test report

FCC ID: SWX-LTU5S

Test Report

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FCCID_4372537

313 West 12800 South, Suite 311 Draper, UT 84020 (801) 260-4040 Test Report Certification FCC ID SWX-LTU5S Equipment Under Test LTU-LR Test Report Serial No V048427_01 May 8, 14, 22, and 23, 2019, June 3 – 6, 13, and 19, 2019, and July 2, 3, Dates of Test and 8, 2019 Report Issue Date July 10, 2019 Test Specifications: Applicant: FCC Part 15, Subpart C Ubiquiti Networks, Inc. 685 Third Avenue, 27th Floor New York, NY 10017 U.S.A.

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 Certification of Engineering Report This report has been prepared by VPI Laboratories, Inc. to document compliance of the device described below with the requirements of Federal Communications Commission (FCC) Part 15, Subpart C. This report may be reproduced in full. Partial reproduction of this report may only be made with the written consent of the laboratory. The results in this report apply only to the sample tested. Applicant Ubiquiti Networks, Inc. Manufacturer Ubiquiti Networks, Inc. Brand Name LTU Model Number LTU-LR FCC ID SWX-LTU5S On this 9th day of July 2019, I, individually and for VPI Laboratories, Inc., certify that the statements made in this engineering report are true, complete, and correct to the best of my knowledge, and are made in good faith. Although NVLAP has accredited the VPI Laboratories, Inc. EMC testing facilities, this report must not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the federal government. VPI Laboratories, Inc. Tested by: Norman P. Hansen Reviewed by: Benjamin N. Antczak V048427_02_LTU-LR_FCC_C_BLE Page 2 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 Revision History Revision Description Date 01 Original Report Release July 9, 2019 Moved Photographs to External Appendix for 02 July, 24, 2019 Confidentiality V048427_02_LTU-LR_FCC_C_BLE Page 3 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 Table of Contents 1 Client Information................................................................................................................................. 5 1.1 Applicant ....................................................................................................................................... 5 1.2 Manufacturer ................................................................................................................................. 5 2 Equipment Under Test (EUT)............................................................................................................... 6 2.1 Identification of EUT .................................................................................................................... 6 2.2 Description of EUT ....................................................................................................................... 6 2.3 EUT and Support Equipment ........................................................................................................ 6 2.4 Interface Ports on EUT ................................................................................................................. 7 2.5 Modification Incorporated/Special Accessories on EUT .............................................................. 7 2.6 Deviation from Test Standard ....................................................................................................... 7 3 Test Specification, Methods and Procedures ........................................................................................ 8 3.1 Test Specification.......................................................................................................................... 8 3.2 Methods & Procedures .................................................................................................................. 8 3.3 Test Procedure ............................................................................................................................ 12 4 Operation of EUT During Testing ...................................................................................................... 13 4.1 Operating Environment ............................................................................................................... 13 4.2 Operating Modes ......................................................................................................................... 13 4.3 EUT Exercise Software............................................................................................................... 13 5 Summary of Test Results .................................................................................................................... 14 5.1 FCC Part 15, Subpart C .............................................................................................................. 14 5.2 Result .......................................................................................................................................... 14 6 Measurements, Examinations and Derived Results ............................................................................ 