modular letter

FCC ID: GU6-9855M5E

Cover Letter(s)

Download: PDF
FCCID_1370829

                                                                                                     170 Monarch Lane
                                                                                                     Miamisburg, OH 45342
                                                                                                     Phone 1.937.865.2123
                                                                                                     Fax 1.937.865.2048

November 3, 2010



SIEMIC Inc.
2206 Ringwood Avenue
San Jose, CA 95131
Tel:+1(408)526 1188
Fax:+1(408)526 1088


Ref: 9855RFMP with ThingMagic M5e


Reference: DA 00-1407 Released: June 26, 2000 PART 15 UNLICENSED MODULAR TRANSMITTER
APPROVAL FCC TCB


To Whom It May Concern:


Below are the eight elements a module is required to meet to comply with Part 15, Unlicensed
Modular Approval notice, DA 00-1407, Dated June 26, 2000. Also included are my arguments on why
our module meets the requirements.


                               1. The modular transmitter must have its own RF shielding. This is intended to
                                    ensure that the module does not have to rely upon the shielding provided by
                                    the device into which it is installed in order for all modular transmitter
                                    emissions to comply with Part 15 limits. It is also intended to prevent
                                    coupling between the RF circuitry of the module and any wires or circuits in
                                    the device into which the module is installed. Such coupling may result in
                                    non-compliant operation.

                                         a. The Transmitter provided by ThingMagic is provided with an
                                               enclosure that provides the required shielding.

                               2. The modular transmitter must have buffered modulation/data inputs (if such
                                    inputs are provided) to ensure that the module will comply with Part 15
                                    requirements under conditions of excessive data rates or over-modulation.




                   Avery Dennison Retail Information Services, LLC, a Subsidiary of Avery Dennison Corporation


                      a. The inputs are buffered and the data
                            is processed by a microprocessor in
                            the ThingMagic M5e, thereby
                            eliminating excessive data rates or over modulation.

            3. The modular transmitter must have its own power supply regulation. This is
                 intended to ensure that the module will comply with Part 15 requirements
                 regardless of the design of the power supplying circuitry in the device into
                 which the module is installed.

                      a. We provide an I/O board that regulates the supply voltage from 24
                            volts down to the 5 volts the ThingMagic M5e module needs.

            4. The modular transmitter must comply with the antenna requirements of
                 Section 15.203 and 15.204(c). The antenna must either be permanently
                 attached or employ a “unique” antenna coupler (at all connections between
                 the module and the antenna, including the cable). Any antenna used with
                 the module must be approved with the module, either at the time of initial
                 authorization or through a Class II permissive change. The “professional
                 installation” provision of Section 15.203 may not be applied to modules.

                      a. The antenna uses MMCX connectors. In this application the
                            customer will never change the antenna. The reason is, if they
                            change it to a higher gain antenna, they will program more than one
                            tag at a time, which will prevent their RFID tags from working
                            properly.

            5. The modular transmitter must be tested in a stand-alone configuration, i.e.,
                 the module must not be inside another device during testing. This is
                 intended to demonstrate that the module is capable of complying with Part
                 15 emission limits regardless of the device into which it is eventually
                 installed. Unless the transmitter module will be battery powered, it must
                 comply with the AC line conducted requirements found in Section 15.207.
                 AC or DC power lines and data input/output lines connected to the module
                 must not contain ferrites, unless they will be marketed with the module (see
                 Section 15.27(a)). The length of these lines shall be length typical of actual
                 use or, if that length is unknown, at least 10 centimeters to insure that there
                 is no coupling between the case of the module and supporting equipment.
                 Any accessories, peripherals, or support equipment connected to the
                 module during testing shall be unmodified or commercially available (see
                 Section 15.31(i)).




Avery Dennison Retail Information Services, LLC, a Subsidiary of Avery Dennison Corporation


                      a. Avery Dennison Retail Information
                         Services LLC tested the RFID module
                         inside one of our printer during the
                         tests at Siemic due to the need to
                         confirm it could be co-located with another transmitter. During the
                         tests it was powered by the printers 24VDC power supply, using
                         the Avery Dennison I/O board to further reduce the supply voltage
                         to 5VDC (see note in item 3 above). The dual regulation will
                         provide a stable operating voltage for the module.

            6. The modular transmitter must be labeled with its own FCC ID number, and,
                 if the FCC ID is not visible when the module is installed inside another
                 device, then the outside of the device into which the module is installed
                 must also display a label referring to the enclosed module. This exterior
                 label can use wording such as the following: “Contains Transmitter Module
                 FCC ID: XYZMODEL1” or “Contains FCC ID: XYZMODEL1.” Any similar
                 wording that expresses the same meaning may be used. The Grantee may
                 either provide such a label, an example of which must be included in the
                 application for equipment authorization, or, must provide adequate
                 instructions along with the module which explain this requirement. In the
                 latter case, a copy of these instructions must be included in the application
                 for equipment authorization.

                      a. This module will only be used in Avery Dennison RIS LLC printers
                            and will be under Avery Dennison RIS LLC control. We will include
                            the required external label as well as label the module.

            7. The modular transmitter must comply with any specific rule or operating
                 requirements applicable to the transmitter and the manufacturer must
                 provide adequate instructions along with the module to explain any such
                 requirements. A copy of these instructions must be included in the
                 application for equipment authorization. For example, there are very strict
                 operational and timing requirements that must be met before a transmitter is
                 authorized for operation under Section 15.231. For instance, data
                 transmission is prohibited, except for operation under Section 15.231(e), in
                 which case there are separate field strength level and timing requirements.
                 Compliance with these requirements must be assured.

                      a. All of the timing is controlled by software in the ThingMagic M5e
                            unit and is not adjustable by the user.

            8. The modular transmitter must comply with any applicable RF exposure
                 requirements. For example, FCC Rules in Sections 2.1091, 2.1093 and
                 specific Sections of Part 15, including 15.319(i), 15.407(f), 15.253(f) and


Avery Dennison Retail Information Services, LLC, a Subsidiary of Avery Dennison Corporation


                                     15.255(g), require that Unlicensed PCS, UNII
                                     and millimeter wave devices perform routine
                                     environmental evaluation for RF Exposure to
                                     demonstrate compliance. In addition, spread spectrum transmitters
                                     operating under Section 15.247 are required to address RF Exposure
                                     compliance in accordance with Section 15.247(b)(4). Modular transmitters
                                     approved under other Sections of Part 15, when necessary, may also need
                                     to address certain RF Exposure concerns, typically by providing specific
                                     installation and operating instructions for users, installers and other
                                     interested parties to ensure compliance.

                                          a. Through testing at Siemic, has confirmed our compliance with RF
                                                Exposure limits.


If you have any questions or concerns, please contact me by email at jim.bacher@averydennsion.com;
phone at 1-937-865-2020; or by fax at 1-937-865-2048.


Sincerely,




James A Bacher
Senior Engineer
Avery Dennison RIS LLC
170 Monarch Lane
Miamisburg, Ohio 45342
1-937-865-2020 (voice)
1-937-865-2048 (fax)
jim.bacher@averydennison.com

cc:     Dave Best




                    Avery Dennison Retail Information Services, LLC, a Subsidiary of Avery Dennison Corporation



Document Created: 2010-11-03 16:10:46
Document Modified: 2010-11-03 16:10:46

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