Response to FCC queries

FCC ID: H9PMC9002B

Cover Letter(s)

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FCCID_458515

Audit Responses to FCC correspondence related to Symbol MC9000 family Introduction The following response is a composite response to issues raised in the following Correspondence letters. The rationale is that many of the issues raised against one (or several) grants are equally of concern to others. Accordingly it is considered appropriate to address the totality of concern rather than focus on individual letters and miss the opportunity to clarify other issues, which though valid have not been highlighted for that particular grant. The following addresses issues raised in the following correspondence: FCC id Pt 24: GSM DTS— 802.11 DSS — Blue TC no. Corr no TC no. Corr no TC no. Corr no HIOPMCI062A TC790916 12997 TC9I96953 13002 TC173701 None HOPMCI062C TC144388 13004 TC691915 None N/A N/A H9PMCI002A TC797792 12646 N/A N/A TC995842 12644 H9PMCIOO2C TC260643 12801 N/A N/A N/A N/A HOPMCIO062B TC270723 13025 TC395364 13026 TC750077 13027 HI9PMCI062D TC276727 12492 TC502219 12490 N/A N/A HOPMCI002B TC156050 12700 N/A N/A TC619324 12702 HOPMCIOO2D TC538435 12803 N/A N/A N/A N/A HIPMCI9060B N/A N/A TC283234 None TCS58§4062 12973 (original/ HOPMCI060B N/A N/A TC195241 12974 TC239174 None (tch pc2)/ Family Relationships Family Building Blocks The MC9000 family of products are all related. They use the same basic main board but vary in the radio modules included. There are 5 Radio modules used within the product Family: Siemens MC46 (GSM 850 and 1900); Siemens MC4S (GSM 1900 only); Symbol 802.11 module; Symbol Bluetooth module; CDMA module. There are also three variations in the housing as follows: Short" housing with the 28 button keypad "Brick" housing with the 53 button keypad which is longer and includes an extended length battery "Gun" Housing with a handle grip. Page 1 of 7 10/08/2004

Audit Responses to FCC correspondence related to Symbol MC9000 family BABT TCB BABT as a TCB have not progressed any applications from this family of products, which include the CDMA module. However, we understand that submissions have been progressed for CDMA based family units through another TCB. BABT have only been involved with the product family members listed below: Products making use of the Quad band GSM transmitter The MC9062A uses the "Short" housing with the 28 button keypad and includes the e MC46 GSM Module, e 802.11 module, e Bluetooth module. The MC9062C is the same as the MC9062A except that the Bluetooth module is omitted. The MC9002A is the same as the MC9062A except that the 802.11 module is omitted. The MC9002C is the same as the MC9062A except that it contains only the MC46 GSM Module Products making use of the Tri—band GSM transmitter The MC9062B uses the "Brick" housing with the 53 button keypad and includes the e MC4S5 GSM Module, e 802.11 module, a * Bluetooth module. The MC9062D is the same as the MC9062B except that the Bluetooth module is omitted. The MC9002B is the same as the MC9062B except that the 802.11 module is omitted. The MC9002D is the same as the MC9062B except that it contains only the MC4S5 GSM Module Products without a GSM transmitter The MC9062B was originally approved using the "Short" housing and include the e 802.11 e Bluetooth Modules. A subsequent Class 2 Permissive Change added the "Brick" housing with additional keys and an alternate battery as an alternative The RLAN 802.11 module was approved by BABT under the FCC ID H9P2164436 as a radio module. 3 subsequent class 2 Permissive changes involved the addition of the following "Hosts" to the grant e Short Housing e Brick Housing e Gun Housing (Information related to the Grantfor the RLAN module is includedfor completeness but is not the subject ofany ofthe correspondence finding) The Bluetooth module was approved by another party under the FCC ID H9P2164381 as a radio module. A subsequent class 2 Permissive change was progressed by BABT and involved the addition of the following "Hosts" to the grant e Short Housing (Information related to the Grant for the Bluetooth module is included for completeness but is not the subject of any of the correspondence finding). Page 2 of 7 10/08/2004

Audit Responses to FCC correspondence related to Symbol MC9000 family Product Family Accessories The product has the following declared accessories: e A holster which is common to all the family e A headset which is common to all the family Test and Approval Strategy Testing Products includinga GSM Module For testing product which included a GSM module the client supplied the fully configured MC9062A and MC9062B variants. Both were initially capable of co—transmission. Symbol implemented a software change, which inhibited this capability. All testing was conducted using these fully configured samples as the client declared there would be no significant differences (related to the included radios) in the sub—equipped versions. There was a meeting between Symbol and the FCC where Symbol justified the use of the "Fully equipped" test data in support of the sub—equipped grants. While the FCC were uncomfortable they agreed in this instance but stated in future "Worst case" testing should be undertaken on the de—configured versions MC9060B This was tested separately from the other family members, in both the "Short" and "Brick" housings EMC Test Photo In the EMC report the Headset is shown mounted on a head phantom. This is for display purposes only and not an SAR phantom; it does not contain any liquid. Approval Strategy Products including a GSM Module Symbol (via their Agent) submitted separate approvals submissions for each variant using the test data obtained using the fully configured versions; additionally many of the supporting letters covered more than one particular product. In some of the data results related to the initial "Co—transmission" capability were still present. It had been agreed between BABT and Symbol that the TCB would progress the initial grants with co— transmission inhibited and that subsequent Class 2 Permissive changes would be made to the FCC to lift this inhibition. Exhibit 13 (Covering letters) entitled "Co—existence Statement" declares the inhibition. [Note since this letter covers the whole product family it includes references to CDMA, as stated earlier None of the Products covered by grants referenced above includes a CDMA transmitter. This note confirms that the Grants made by BABT covered products where the client had declared they were unable to co—transmit. Page 3 of 7 10/08/2004