15 6.1 General Comments...................................................................................................................... 15 6.2 Test Results ................................................................................................................................. 15 7 Test Procedures and Test Equipment .................................................................................................. 26 7.1 Conducted Emissions at Mains Ports .......................................................................................... 26 7.2 Radiated Emissions ..................................................................................................................... 27 7.3 Equipment Calibration ................................................................................................................ 29 7.4 Measurement Uncertainty ........................................................................................................... 29 8 Photographs ........................................................................................................................................ 30 V048427_02_LTU-LR_FCC_C_BLE Page 4 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 1 Client Information 1.1 Applicant Ubiquiti Networks, Inc. 685 Third Avenue, 27th Floor Company Name New York, NY 10017 U.S.A. Contact Name Mark Feil Title Compliance Manager 1.2 Manufacturer Ubiquiti Networks, Inc. 685 Third Avenue, 27th Floor Company Name New York, NY 10017 U.S.A. Contact Name Mark Feil Title Compliance Manager V048427_02_LTU-LR_FCC_C_BLE Page 5 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 2 Equipment Under Test (EUT) 2.1 Identification of EUT Brand Name LTU Model Number LTU-LR Serial Number None Dimensions (cm) 37 diameter x 25 2.2 Description of EUT The LTU-LR is a point to point transceiver operating in the UNII-1 and UNII-3 frequency bands. A Bluetooth LE transceiver is included for device management. An Ethernet port is used for data transfer and to provide power using a POE-24V-5X-HD POE supply. The Bluetooth LE transceiver used 40 channels in the 2400 – 2483.5 MHz ISM frequency band. It uses an inverted F trace antenna with a maximum gain of 2 dBi. This report covers the Bluetooth LE circuitry of the device subject to FCC Part 15, Subpart C. The circuitry of the device subject to FCC Subpart B was found to be compliant and is covered in VPI Laboratories, Inc. report V048426. The UNII-1 and UNII-3 transceiver is to be covered in separate reports. 2.3 EUT and Support Equipment The EUT and support equipment used during the test are listed below. Brand Name Name of Interface Ports / Model Number Description Interface Cables Serial Number BN: LTU MN: LTU-LR (Note 1) Point to Point Transceiver See Section 2.4 SN: None BN: Ubiquiti MN: POE-24V-5X-HD See Section 2.4 POE Supply (Note 1) SN: None BN: Dell Ethernet/Shielded Cat 5e cable (Note MN: XPS Computer 2) SN: None Notes: (1) EUT (2) Interface port connected to EUT (See Section 2.4) The support equipment listed above was not modified in order to achieve compliance with this standard. V048427_02_LTU-LR_FCC_C_BLE Page 6 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 2.4 Interface Ports on EUT 2.4.1 Interface ports on the LTU-LR No. of Ports Fitted Cable Description/Length Name of Ports to EUT POE/Data 1 Shielded Cat 5e cable/8 meters 2.4.2 Interface ports on the POE-24V-5X-HD Supply No. of Ports Fitted Cable Description/Length Name of Ports to EUT AC 1 3 conductor power cord/80 cm Data 1 Shielded Cat 5e cable/1 meters POE/Data 1 Shielded Cat 5e cable/8 meters 2.5 Modification Incorporated/Special Accessories on EUT The following modifications were made to the EUT by the Client during testing to comply with the specification. This report is not complete without an accompanying signed attestation, that the product will have all of the documented modifications incorporated into the product when manufactured and placed on the market. • Metal RF shields were placed over the UNII-1 and UNII-3 transceiver circuitry. The RF shields had RF absorber material placed inside between the components and the shield. Copper tape was placed on the shields, connecting them together and was soldered to the PCB ground plane. See Photographs 13 - 18. 2.6 Deviation from Test Standard There were no deviations from the test specification. V048427_02_LTU-LR_FCC_C_BLE Page 7 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 3 Test Specification, Methods and Procedures 3.1 Test Specification FCC PART 15, Subpart C (47 CFR 15) 15.203, 15.207, and 15.247 Title Limits and methods of measurement of radio interference characteristics of radio frequency devices. Purpose of Test The tests were performed to demonstrate initial compliance 3.2 Methods & Procedures 3.2.1 §15.203 Antenna Requirement An intentional radiator shall be designed to ensure that no antenna other than that furnished by the responsible party shall be used with the device. The use of a permanently attached antenna or of an antenna that uses a unique coupling to