Modular approval

FCC ID: MCQ-50M1538

Cover Letter(s)

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FCCID_1009449

                 Digi International
                 11001 Bren Road East
                 Minnetonka, MN 55343
                 952-912-3444 tel
                 952-912-4991 central fax

07-14-2008

AmericanTCB
6731 Whittier Avenue
McLean VA 22101

Attn: Director of Certification

RE: FCC ID: MCQ-50M1538 / IC: 1846A-50M1538 submittal as modular device

1. The modular transmitter must have its own RF shielding. This is intended to ensure that the module
   does not have to rely upon the shielding provided by the device into which it is installed in order for all
   modular transmitter emissions to comply with FCC Part 15 and Industry Canada limits. It is also
   intended to prevent coupling between the RF circuitry of the module and any wires or circuits in the
   device into which the module is installed. Such coupling may result in non-compliant operation.

    The WiEM9210bg module is designed such that all RF components and circuitry are placed on the top
    surface of the PCB. No RF related circuitry is present on the bottom surface of the PCB. A formed
    metal shield is soldered onto the top of the PCB and covers all RF components and circuitry.

2. The modular transmitter must have buffered modulation/data inputs (if such inputs are provided) to
   ensure that the module will comply with Part 15 and Industry Canada requirements under conditions of
   excessive data rates or over-modulation.

    The user data enters the WiEM9210bg module by way of serial data ports. All of the user data that is to
    be transmitted over the modular transmitter is buffered by the WiEM9210bg’s baseband controller. The
    user’s data is packetized and transmitted at data rates that are completely controlled by the baseband
    controller and its software. The user has no access to either the baseband controller or its software.

3. The modular transmitter must have its own power supply regulation. This is intended to ensure that the
   module will comply with Part 15 and Industry Canada requirements regardless of the design of the
   power supplying circuitry in the device into which the module is installed.

    All critical RF circuitry runs on a locally regulated power supply which allows the module to function
    within specification with worst case input voltages ranging from 2.93V (module will enter a non-
    operative state if the Vin drops to <2.93V ) to 4V (Vin >4V will cause a catastrophic failure of the
    processor and the unit will cease to function) . The optimal Vin voltage range is 3.3V +/-5%.


                Digi International
                11001 Bren Road East
                Minnetonka, MN 55343
                952-912-3444 tel
                952-912-4991 central fax

4. The modular transmitter must comply with the antenna requirements of FCC Sections 15.203 and
   15.204(c) and Industry Canada requirements. The antenna must either be permanently attached or
   employ a “unique” antenna coupler (at all connections between the module and the antenna, including
   the cable). Any antenna used with the module must be approved with the module, either at the time of
   initial authorization or through a Class II permissive change. The “professional installation” provision of
   FCC Section 15.203 may not be applied to modules.

    The WiEM9210bg module has two antenna configurations. One configuration uses a single reverse
    polarity SMA (RP-SMA) antenna connector and the other uses two U.FL antenna connectors. The
    RPSMA connector is designed with a male center pin which prevents a standard SMA connector from
    being mated to the WiEM9210bg module.

5. The modular transmitter must be tested in a stand-alone configuration, i.e., the module must not be
   inside another device during testing. This is intended to demonstrate that the module is capable of
   complying with FCC Part 15 and Industry Canada emission limits regardless of the device into which it is
   eventually installed. Unless the transmitter module will be battery powered, it must comply with the AC
   line conducted requirements found in FCC Section 15.207. AC or DC power lines and data input/output
   lines connected to the module must not contain ferrites, unless they will be marketed with the module
   (see FCC Section 15.27(a)). The length of these lines shall be length typical of actual use or, if that
   length is unknown, at least 10 centimeters to insure that there is no coupling between the case of the
   module and supporting equipment. Any accessories, peripherals, or support equipment connected to
   the module during testing shall be unmodified or commercially available (see FCC Section 15.31(i)).

    The WiEM9210bg module is designed to be compliant with all relevant FCC requirements without any
    additional shielding or filtering of any sort. As tested, the WiEM9210bg module was mounted on top of a
    carrier board which provided the +3.3VDC to power the module and an RS232 line transceiver to allow
    serial data traffic. The carrier board drives the +3.3V from an on-card DC to DC converter which is in
    turn powered by an external +12VDC power supply which is mains powered. There are no additional
    filters associated with the module/carrier board. Nor is there any additional shielding associated with
    this setup – beyond the shield that is soldered to the module.


                Digi International
                11001 Bren Road East
                Minnetonka, MN 55343
                952-912-3444 tel
                952-912-4991 central fax


6. The modular transmitter must be labeled with its own FCC ID / IC number, and, if the FCC ID / IC
   number is not visible when the module is installed inside another device, then the outside of the device
   into which the module is installed must also display a label referring to the enclosed module. This
   exterior label can use wording such as the following: “Contains Transmitter Module FCC ID:
   XYZMODEL1 / IC: XXX-YYYY” or “Contains FCC ID: XYZMODEL1 / IC: XXX-YYYY.” Any similar
   wording that expresses the same meaning may be used. The Applicant may either provide such a
   label, an example of which must be included in the application for equipment authorization, or, must
   provide adequate instructions along with the module which explain this requirement. In the latter case, a
   copy of these instructions must be included in the application for equipment authorization.

    The WiEM9210bg module will have the FCC/IC ID numbers silk-screened in contrasting ink on the
    bottom of the PCB in the corner. See following silkscreen image of PCB, the FCC/IC text is in 0.025”
    text.


                Digi International
                11001 Bren Road East
                Minnetonka, MN 55343
                952-912-3444 tel
                952-912-4991 central fax

7. The modular transmitter must comply with any specific rule or operating requirements applicable to the
   transmitter and the manufacturer must provide adequate instructions along with the module to explain
   any such requirements. A copy of these instructions must be included in the application for equipment
   authorization. For example, there are very strict operational and timing requirements that must be met
   before a transmitter is authorized for operation under FCC Section 15.231 and Industry Canada
   specifications. For instance, data transmission is prohibited, except for operation under FCC Section
   15.231(e), in which case there are separate field strength level and timing requirements. Compliance
   with these requirements must be assured.

    There are no operational requirements for 15.247.

8. The modular transmitter must comply with any applicable RF exposure requirements. For example,
   FCC Rules in Sections 2.1091, 2.1093 and specific Sections of Part 15, including 15.319(i), 15.407(f),
   15.253(f) and 15.255(g), require that Unlicensed PCS, UNII and millimeter wave devices perform
   routine environmental evaluation for RF Exposure to demonstrate compliance. In addition, spread
   spectrum transmitters operating under Section 15.247 are required to address RF Exposure
   compliance in accordance with Section 15.247(b)(4). Modular transmitters approved under other
   Sections of FCC Part 15, when necessary, may also need to address certain RF Exposure concerns,
   typically by providing specific installation and operating instructions for users, installers and other
   interested parties to ensure compliance. Refer to Industry Canada RSS-GEN Section 7.1.1 and 7.1.2
   for Industry Canada requirements.

    The WiEM9210bg module complies with the RF exposure limits for humans as called out in RSS-102. It
    is exempt from RF evaluation based on its operating frequency of 2.4GHz and effective radiated power
    less than the 3W requirement for a mobile device (>20 cm separation) operating at 2.4GHz.



Document Created: 2008-08-26 14:45:59
Document Modified: 2008-08-26 14:45:59

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