13_Cover letter 2 for Wi-Fi at 5GHz V6

FCC ID: RI7WL865E4

Cover Letter(s)

Download: PDF
FCCID_4491021

Date: 2019-10-09

to:                                             from:

      Regulatory Certification Body                Manufacturer:
      DEKRA Testing and Certification, S.A.U.      Telit Communications S.p.A.,
      Parque Tecnológico de Andalucía              Via Stazione di Prosecco, 5/B. 34010
      C/ Severo Ochoa 2 & 6                        Sgonico, Trieste (Italy),
      29590 Campanillas
      Málaga, España


Related to product:

                         Type of equipment:             Radio module

                         Brand name:                            Telit

                         FCC ID:                        RI7WL865E4

                         IC:                        5131A-WL865E4

      We hereby declare that this device is programmed to operate only in the following
      frequencies:

5GHz Band,

               •   Frequency center Range 5.170 – 5.735 GHz
                       o Channels 36-165 (BW 20 MHz)
                              ▪ 36,40,44,48,52,56,60,64,100,104,108,112,116,132,136,140


Operation modes, DFS and TPC

DFS Operational Mode: Slave without Radar detection.

TPC Function: Not Supported



In the frequency band below, this product can only be used as a client, since the RF chip
has no hardware radar detection capability and uses passive scanning in these channels.

      • 5250-5350 MHz

      • 5470 – 5725 MHz

Whereas the product can operate as both client and master in the following frequency
bands

      • 5170 – 5250MHz


Software security description per KDB 594280 D02:

                                                     RF parameters are part of OTP and
                                                     programmed in production line.
             1. Describe how any                     This cannot be over-written in the
             software/firmware updates for           field by a firmware upgrade.
             elements than can affect the
             device’s RF parameters will be          Firmware is downloaded through
             obtained, downloaded, validated         HTTPS (secured tunnel) from the
             and installed. For software that is     server and is protected with the
             accessed through manufacturer’s         Hash to make sure the firmware is
             website or device’s management          not tampered.
             system, describe the different levels
             of security as appropriate.             A secured boot, would further
                                                     validate the firmware image
                                                     before execution.

            2. Describe the RF parameters that
 General    are modified by any
Description software/firmware without any
            hardware changes. Are these              No RF parameters are modified by
            parameters in some way limited           software without hardware
            such that any other                      changes.
            software/firmware changes will not
            allow the device to exceed the
            authorized RF characteristics?

                                                     Firmware is downloaded through
             3. Describe in detail the               HTTPS (secured tunnel) from the
             authentication protocols that are in    server and is protected with the
             place to ensure that the source of      Hash to make sure the firmware is
             the RF-related software/firmware is     not tampered.
             valid. Describe in detail how the RF-
             related software is protected against   A secured-boot, would further
             modification.                           validate the firmware image
                                                     before execution.


              4. Describe in detail any encryption
                                                       Hashing mechanism is used to
              methods used to support the use of
                                                       ensure that the firmware is not
              legitimate RF-related
                                                       tampered with.
              software/firmware.

              5. For a device that can be
              configured as a master and client        Firmware restricts users from
              (with active or passive scanning),       configuring the device to act as
              explain how the device ensures           master in restricted bands and the
              compliance for each mode? In             same applies for active scanning in
              particular if the device acts as         client mode.
              master in some band of operation
              and client in another; how is            Also user doesn’t have option to
              compliance ensured in each band of       overwrite these configuration.
              operation?



              1. Explain if any third parties have
              the capability to operate a U.S.-sold
              device on any other regulatory
                                                     Not applicable, since the module
              domain, frequencies, or in any
                                                     isn’t an end product.
              manner that may allow the device to
              operate in violation of the device’s
              authorization if activated in the U.S.

              2. Describe, if the device permits
              third-party software or firmware
              installation, what mechanisms are
Third-Party
              provided by the manufacturer to
  Access
              permit integration of such functions
  Control
              while ensuring that the RF
              parameters of the device cannot be
              operated outside its authorization
                                                       Not applicable
              for operation in the U.S. In the
              description include what controls
              and/or agreements are in place with
              providers of third-party functionality
              to ensure the devices’ underlying RF
              parameters are unchanged and how
              the manufacturer verifies the
              functionality.


               3. For Certified Transmitter modular
               devices, describe how the module
               grantee ensures that host
               manufacturers fully comply with
               these software security
                                                      The module firmware doesn’t
               requirements for U-NII devices. If
                                                      expose any functionality that can
               the module is controlled through
                                                      alter the RF parameters to the
               driver software loaded in the host,
                                                      host.
               describe how the drivers are
               controlled and managed such that
               the modular transmitter RF
               parameters are not modified
               outside the grant of authorization.

Sincerely,




Title:  VP Application Engineer
Company: Telit Communications S.p.A.
Telephone: 1-919-415-1517
e-mail: Ken.Bednasz@telit.com



Document Created: 2019-10-09 16:08:56
Document Modified: 2019-10-09 16:08:56

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