the intentional radiator shall be considered sufficient to comply with the provisions of this Section. The manufacturer may design the unit so that a broken antenna can be replaced by the user, but the use of a standard antenna jack or electrical connector is prohibited. This requirement does not apply to carrier current devices or to devices operated under the provisions of Sections 15.211, 15.213, 15.217, 15.219, or 15.221. Further, this requirement does not apply to intentional radiators that must be professionally installed, such as perimeter protection systems and some field disturbance sensors, or to other intentional radiators which, in accordance with Section 15.31(d), must be measured at the installation site. However, the installer shall be responsible for ensuring that the proper antenna is employed so that the limits in this Part are not exceeded. 3.2.2 §15.207 Conducted Limits (a) Except as shown in paragraphs (b) and (c) of this section, for an intentional radiator that is designed to be connected to the public utility (AC) power line, the radio frequency voltage that is conducted back onto the AC power line on any frequency or frequencies, within the band 150 kHz to 30 MHz, shall not exceed the limits in the following table, as measured using a 50 μH/50 ohms line impedance stabilization network (LISN). Compliance with the provisions of this paragraph shall be based on the measurement of the radio frequency voltage between each power line and ground at the power terminal. The lower limit applies at the boundary between the frequency ranges. Limit Frequency range (dBV) (MHz) Quasi-peak Average 0.15 to 0.50* 66 to 56* 56 to 46* 0.50 to 5 56 46 5 to 30 60 50 *Decreases with the logarithm of the frequency. Table 1: Limits for conducted emissions at mains ports of Class B ITE. 3.2.3 §15.247 Operation within the bands 902 – 928 MHz, 2400 – 2483.5 MHz, and 5725 – 5850 MHz a) Operation under the provisions of this Section is limited to frequency hopping and digitally modulated intentional radiators that comply with the following provisions. V048427_02_LTU-LR_FCC_C_BLE Page 8 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 1) Frequency hopping systems shall have hopping channel carrier frequencies separated by a minimum of 25 kHz or the 20 dB bandwidth of the hopping channel, whichever is greater. Alternatively, frequency hopping systems operating in the 2400 – 2483.5 MHz band may have hopping channel carrier frequencies that are separated by 25 kHz or two-thirds of the 20 dB bandwidth of the hopping channel, whichever is greater, provided the systems operate with an output power no greater than 125 mW. The system shall hop to channel frequencies that are selected at the system hopping rate from a pseudorandomly ordered list of hopping frequencies. Each frequency must be used equally on the average by each transmitter. The system receivers shall have input bandwidths that match the hopping channel bandwidths of their corresponding transmitters and shall shift frequencies in synchronization with the transmitted signals. i. For frequency hopping systems operating in the 902-928 MHz band: if the 20 dB bandwidth of the hopping channel is less than 250 kHz, the system shall use at least 50 hopping frequencies and the average time of occupancy on any frequency shall not be greater than 0.4 seconds within a 20 second period; if the 20 dB bandwidth of the hopping channel is 250 kHz or greater, the system shall use at least 25 hopping frequencies and the average time of occupancy on any frequency shall not be greater than 0.4 seconds within a 10 second period. The maximum allowed 20 dB bandwidth of the hopping channel is 500 kHz. ii. Frequency hopping systems operating in the 5725-5850 MHz band shall use at least 75 hopping frequencies. The maximum 20 dB bandwidth of the hopping channel is 1 MHz. The average time of occupancy on any frequency shall not be greater than 0.4 seconds within a 30 second period. iii. Frequency hopping systems in the 2400-2483.5 MHz band shall use at least 15 non-overlapping channels. The average time of occupancy on any channel shall not be greater than 0.4 seconds within a period of 0.4 seconds multiplied by the number of hopping channels employed. Frequency hopping systems may avoid or suppress transmissions on a particular hopping frequency provided that a minimum of 15 non-overlapping channels are used. 2) Systems using digital modulation techniques may operate in the 902 - 928 MHz, 2400 - 2483.5 MHz, and 5725 - 5850 MHz bands. The minimum 6 dB bandwidth shall be at least 500 kHz. b) The maximum peak output power of the intentional radiator shall not exceed the following: 1) For frequency hopping systems operating in the 2400-2483.5 MHz band employing at least 75 non-overlapping hopping channels, and all frequency hopping systems in the 5725-5850 MHz band: 1 watt. For all other frequency hopping systems in the 2400-2483.5 MHz band: 0.125 watts. 