Request for action

FCC ID: KBCIX300AC775WLBT

Cover Letter(s)

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FCCID_505274

                     EXHIBIT XIII - Cover Letters

                   New Certification Report for the

                   FCC ID: KBCIX300AC775WLBT




Cover Letter 1.)   Certification Action Requested

Cover Letter 2.)   Request for Confidentiality under Part 0.459.

Cover Letter 3.)   ITRONIX Agent Authorization letter allowing Rod Munro to
                   Sign FCC Form 731 on behalf of ITRONIX, Corp.




                                  Exhibit 13


               fual


s PE CTRU M                     209 Dayton Street, Suite 205
*52RR81O8RY U Y                 Edmonds, WA 98020—3581                  425 771—4482             425 771—9283   Fax

       November 19, 2004

       Federal Communications Commission
       Authorization and Evaluation Division
       C/O American TCB, Inc.
       6731 Whitter Avenue
       McLean, VA 22101

       Re:     Action requested: Certification of co—located mobile transmitters (20 cm antenna to user)
               Grantee: ITRONIX, Corporation
               FCC ID:; KBCIX300AC775WLT

       Gentlemen:

       On behalf of ITRONIX, Corporation we request Certification under Parts 15, 22 and 24 for the
       1X300 as a mobile device with the three internally integrated co—located transmitters. The 1X300
       is a ruggedized Tablet PC that contains the following Transmitter and two Intentional Radiators:

       1.) PCS Transmitter previously Certified by Sierra Wireless, Inc., FCC ID: NCNAC775 operating
           under Parts 22H and 24E
       2.) WLAN, 802.11(b) previously Certified Intentional Radiator by AirVast Technology Inc., FCC
           D; QDWWM168B under Part 15.247 for DTS devices.
       3.) A Bluetooth Intentional Radiator previously Certified by Billionton Systems, Inc., FCC ID:
           NLE—MUBTC2—CLEVO under Part 15.247 DSS rules for FHSS.

       For Items 1, 2 and 3 we have submitted EMC test reports covering EIRP, radiated spurious and
       harmonic emissions for these three transmitters and their individual antenna combinations.
       Measurement data addressing simultaneous transmit of the co—located transmitters is also
       provided. We will be referring to the original manufacturers Certification test report data for some
       of the conducted measurements where appropriate. All OEM models would be considered
       "identical" to the originally approved device as defined by Part 2.908. The AirCard 775 uses the
       identical antenna it was originally approved with in the Sierra Wireless, Inc. OEM filing.

       MPE calculations according to the FCC training materials from May 2003, are in Exhibit 11, and
       are submitted for multiple frequency exposure criteria. The ratio of the field strength or power
       density to the applicable exposure limit at the exposure location was determined for each
       transmitter and the sum of these ratios does not exceed the 1mW/cm*2 limit for General
       Population/Uncontrolled. in this product the WAN and Bluetooth can transmit at the same time as
       can the WLAN and Bluetooth. The WAN and WLAN cannot transmit at the same time, neither
       can all three transmit at the same time with the software available to the end user.

       We sincerely thank you for your time and consideration of this application. Please contact the
       undersigned should you require any additional information concerning this request for
       Certification.

       Sin    ly,


       /     ;
       Rod Munro
       President
       Spectrum Technology, Inc.
       Agent on behalf of ITRONIX, Corp.
       Email: rmunro@spectrumti.com



                                                  Exhibit 13


                                                              ITRONDC
                                                               801 S. STEVENS STREET
                                                               SPOKANE, WA 99204

                                                               509.624.6600
                                                               800.441.1309
                                                               FAX 509.626.4203
                                                               www.itronix.com


November 17, 2004



American Telecommunications Certification Body, Inc.
6731 Whittier Avenue
Suite C110
McLean, VA 22101

TO WHOM IT MAY CONCERN

Pursuant to Paragraphs 0.457 and 0.459 of the Commission Rules (47 C.F.R.) and section
552(b) (4) of the Freedom of Information Act, Itronix Corporation requests confidentiality
for the following product:

FCC ID: KBCIX300AC77Z5SWLBT

For the product stated above, we request that the following information be held
confidential:
Schematic diagrams.
Parts List.
Tune—up Procedure.
Operational description.
Block Diagrams

No other items submitted as part of the equipment authorization filing process are deemed
confidential. The above exhibits contain Itronix Corporation and Sierra Wireless
Corporation Trade secrets and proprietary information that could be of benefit to our
competitors regarding the design of our mobile PC Card. This material is not customarily
available to the general public and we request that it be withheld from public inspection.

If you have any questions, please feel free to contact me at address shown below.
Sincerely,



Li Q/X77>-
Richard Sargent
Sr. Manager Agency
ITRONIX CORPORATION


                                                                 801 S. STEVENS STREET
                                                                 SPOKANE, WA 99204

                                                                 509.624.6600
                                                                 800.441.1309
                                                                 FAX 509.626.4203
                                                                 www.itronix.com




November 17, 2004



American Telecommunications Certification Body, Inc.
6731 Whittier Avenue
Suite C110
MclLean, VA 22101


To Whom It May Concern:

Please be advised that Itronix Corporation authorizes Rod Munro of Spectrum Technology
Corporation to act on our behalf, until otherwise notified, for applications submitted to
American Telecommunications Certification Body, Inc. (ATCB).

We certify that we are not subject to denial of federal benefits, that includes FCC benefits,
pursuant to Section 5301 of the Anti—Drug Abuse ACT of 1988, U.S.C. 862. Further, no
party, as defined in 47 CFR 1.2002(b), to the application is subject to denial of federal
benefits, that includes FCC benefits.

Thank you for your attention to this matter.



Sargent
Rlchard             2
Sr. Manager Agency
ITRONIX CORPORATION



Document Created: 2004-11-19 13:04:11
Document Modified: 2004-11-19 13:04:11

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