Audit Responses to FCC correspondence related to Symbol MC9000 family SAR Issues Co—Transmission Results As stated earlier the client declared during test that a software inhibition to co—transmission would be included in the initial product. The uploaded SAR reports included such data. The SAR report will be amended to include only results related to single transmission cases. Headset The headset is connect via a wire and does not have a transmitter It is noted that TUV test practice was to conduct Head SAR tests with a headset in place. It is recognised these test results are not required The test results related to the Headset placed on the Head phantom will be deleted from the SAR Reports The Body testing was conducted with the Headset connected. Holster The PCT transmitters were tested in the holster initially with the device in the "intended " orientation. However the worst—case frequency was used to test with the device 180 degrees turned facing the opposite direction. Initially this data was "For advice" only. After discussion between Symbol, the FCC, and both interested TCB‘s Symbol have agreed that the Worst case is the "incorrect" orientation; these results will be used for the SAR levels. The DTS and DSS transmitters were tested at 1 cm separation and outside the holster. This was based upon the declared separation distance in the User Manual since no "orientation could be guaranteed in third party holsters the orientation with the active Antenna nearest the phantom was used. The separation distance for the holster was much greater. Accordingly it was viewed that the 1 cm distance was the worst case. Since we cannot use different minimum distance criteria for co—located transmitters where the transmitter position is not visible the 4 cm separation distance will be used for the DTS and DSS grants. Symbol wished that other holsters be permitted for use. It was determined that the existing holster provides for a 4 cm separation. In the absence of any "Out of Holster" data for the PCT Symbol have agreed to a 4 cm distance stipulation. The Symbol supplied holster contains metal parts and the primary SAR testing took place using the Holster. The User manual will be updated to provide advice on device orientation; holster positioning; and the minimum distance to be used for 3"" party holsters This is not significant as the primary SAR testingtook place using the Holster. Page 4 of 7 10/08/2004

Audit Responses to FCC correspondence related to Symbol MC9000 family The Use of Phantom Although the device is almost as large as the flat phantom it was assessed against, the phantom size was sufficient to cover the whole area of the device tested and the device‘s active area was measured to be significantly smaller due to the nature of the frequencies being employed in the transmitter modules. The device was positioned so that the central location of the maximum RF energy location was centrally positioned against the 2mm side of the flat phantom. The actual RF distribution, recorded during the SAR scan showed that there was no potential secondary peak and that there were no significant boundary effects caused by the phantom size. It is believed that the process described above adequately covers the requirements for assessing localised SAR distributions on large devices. Please refer to a previously provided paper ‘Flat Phantom Set—up for the performance Check and System Validation of measurement systems according to IEEE15S28 and IEC62209 — Andreas Christ and Niels Kuster May 13, 2002‘ which suggests that the size of phantom used is quite adequate for the transmit frequency of the device under test since our procedure additionally checked that the SAR field distribution was well—contained within the volume of the phantom. SAR Evaluation Notes The SAR evaluation Notes will be updated as appropriate to the above changes/clarifications Page 5 of 7 10/08/2004

Audit Responses to FCC correspondence related to Symbol MC9000 family Grant Issues PCT Grants The following aspects will be clarified/amended on the GSM grants Amend SAR value to represent SAR value for "incorrect/worst case" orientation Add reference to listed holster Add reference to 4 cm separation Check/clarify co—location statement in Grant Add statement that Grant only relates to 1900 (and as applicable 950) MHz "i.e. not EU bands" 802.11 transmitter grants The following aspects will be clarified/amended on the 802.11 transmitter grants Amend EAC from DSS to be DTS Clarify Frequency bands (to match modular approvals) Revise Power to be "Conducted power" Add Radiated Power as a grant note Add reference to listed holster Add reference to 4 cm separation Check/clarify co—location statement in Grant Add "CC" note where Bluetooth also present Bluetooth (DSS) transmitter grants The following aspects will be clarified/amended on the Bluetooth transmitter grants Clarify Frequency bands (to match modular approvals) Revise Power to be "Conducted power" Add Radiated Power as a grant note Add reference to listed holster Add reference to 4 cm separation Check/clarify co—location statement in Grant Add "CC" note where Bluetooth also present Page 6 of 7 10/08/2004

Audit Responses to FCC correspondence related to Symbol MC9000 family Changed Exhibits Changed Exhibits The following exhibits will be uploaded or superseded e Exhibit 8 (User Manual): A new version (Regulatory Guide) has been uploaded (as non— confidential). e Exhibit 9 (Internal Photos) : For all sub—equipped variants additional exhibits have been uploaded * Exhibit 11 (SAR Report) : The existing report will be superseded; An updated version with appropriate changes from above responses has been uploaded * Exhibit 11 (SAR Assessment): The existing SAR evaluation letters will be superseded; New versions based upon the updated SAR reports have been uploaded * Exhibit 12 (Antenna Placement) For all sub—equipped variants Additional photograph exhibits have been uploaded e Exhibit 13: (Cover Letters) A new "Family Tree" description has been uploaded to define the product interrelationships e Exhibit 13:; (Cover Letters): The exhibit entitled "Sub—equipped Models letter" has been superseded Special Changes In H9PMCI002C TC260643 Exhibit 6 (Test Report). MC45 Report has been superseded Page 7 of 7 10/08/2004


Document Created: 2019-11-10 23:30:40
Document Modified: 2019-11-10 23:30:40
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