2) For frequency hopping systems operating in the 902-928 MHz band: 1 watt for systems employing at least 50 hopping channels; and, 0.25 watts for systems employing less than 50 hopping channels, but at least 25 hopping channels, as permitted under paragraph (a)(1)(i) of this section. V048427_02_LTU-LR_FCC_C_BLE Page 9 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 3) For systems using digital modulation in the 902-928 MHz, 2400-2483.5 MHz, and 5725 – 5850 MHz bands: 1 watt. As an alternative to a peak power measurement, compliance with the Conducted Output Power is defined as the total transmit power delivered to all antennas and antenna elements averaged across all symbols in the signaling alphabet when the transmitter is operating at its maximum power control level. Power must be summed across all antennas and antenna elements. The average must not include any time intervals during which the transmitter is off or is transmitting at a reduced power level. If multiple modes of operation are possible (e.g., alternative modulation methods), the maximum conducted output power is the highest total transmit power occurring in any mode. 4) The conducted output power limit specified in paragraph (b) of this section is based on the use of antennas with directional gains that do not exceed 6 dBi. Except as shown in paragraph (c) of this section, if transmitting antennas of directional gain greater than 6 dBi are used, the conducted power from the intentional radiator shall be reduced below the stated values in paragraphs (b)(1), (b)(2), and (b)(3) of this section, as appropriate, by the amount in dB that the directional gain of the antenna exceeds 6 dBi. c) Operation with directional antenna gains greater than 6 dBi. 1) Fixed point-to-point operation: i. Systems operating in the 2400-2483.5 MHz band that are used exclusively for fixed, point-to-point operations may employ transmitting antennas with directional gain greater than 6 dBi provided the maximum peak output power of the intentional radiator is reduced by 1 dB for every 3 dB that the directional gain of the antenna exceeds 6 dBi. ii. Systems operating in the 5725-5850 MHz band that are used exclusively for fixed, point-to-point operations may employ transmitting antennas with directional gain greater than 6 dBi without any corresponding reduction in transmitter peak output power. iii. Fixed, point-to-point operation, as used in paragraphs (b)(4)(i) and (b)(4)(ii) of this section, excludes the use of point-to-multipoint systems, omnidirectional applications, and multiple co-located intentional radiators transmitting the same information. The operator of the spread spectrum or digitally modulated intentional radiator or, if the equipment is professionally installed, the installer is responsible for ensuring that the system is used exclusively for fixed, point-to-point operations. The instruction manual furnished with the intentional radiator shall contain language in the installation instructions informing the operator and the installer of this responsibility. 2) In addition to the provisions in paragraphs (b)(1), (b)(3), (b)(4) and (c)(1)(i) of this section, transmitters operating in the 2400-2483.5 MHz band that emit multiple directional beams, simultaneously or sequentially, for the purpose of directing signals to individual receivers or to groups of receivers provided the emissions comply with the following: i. Different information must be transmitted to each receiver. V048427_02_LTU-LR_FCC_C_BLE Page 10 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 ii. If the transmitter employs an antenna system that emits multiple directional beams but does not emit multiple directional beams simultaneously, the total output power conducted to the array or arrays that comprise the device, i.e., the sum of the power supplied to all antennas, antenna elements, staves, etc. and summed across all carriers or frequency channels, shall not exceed the limit specified in paragraph (b)(1) or (b)(3) of this section, as applicable. However, the total conducted output power shall be reduced by 1 dB below the specified limits for each 3 dB that the directional gain of the antenna /antenna array exceeds 6 dBi. The directional antenna gain shall be computed as follows: A. The directional gain shall be calculated as the sum of 10 log (number of array elements or staves) plus the directional gain of the element or stave having the highest gain. B. A lower value for the directional gain than that calculated in paragraph (c)(2)(ii)(A) of this section will be accepted if sufficient evidence is presented, e.g., due to shading of the array or coherence loss in the beamforming. iii. If a transmitter employs an antenna that operates simultaneously on multiple directional beams using the same or different frequency channels, the power supplied to each emission beam is subject to the power limit specified in paragraph (c)(2)(ii) of this section. If transmitted beams overlap, the power shall be reduced to ensure that their aggregate power does not exceed the limit specified in paragraph (c)(2)(ii) of this section. In addition, the aggregate power transmitted simultaneously on all beams shall not exceed the limit specified