Reply to ATCB

FCC ID: KBCIX300AC775WLBT

Cover Letter(s)

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FCCID_505240

American Telecommunications Certification Body Inc. 6731 Whittier Ave, McLean, VA 22101 January 2, 2005 RE: FCC ID: KBCIX300AC775WLBT_ATCB001936 Attention: Rod Munro I have a few comments on this Application. Please note that further comments may arise in response to answers provided to the questions below. 1. Please provide a photo of what is under the covered section of the first photo in the exhibit “Exhibit 9 Internal Photos AC775.pdf”. 2. Please note that while you have provided the parts list for the BT and the WLAN, you have not provided the parts list for the licensed device. Please provide the parts list for the licensed device. 3. Please verify that this device cannot be used in any configuration where the antenna(s) are closer than 2.5 cm to the body. Please verify that no advertising or other documentation shows or indicates that this device can be used in this type configuration. 4. Please note that while the antenna conducted measurements provided may be used, the radiated emissions testing including the simultaneous transmission test data must be with the transmitters in the host listed in the filing (i.e. KBCIX300AC775WLBT). The simultaneous transmission data provided, while referencing the above ID, is listed as being from that of the AC555 device. Please explain. 5. Please note that the MPE report states that all three devices cannot transmit simultaneously. Please also note that the report “Exhibit 6 Test Report Simultaneous Transmit IX300 AC555 WLAN BT.pdf” states that all three devices can transmit simultaneously. Please explain and please reconcile all documentation as to the simultaneous operating capabilities of this device. 6. Please be precise as to what specific tests from the multiple reports apply specifically to this application. As you have a number of varying reports for different products it is important to clearly state what tests are deemed to apply to the specific application. Dennis Ward mailto:dward@AmericanTCB.com The items indicated above must be submitted before processing can continue on the above referenced application. Failure to provide the requested information may result in application termination. Correspondence should be considered part of the permanent submission and may be viewed from the Internet after a Grant of Equipment Authorization is issued. Please do not respond to this correspondence using the email reply button. In order for your response to be processed expeditiously, you must submit your documents through the AmericanTCB.com website. Also, please note that partial responses increase processing time and should not be submitted. Any questions about the content of this correspondence should be directed to the sender.

_2A /,/i‘/’/ \\_}:\ s P EC TR U M 209 Dayton Street, Suite 205 feprhnolo§s8 Mn ‘ii Edmonds, WA 98020—3581 425 771—4482 425 771—9283 Fax January 5, 2005 ATCB, Inc. 67312 Whitter Ave. McLean, Va 22101 Attn: Dennis Ward In Reply to your January 2, 2005 Email RE: FCC ID: KBCIX300AC775UWLBT_ATCBO01936 Dennis, We have replied to your comments concerning the above referenced Application below in blue under the original question. 1. Please provide a photo of what is under the covered section of the first photo in the exhibit "Exhibit 9 Internal Photos AC775.pdf. A new photo showing the section under the shield has been submitted by Sierra Wireless to you directly by email in separate correspondence. 2. Please note that while you have provided the parts list for the BT and the WLAN, you have not provided the parts list for the licensed device. Please provide the parts list for the licensed device. A separate email correspondence from Ying Wang of Sierra Wireless to you directly, discussed the issue of referring to the tune up procedure provided and not the BOM. 3. Please verify that this device cannot be used in any configuration where the antenna(s) are closer than 2.5 cm to the body. Please verify that no advertising or other documentation shows or indicates that this device can be used in this type configuration. A statement from Itronix has been uploaded specifically addressing this request. 4. Please note that while the antenna conducted measurements provided may be used, the radiated emissions testing including the simultaneous transmission test data must be with the transmitters in the host listed in the filing (i.e. KBCIX300AC775WLBT). The simultaneous transmission data provided, while referencing the above ID, is listed as being from that of the AC555 device. Please explain. The simultaneous data references the 1X300 with AC555 only for the two Part 15.247 transmitters simultaneous test data and does not the include AC555 emissions, only the two Part 15 devices operating on the same channels for a worst case. The BT and WLAN in the AC555 configuration are physically and electrically identical to the BT and WLAN transmitters in the AC775 configuration. The Part 15.247 test data would remain representative of the newly identified device. Simultaneous transmit measurements were made with the AC775 last month and are in the same report but show that cellular and PCS related channels and harmonics.

5. Please note that the MPE report states that all three devices cannot transmit simultaneously. Please also note that the report "Exhibit 6 Test Report Simultaneous Transmit IX300 AC555 WLAN BT.pdf" states that all three devices can transmit simultaneously. Please explain and please reconcile all documentation as to the simultaneous operating capabilities of this device. The standard User Operating software does NOT allow for all three transmitters to operate simultaneously. So for the purpose of MPE this mode, (all three transmitters transmitting) of operation could not exist when operating with User software. Using Test software we are able to transmit with all three but the user could NOT do this. Where data is provided with all three active, it is done to reduce the number of separate measurements and provide a "worst case" scenario. The equipment complied with the Part 22/24 standards with all three active so although an artificial circumstance, we were not concerned. The User can transmit with the 1.) AC775 & BT or 2.) WLAN & BT only. The simultaneous data submitted is to cover these 2 modes of operation. 6. Please be precise as to what specific tests from the multiple reports apply specifically to this application. As you have a number of varying reports for different products it is important to clearly state what tests are deemed to apply to the specific application. The specific test reports are applicable as follows: Applicable to: _ Report file name '?Radi’a'tédmsmpuflridu‘s a'hfd Haflrméhi'cs ERP/ EIRP' IXBOO | |Exhibit 06 Test Report 1 Pt 22 24 and AC775 Part 22/24 AC775KBCIX300AC775WLBT. pdf Exhibit 6 Test Report 2_Pt 15 WM168B MOLEX ~[Radiated Spurious and Harmonics _ §IX300 WLAN & BT Part 15.247 KBCIX300ACSS5SWLBT.pdf — %'Radia"ced ’Sp'u'rious é'nd'Harmonics 'Ohly — ‘Exhibit 6 Test Report 3 PT 15.247 BT Test Report §IX300 WLAN & BT Part 15.247 TX300AC555WLBT. pdf ‘Exhibit 6 Referenced 1X300 Original Twinhead ‘All Conducted data for WLAN & BT Part 15.247 |Report WLAN and BT.pdf QExhibit 6 Sierra Wireless Pt 2224 OEM Test _ lAll Conducted data for AC775 |Part 22/24 Report.pdf |Exhibit 6 Test Report Part 15.107_109_207_209 _ |AC Conducted/ Radiated Emissions for IX300with _ [AC775 WLAN & BT Part 15.107 & 15.109 1X300 with AC775.pdf |Exhibit 6 Test Report Simultaneous Transmit 1X300 SimultaneousTransmit WLANandBT ONLY _ _ [Part15.247 from AC555 report and Simultaneous AC555 WLAN BT.pdf _ Transmit with AC775, WLAN and BT Part 22/24 _ I hope to have adequately addressed your concerns. Please let me know if I may provide anything further to assist in your review of this application. To) bf Hun Best Regards, Rod Munro


Document Created: 2005-01-05 12:35:56
Document Modified: 2005-01-05 12:35:56
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