Request for Confidentiality

FCC ID: EOA-24LIVIOR312

Cover Letter(s)

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FCCID_4496585

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

 September 23, 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—24LIVIOR312
 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    Detailed Operational/Functional Description


 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 successful implementation of unpublished, leading edge technology developed by us.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,

F7
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                            tC(7/
 William J. Mitchell, PE
 Principal Regulatory Affairs Engineer
 Starkey Laboratories, Inc.
 952—918—5683
 bill_mitchell@starkey.com



Document Created: 2019-10-10 08:20:35
Document Modified: 2019-10-10 08:20:35

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