in paragraph (c)(2)(ii) of this section by more than 8 dB. iv. Transmitters that emit a single directional beam shall operate under the provisions of paragraph (c)(1) of this section. d) In any 100 kHz bandwidth outside the frequency band in which the spread spectrum or digitally modulated intentional radiator is operating, the radio frequency power that is produced by the intentional radiator shall be at least 20 dB below that in the 100 kHz bandwidth within the band that contains the highest level of the desired power, based on either an RF conducted or a radiated measurement, provided the transmitter demonstrates compliance with the peak conducted power limits. If the transmitter complies with the conducted power limits based on the use of RMS averaging over a time interval, as permitted under paragraph (b)(3) of this section, the attenuation required under this paragraph shall be 30 dB instead of 20 dB. Attenuation below the general limits specified in Section 15.209(a) is not required. In addition, radiated emissions which fall in the restricted bands, as defined in Section 15.205(a), must also comply with the radiated emission limits specified in Section 15.209(a) (see Section 15.205(c)). e) For digitally modulated systems, the power spectral density conducted from the intentional radiator to the antenna shall not be greater than 8 dBm in any 3 kHz band during any time interval of continuous transmission. This power spectral density shall be determined in accordance with the provisions of paragraph (b) of this section. The same method of determining the conducted output power shall be used to determine the power spectral density. f) For the purposes of this section, hybrid systems are those that employ a combination of both frequency hopping and digital modulation techniques. The frequency hopping operation of the hybrid system, with the direct sequence or digital modulation operation turned off, shall have an V048427_02_LTU-LR_FCC_C_BLE Page 11 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 average time of occupancy on any frequency not to exceed 0.4 seconds within a time period in seconds equal to the number of hopping frequencies employed multiplied by 0.4. The digital modulation operation of the hybrid system, with the frequency hopping turned off, shall comply with the power density requirements of paragraph (d) of this section. g) Frequency hopping spread spectrum systems are not required to employ all available hopping channels during each transmission. However, the system, consisting of both the transmitter and the receiver, must be designed to comply with all of the regulations in this section should the transmitter be presented with a continuous data (or information) stream. In addition, a system employing short transmission bursts must comply with the definition of a frequency hopping system and must distribute its transmissions over the minimum number of hopping channels specified in this section. h) The incorporation of intelligence within a frequency hopping spread spectrum system that permits the system to recognize other users within the spectrum band so that it individually and independently chooses and adapts its hopsets to avoid hopping on occupied channels is permitted. The coordination of frequency hopping systems in any other manner for the express purpose of avoiding the simultaneous occupancy of individual hopping frequencies by multiple transmitters is not permitted. i) Systems operating under the provisions of this section shall be operated in a manner that ensures that the public is not exposed to radio frequency energy levels in excess of the Commission's guidelines. See § 1.1307(b)(1) of this Chapter. Note: Spread spectrum systems are sharing these bands on a noninterference basis with systems supporting critical Government requirements that have been allocated the usage of these bands, secondary only to ISM equipment operated under the provisions of Part 18 of this Chapter. Many of these Government systems are airborne radiolocation systems that emit a high EIRP which can cause interference to other users. Also, investigations of the effect of spread spectrum interference to U. S. Government operations in the 902-928 MHz band may require a future decrease in the power limits allowed for spread spectrum operation. 3.3 Test Procedure VPI Laboratories, Inc. is accredited by National Voluntary Laboratory Accreditation Program (NVLAP); NVLAP Lab Code: 100272-0, which is effective until September 30, 2019. VPI Laboratories, Inc. carries FCC Accreditation Designation Number US5263. VPI Laboratories main office is located at 313 W 12800 S, Suite 311, Draper, UT 84020. The testing was performed according to the procedures in ANSI C63.10- 2013, KDB 558074, and 47 CFR Part 15. Testing was performed at the VPI Laboratories, Inc. Wanship Upper Open Area Test Site, located at 29145 Old Lincoln Highway, Wanship, UT. This location is listed on NVLAP scope under the lines for C63.4 and C63.10. V048427_02_LTU-LR_FCC_C_BLE Page 12 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 4 Operation of EUT During Testing 4.1 Operating Environment Power Supply 120 VAC AC Mains Frequency 60 Hz 4.2 Operating Modes The transmitter was tested while the Bluetooth LE transceiver was in a constant transmit mode at the upper, middle, and lower channels. The UNII band transceiver was active while testing the Bluetooth LE transceiver to assess any transmitter interactions. The AC mains voltage to the AC adapter was varied as required by §15.31(e) with no change seen in the voltage supplied to the transmitter or in transmitter characteristics. 