Confidentiality

FCC ID: JQU801604

Cover Letter(s)

Download: PDF
FCCID_771786

                                                   6030 AMBLER DRIVE. M.SSISSAUGA. ONTARIO L4W2P1



March 2, 2007



      Request for Confidential Treatment — Application for Equipment Authorization for
                                   TDMA V6 Transponder
                                              FCC ID: JQU801604

On behalf of Mark IV Industries Corp. ("Mark IV") we request confidential treatment for the following
exhibits filed with Mark IV‘s application for equipment authorization for the TDMA V6 Transponder, FCC ID
JQU801604.

Mark IV requests that the following be treated as confidential and withheld from public inspection in
accordance with Section 0.457(d) (trade secrets) of the Commission‘s Rules. Pursuant to Section 0.459(b)
of the Commission‘s rules, Mark IV provides the following information in support of its request for
confidential treatment:

(1)   Mark IV requests confidential treatment for the operational description, schematic diagrams, parts list,
      voltage/currants, tune—up procedure and block diagram information submitted in exhibits to its
      application for equipment authorization for its TDMA V6 Transponder, FCC ID JQU801604 being filed
      concurrently. These exhibits are listed as follows:

      Exhibit Description

      TDMA V6 TRANSPONDER TECHNICAL DESCRIPTION/... Voltage/Currents and Tune—up
      Procedure Confidential Supplement.

      TDMA V6 TRANSPONDER SCHEMATICS AND PARTS LIST Confidential Supplement.

      TDMA V6 TRANSPONDER INTERNAL PHOTOGRAPHS — Marked Confidential Proprietary.

      TDMA V68 TRANSPONDER GENERAL OPERATION DESCRIPTION — Marked Confidential.

      Note: The TDMA V6 Transponder is not user serviceable and the case is closed with a tamper proof
      sticker.

(2)    These exhibits were submitted to the Commission in support of Mark IV‘s application for equipment
      authorization and provide the additional detail needed for the Commission‘s staff to properly evaluate
      the equipment.

(3)   These exhibits contain highly confidential and proprietary technical information about the equipment
      design and operating characteristics.

(4)   Mark IV competes with a number of companies that are developing and marketing similar
      transponders for ITS applications, including tolling operations.


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                                        1SO 2001:2000 — CERTIFICATE #002002


                                    MARK IV INDUSTRIES — IVHS DIVISION
MISSISSATGA. ONTARIO                        ALDBANXY, NEWYORK                        FLEMINGTON. NEWJERSEY
 TEL: 19051 624—3020                        TEL: (518; 458 8440                         TEL: 1908; 237 3020
 FAX: 1905) 625—6197                          FAX: (518; 458 9562                        FAX: (9081 237 8033


(5)    Disclosure of such information to competitors could compromise Mark IV‘s ability to develop this
       technology, in that other companies could reverse engineer products using this information.

(6)    Disclosure would relinquish valuable proprietary information about the technologies Mark IV has
       developed and its manufacturing processes. Disclosure would also offer competitors additional
       unwarranted insight into the state of Mark IV‘s product development thereby allowing competitors an
       advantage that would otherwise be unavailable to Mark IV.

(7)    Mark IV is careful in protecting proprietary aspects of its equipment design and processes. The
       information for which confidential treatment is sought is been kept confidential from public disclosure
       by Mark IV and has not been made available to third parties except pursuant to non—disclosure
       agreements. It is also Mark IV‘s practice to file a request for confidentiality at the time it submits an
       application for equipment authorization.

(8)    Mark IV requests that this information be withheld from public disclosure until and unless Mark IV
       notifies the Commission that such information may be publicly released. This equipment is designed
       for commercial, industrial, and governmental transportation applications and is expected to be used
       for more than a decade in some cases. Moreover, this equipment will be used in revenue collection
       (i.e. toll collections) where it is important that its design and operations details not be made available
       to unauthorized persons who might attempt to use knowledge of such details to compromise the
       applications for which the equipment will be employed.

(9)    Confidential treatment of exhibits, such as these, allows Mark IV to provide a full technical description
       of the equipment, which disclosure is in the public interest. Refusal to treat such documents as
       confidential would result in submission of insufficient information on which the FCC could base its
       decision to grant authorizations and delay deployment of these new and improved devices for ITS
       applications.



                          M
Sincerely,       /@0 /%;Z




Haijo Gabert
Director of Systems & Projects Engineering
Mark IV Industries Corp.




Request for Confidential Treatment — Application for Equipment Authorization for
TDMA V6 Transponder
ECC 1D: JQL801604
                                                                                                     Page 2 of 2



Document Created: 2019-09-17 19:15:50
Document Modified: 2019-09-17 19:15:50

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