Reply to FCC correspondence 9455

FCC ID: KBCIX260MPIA750BT

Cover Letter(s)

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FCCID_364768

sPECTrRU M                       209 Dayton Street, Suite 205
technology     inc.
                                 Edmonds, WA       98020—3581             425    771—4482          425    771—9283   Fax



      October 13, 2003


      Mr. Martin Perrine
      mperrine@fec.gov
      FCC Equipment Authorization Branch

      Re:       FCC ID: KBCIX26OMPIA75OBT
                Applicant: Itronix Corporation
                Correspondence Reference Number: 9445
                731 Confirmation Number: TC133864
                Date of Original Email: 09/22/2003

      Subject : Reply to request for additional information email 09/22/2003

      Your original questions are listed as Q 1 — Q3 will the reply below each.

      Q1) Please provide details of chosen method to avoid FCC ID label confusion in accordance with
      the following statement. We have noticed that with some products with internal transmitters such
      as laptops or PDA‘s, an incorrect FCC identifier can be seen when the product is opened up by
      the end user while installing an internal component such as a memory card. We are concerned
      that this may cause some confusion as to which FCC identifier is valid. Therefore, we suggest
      that the manufacturer implement some method to avoid this issue. Although we prefer that the
      manufacturer remove or cross out the incorrect label, other methods such as user warnings
      (external label or manual statements) may be acceptable.

      1.) ITRONIX Corp. has chosen to add the wording below to the product manual for the IX260.
          Attached please find file: Exhibit 8 User Cautions Revised ManuallegallX260MPIA750BT
          rev2.

            "The GOBook II (IX260) computer may have multiple transmitters installed. Each radio may
            have an individual FCC identifier. Only the FCC identifier on the Itronix Label is Valid for this
            configuration.

      Q2) Please detail the location(s) of the exposure evaluation. How was this location determined?
      The FCC understands that the evaluation was performed at a distance from the antenna not at
      the antenna terminal. However, there is more than one antenna and colocation techniques must
      be used to determine the maximum location. Please provide additional details of how the location
      of maximum exposure was performed.

      2.) The location of RF exposure was at the antenna terminal. The calculations provided in
          Exhibit 11 were based on the measured power output at the antenna terminal for each of the
            transmitters. We would expect that the measured levels at the antenna terminal would
            represent a worst case level when calculated using max. power, max. antenna gain, and the
            summing of all transmitter power.    Further no cable loss for the cables from the transmitter
            terminals to their respective antenna‘s is included in this calculation would reduce the level a
            minimum of 1.3 dB at 1850 MHz and 1.6 at 2450 MHz. Attached is a Simplistic Co—location
            Sample for the three transmitters to show the summed power density based on a modified
            sample Excel calculations from the TCB Session 8 (modified to sum the power density for 3
            transmitters), see attached file: Tri locate MPE EXCEL Spreadsheet KBCIX26O0MPIA750BT.
            Also attached is a file named: Cell Calculations for Tri locate MPE EXCEL Spreadsheet
            KBCIX26O0MPIAT7ZSOBT, that should display the formula for each cell.     | would be glad to


    provide a separate Excel copy via email if you would care to look at it in more detail in Excel
    rather than after being converted to a PDF when uploaded.

Q3) Please discuss the reason for the division by 5 in the second table on page 1.

3.) This original Exhibit 11 filed had the type—o mistake listing the 5 on the second table on page
    1 which had been corrected to 1 and replaced during the TCB review. The original rather
    than the revised file was inadvertently submitted to the FCC. The correct revised file Exhibit
    11 MPE for Pt 24 & 15.247 Revi is attached.

The Grantee has been advised that this FCC ID cannot be used when any one of the transmitters
has been depopulated from the laptop. All transmitters must be present.

I hope that we have addressed the questions to your satisfaction.


Best Regards,




Lod)Uts
Rod Munro



Document Created: 2003-10-13 16:48:26
Document Modified: 2003-10-13 16:48:26

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