4.3 EUT Exercise Software Ubiquiti test software and firmware were used to exercise the EUT. V048427_02_LTU-LR_FCC_C_BLE Page 13 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 5 Summary of Test Results 5.1 FCC Part 15, Subpart C 5.1.1 Summary of Tests Frequency Section Environmental Phenomena Range Result (MHz) Structural 15.203 Antenna Requirements Complied requirement 15.207 Conducted Disturbance at Mains Ports 0.15 to 30 Complied 15.247(a) Bandwidth Requirement 2400 to 2483.5 Complied 15.247(b) Peak Output Power 2400 to 2483.5 Complied 15.247(d) Radiated Spurious Emissions 0.009 - 30000 Complied 15.247(e) Peak Power Spectral Density 2400 to 2483.5 Complied 5.2 Result In the configuration tested, the EUT complied with the requirements of the specification. V048427_02_LTU-LR_FCC_C_BLE Page 14 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 6 Measurements, Examinations and Derived Results 6.1 General Comments This section contains the test results only. Details of the test methods used and a list of the test equipment used during the measurements can be found in Section 7 of this report. 6.2 Test Results 6.2.1 §15.203 Antenna Requirements The EUT uses a trace on the PCB as an inverted F antenna with a maximum gain of 2 dBi. Result The EUT complied with the specification. 6.2.2 Conducted Emissions at Mains Ports Data (Hot Lead) Measured Margin Frequency Limit AC Mains Lead Detector Level (dB) (MHz) (dBV) (dBV) 0.17 Hot Lead Quasi-Peak (Note 2) 56.3 64.8 -8.5 0.17 Hot Lead Average (Note 2) 37.4 54.8 -17.4 0.19 Hot Lead Quasi-Peak (Note 2) 53.6 63.9 -10.3 0.19 Hot Lead Average (Note 2) 36.4 53.9 -17.5 0.25 Hot Lead Quasi-Peak (Note 1) 44.3 51.7 -7.4 0.64 Hot Lead Quasi-Peak (Note 2) 46.9 56.0 -9.1 0.64 Hot Lead Average (Note 2) 40.9 46.0 -5.1 1.09 Hot Lead Peak (Note 1) 40.3 46.0 -5.7 4.73 Hot Lead Peak (Note 1) 40.8 46.0 -5.2 0.16 Neutral Lead Quasi-Peak (Note 1) 47.7 55.5 -7.8 0.19 Neutral Lead Quasi-Peak (Note 2) 52.8 64.1 -11.3 0.19 Neutral Lead Average (Note 2) 35.2 54.1 -18.9 0.22 Neutral Lead Quasi-Peak (Note 1) 47.4 52.9 -5.5 0.26 Neutral Lead Peak (Note 1) 45.2 51.5 -6.3 0.64 Neutral Lead Quasi-Peak (Note 2) 48.0 56.0 -8.0 0.64 Neutral Lead Average (Note 2) 41.7 46.0 -4.3 1.66 Neutral Lead Peak (Note 1) 39.7 46.0 -6.3 Note 1: The reference detector used for the measurements was Quasi-Peak or Peak and the data was compared to the average limit; therefore, the EUT was deemed to meet both the average and quasi-peak limits. Note 2: The reference detector used for the measurements was quasi-peak and average and the data was compared to the respective limits. Result The EUT complied with the specification limit by a margin of 4.3 dB. V048427_02_LTU-LR_FCC_C_BLE Page 15 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 6.2.3 §15.247(a)(2) Emissions Bandwidth Frequency Emissions 6 dB bandwidth (MHz) (kHz) 2402 651 2442 669 2480 672 Result In the configuration tested, the 6 dB bandwidth was greater than 500 kHz; therefore, the EUT complied with the requirements of the specification (see spectrum analyzer plots below). dBuV Peak 120 110 1 100 2-1 3-2 90 80 70 60 50 40 30 20 Start: 2.4005 GHz Stop: 2.4035 GHz Res BW: 100 kHz Vid BW: 300 kHz Sweep: 50.00 ms 5/14/2019 9:47:06 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4020 GHz 97.55 dBuV 2-1 Peak -348.0000 kHz -5.99 dB 3-2 Peak 651.0000 kHz -0.00 dB Graph 1: Lowest Channel Bandwidth V048427_02_LTU-LR_FCC_C_BLE Page 16 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 dBuV Peak 120 110 1 2-1 3-2 100 90 80 70 60 50 40 30 20 Start: 2.4405 GHz Stop: 2.4435 GHz Res BW: 100 kHz Vid BW: 300 kHz Sweep: 50.00 ms 5/14/2019 10:16:53 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4420 GHz 101.83 dBuV 2-1 Peak -363.0000 kHz -6.11 dB 3-2 Peak 669.0000 kHz 0.14 dB Graph 2: Middle Channel Bandwidth dBuV Peak 120 110 1 2-1 3-2 100 90 80 70 60 50 40 30 20 Start: 2.4785 GHz Stop: 2.4815 GHz Res BW: 100 kHz Vid BW: 300 kHz Sweep: 50.00 ms 5/14/2019 10:07:30 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4800 GHz 102.33 dBuV 2-1 Peak -357.0000 kHz -6.01 dB 3-2 Peak 672.0000 kHz -0.27 dB Graph 3: Highest Channel Bandwidth V048427_02_LTU-LR_FCC_C_BLE Page 17 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 6.2.4 §15.247(b)(3) Peak Output Power The maximum peak RF power measured using radiated methods as an integral antenna with no provision for doing a direct connection at the antenna port provided. The field strength measurements were converted to EIRP using the equation 1.1 of FCC KDB 412172. The