ID: EOA-24LIVIOBCHG

Cover Letter(s)

Download: PDF
FCCID_4493187

     S          k                                                                    6600 Washington Avenue S.
         ta r    ey.                                                                Eden Prairie, Minnesota 55344
     Hearing Technologies                                                                       T: 1.800.328.8602
                                                                                             www.starkey.com

 September 19, 2019
 Federal Communications Commission
 Authorization and Evaluation Division
 7435 Oakland Mills Road
 Columbia, Maryland 21046
 Re: Request for confidentiality
 Applicant: Starkey Laboratories, Inc. DBA Starkey Hearing Technologies
 FCC ID: EOA—24LIVIOBCHG
 To whom it may concern,
 Permanent Confidentiality
 Request is hereby submitted by Starkey Laboratories, Inc. DBA Starkey Hearing Technologies to
 withhold permanently from public review certain portions of the application for equipment
 certification for the referenced FCC identifiers. This request for confidentiality is made pursuant to
 47 CFR 0.457(d) and 0.459 of the FCC Rules. In particular, the following sections of the application
 are to be kept permanently confidential:
      e Schematics
      e Detailed Block diagrams
      e Detailed Operational/Functional Description
Short—term Confidentiality
Request is hereby submitted by Starkey Laboratories, Inc. DBA Starkey Hearing Technologies to
withhold from public review for a period of 180 days from the date of the Grant of Equipment
Authorization and prior to marketing, certain portions of the application for equipment certification
for the referenced FCC identifiers. This request for confidentiality is made pursuant to 47 CFR
0.457(d) and 0.459 of the FCC Rules. In particular, the following sections of the application are to
be kept confidential for a period of 180 days from the date of Authorization:
     e Test setup photos
     e External photos
     e Internal photos
     e User manual
Rationale for request for confidentiality:
Starkey Laboratories, Inc. DBA Starkey Hearing Technologies has invested considerable time and
materials in research and development to produce the referenced product: Disclosure of the
permanently confidential portions of this application to competitors would not only give them
significant competitive advantages in developing similar products, but would also disclose
successful implementation of unpublished, leading edge technology developed by us. Disclosure of
the short—term confidential portions of this application during the period of importation and/or
distribution would reveal key aspects of proprietary technology to competitors and diminish the
value of our investment in research and development.
 Sincerely,



~William J. Mitchell, PE
 Principal Regulatory Affairs Engineer
 Starkey Laboratories, Inc.
 952—918—5683
 bill_mitchell@starkey.com



Document Created: 2019-09-19 12:32:34
Document Modified: 2019-09-19 12:32:34

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