antenna gain was then subtracted from the calculated EIRP to give a calculated conducted power and compared to the limit of 1 Watt. The antenna has a maximum gain of 2.0 dBi. Frequency Measured EIRP Calculated Calculated Field Strength EIRP (MHz) (mW) Conducted Conducted (dBµV/m) (dBm) Power (dBm) Power (W) 2402 98.01 1.897 2.78 0.78 0.0012 2442 102.05 4.810 6.82 4.82 0.0030 2480 102.63 5.497 7.40 5.40 0.0035 Result In the configuration tested, the RF peak output power was less than 1 Watt; therefore, the EUT complied with the requirements of the specification (see spectrum analyzer plots below). dBuV Peak 120 110 1 100 90 80 70 60 50 40 30 20 Start: 2.3975 GHz Stop: 2.4065 GHz Res BW: 3 MHz Vid BW: 10 MHz Sweep: 5.00 ms 5/14/2019 9:43:12 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4019 GHz 98.01 dBuV Graph 4: Lowest Channel Output Power Plot V048427_02_LTU-LR_FCC_C_BLE Page 18 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 dBuV Peak 120 110 1 100 90 80 70 60 50 40 30 20 Start: 2.4375 GHz Stop: 2.4465 GHz Res BW: 3 MHz Vid BW: 10 MHz Sweep: 5.00 ms 5/14/2019 10:19:49 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4420 GHz 102.05 dBuV Graph 5: Middle Channel Output Power dBuV Peak 120 110 1 100 90 80 70 60 50 40 30 20 Start: 2.4755 GHz Stop: 2.4845 GHz Res BW: 3 MHz Vid BW: 10 MHz Sweep: 5.00 ms 5/14/2019 10:10:02 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4798 GHz 102.63 dBuV Graph 6: Highest Channel Output Power Plot V048427_02_LTU-LR_FCC_C_BLE Page 19 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 6.2.5 §15.247(d) Spurious Emissions The frequency range from the lowest frequency generated or used in the device to the tenth harmonic of the highest fundamental emission was investigated to measure any radiated emissions. The emissions in the restricted bands of §15.205 must meet the limits specified in §15.209. Emissions outside the restricted bands must be attenuated 20 dB from the highest measured fundamental emission using a resolution bandwidth of 100 kHz or for this device, 82.33 dBµV/m (102.33 – 20 = 82.33). Tabular data for each of the spurious emissions is shown below. Plots of the band edges are also shown. Note that all emissions were compared to the tighter limits of µ15.209. Result All emissions, including those outside the restricted bands, met the limits specified in §15.209; therefore, the EUT complies with the specification. Receiver Correction Field Margin Frequency Antenna Limit Detector Reading Factor Strength (dB) (MHz) Polarity (dBV/m) (dBV) (dB) (dBV/m) 4804.0 Peak Vertical 4.7 38.7 43.4 74.0 -30.6 4804.0 Average Vertical -3.3 38.7 35.4 54.0 -18.6 4804.0 Peak Horizontal 5.4 38.7 44.1 74.0 -29.9 4804.0 Average Horizontal -2.7 38.7 36.0 54.0 -18.0 7206.0 Peak Vertical 5.7 42.8 48.5 74.0 -25.5 7206.0 Average Vertical -3.2 42.8 39.6 54.0 -14.4 7206.0 Peak Horizontal 5.0 42.8 47.8 74.0 -26.2 7206.0 Average Horizontal -5.1 42.8 37.7 54.0 -16.3 9608.0 Peak Vertical 4.8 45.9 50.7 74.0 -23.3 9608.0 Average Vertical -7.3 45.9 38.6 54.0 -15.4 9608.0 Peak Horizontal 4.2 45.9 50.1 74.0 -23.9 9608.0 Average Horizontal -7.2 45.9 38.7 54.0 -15.3 12010.0 Peak Vertical 9.7 48.3 58.0 74.0 -16.0 12010.0 Average Vertical -0.5 48.3 47.8 54.0 -6.2 12010.0 Peak Horizontal 5.1 48.3 53.4 74.0 -20.6 12010.0 Average Horizontal -4.5 48.3 43.8 54.0 -10.2 14412.0 Peak Vertical -0.2 51.9 51.7 74.0 -22.3 14412.0 Average Vertical -10.8 51.9 41.1 54.0 -12.9 14412.0 Peak Horizontal 0.8 51.9 52.7 74.0 -21.3 14412.0 Average Horizontal -10.8 51.9 41.1 54.0 -12.9 Table 2: Transmitting at the Lowest Frequency V048427_02_LTU-LR_FCC_C_BLE Page 20 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 Receiver Correction Field Margin Frequency Antenna Limit Detector Reading Factor Strength (dB) (MHz) Polarity (dBV/m) (dBV) (dB) (dBV/m) 4884.0 Peak Vertical 8.1 38.9 47.0 74.0 -27.0 4884.0 Average Vertical 0.7 38.9 39.6 54.0 -14.4 4884.0 Peak Horizontal 7.1 38.9 46.0 74.0 -28.0 4884.0 Average Horizontal -0.6 38.9 38.3 54.0 -15.7 7326.0 Peak Vertical 7.7 43.2 50.9 74.0 -23.1 7326.0 Average Vertical 1.2 43.2 44.4 54.0 -9.6 7326.0 Peak Horizontal 6.4 43.2 49.6 74.0 -24.4 7326.0 Average Horizontal -0.3 43.2 42.9 54.0 -11.1 9768.0 Peak Vertical 5.3 46.0 51.3 74.0 -22.7 9768.0 Average Vertical -4.1 46.0 41.9 54.0 -12.1 9768.0 Peak Horizontal 5.0 46.0 51.0 74.0 -23.0 9768.0 Average Horizontal -5.3 46.0 40.7 54.0 -13.3 12210.0 Peak Vertical 17.3 48.2 65.5 74.0 -8.5 12210.0 Average Vertical 5.7 48.2 53.9 54.0 -0.1 12210.0 Peak Horizontal 8.5 48.2 56.7 74.0 -17.3 12210.0 Average Horizontal 0.5 48.2 48.7 54.0 -5.3 14652.0 Peak Vertical 2.6 51.7 54.3 74.0 -19.7 14652.0 Average Vertical -9.4 51.7 42.3 54.0 -11.7 14652.0 Peak Horizontal 2.2 51.7 53.9 74.0 -20.1 14652.0 Average Horizontal -9.5 51.7 42.2 54.0 -11.8 Table 3: Transmitting at the Middle Frequency Receiver Correction Field Margin Frequency Antenna Limit Detector Reading Factor Strength (dB) (MHz) Polarity (dBV/m) (dBV) (dB) (dBV/m) 4960.0 Peak Vertical 5.6 39.1 44.7 74.0 -29.3 4960.0 Average Vertical -2.6 39.1 36.5 54.0 -17.5 4960.0 Peak Horizontal 5.9 39.1 45.0 74.0 -29.0 4960.0 Average Horizontal -2.4 39.1 36.7 54.0 -17.3 7440.0 Peak Vertical 6.3 43.6 49.9 74.0 -24.1 7440.0 Average Vertical -1.5 43.6 42.1 54.0 -11.9 7440.0 Peak Horizontal 5.4 43.6 49.0 74.0 -25.0 7440.0 Average Horizontal -4.1 43.6 39.5 54.0 -14.5 9920.0 Peak Vertical 5.4 46.1 51.5 74.0 -22.5 V048427_02_LTU-LR_FCC_C_BLE Page 21 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 Receiver Correction Field Margin Frequency Antenna Limit Detector Reading Factor Strength (dB) (MHz) Polarity (dBV/m) (dBV) (dB) (dBV/m) 9920.0 Average Vertical -6.8 46.1 39.3 54.0 -14.7 9920.0 Peak Horizontal 5.2 46.1 51.3 74.0 -22.7 9920.0 Average Horizontal -6.6 46.1 39.5 54.0 -14.5 12400.0 Peak Vertical 14.0 48.0 62.0 74.0 -12.0 12400.0 Average Vertical 2.3 48.0 50.3 54.0 -3.7 12400.0 Peak Horizontal 9.3 48.0 57.3 74.0 -16.7 12400.0 Average Horizontal -1.2 48.0 46.8 54.0 -7.2 14880.0 Peak Vertical 3.3 51.2 54.5 74.0 -19.5 14880.0 Average Vertical -8.9 51.2 42.3 54.0 -11.7 14880.0 Peak Horizontal 2.9 51.2 54.1 74.0 -19.9 14880.0 Average Horizontal -9.3 51.2 41.9 54.0 -12.1 Table 4: Transmitting at the Highest Frequency dBuV Peak Average 120 110 100 90 80 70 1 60 2 50 40 30 20 Start: 2.3850 GHz Stop: 2.4050 GHz Res BW: 1 MHz Vid BW: 10 MHz Sweep: 10.00 s 5/14/2019 10:14:18 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.3900 GHz 57.93 dBuV 2 Average 2.3900 GHz 45.12 dBuV Graph 7: Radiated Lower Band Edge Plot V048427_02_LTU-LR_FCC_C_BLE Page 22 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 dBuV Peak Average 120 110 100 90 80 1 70 60 2 50 40 30 20 Start: 2.4735 GHz Stop: 2.4935 GHz Res BW: 1 MHz Vid BW: 10 MHz Sweep: 10.00 s 5/14/2019 10:05:20 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4835 GHz 64.74 dBuV 2 Average 2.4835 GHz 53.14 dBuV Graph 8: Radiated Upper Band Edge Plot 6.2.6 §15.247(e) Peak Power Spectral Density The maximum peak 3 kHz spectral density measured using radiated methods as an integral antenna with no provision for doing a direct connection at the antenna port provided. The field strength measurements were converted to EIRP using the equation 1.1 of FCC KDB 412172. The maximum antenna gain of 2.0 dBi was then subtracted from the calculated EIRP and was then compared to the limit of 8 dBm. Frequency Measurement EIRP Calculated Conducted PSD (MHz) (dBuV/m) (dBm) (dBm) 2402 91.44 -3.79 -5.79 2442 95.55 0.32 -1.68 2480 96.01 0.78 -1.22 Result The maximum peak power spectral density was less than the limit of 8 dBm; therefore, the EUT complies with the specification. V048427_02_LTU-LR_FCC_C_BLE Page 23 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 dBuV Peak 120 110 100 1 90 80 70 60 50 40 30 20 Start: 2.4015 GHz Stop: 2.4025 GHz Res BW: 3 kHz Vid BW: 10 kHz Sweep: 115.00 ms 5/14/2019 9:54:35 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4022 GHz 91.44 dBuV Graph 9: Lowest Channel 3 kHz PSD Plot dBuV Peak 120 110 1 100 90 80 70 60 50 40 30 20 Start: 2.4415 GHz Stop: 2.4425 GHz Res BW: 3 kHz Vid BW: 10 kHz Sweep: 115.00 ms 5/14/2019 10:20:44 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4422 GHz 95.55 dBuV Graph 10: Middle Channel 3 kHz PSD Plot V048427_02_LTU-LR_FCC_C_BLE Page 24 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 dBuV Peak 120 110 1 100 90 80 70 60 50 40 30 20 Start: 2.4795 GHz Stop: 2.4805 GHz Res BW: 3 kHz Vid BW: 10 kHz Sweep: 115.00 ms 5/14/2019 10:11:20 AM Atten: 10 dB ESU-40 Mkr Trace X-Axis Value Notes 1 Peak 2.4802 GHz 96.01 dBuV Graph 11: Highest Channel Output 3 kHz PSD Plot V048427_02_LTU-LR_FCC_C_BLE Page 25 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 7 Test Procedures and Test Equipment 7.1 Conducted Emissions at Mains Ports The conducted emissions at mains and telecommunications ports from the EUT were measured using a spectrum analyzer with a quasi-peak adapter for peak, quasi-peak and average readings. The quasi-peak adapter uses a bandwidth of 9 kHz, with the spectrum analyzer's resolution bandwidth set at 100 kHz, for readings in the 150 kHz to 30 MHz frequency ranges. The conducted emissions at mains ports measurements are performed in a screen room using a (50 /50 µH) Line Impedance Stabilization Network (LISN). Where mains flexible power cords are longer than 1 m, the excess cable is folded back and forth as far as possible so as to form a bundle not exceeding 0.4 m in length. Where the EUT is a collection of devices with each device having its own power cord, the point of connection for the LISN is determined from the following rules: • Each power cord, which is terminated in a mains supply plug, shall be tested separately. • Power cords, which are not specified by the manufacturer to be connected via a host unit, shall be tested separately. • Power cords which are specified by the manufacturer to be connected via a host unit or other power supplying equipment shall be connected to that host unit and the power cords of that host unit connected to the LISN and tested. • Where a special connection is specified, the necessary hardware to effect the connection is supplied by the manufacturer for the testing purpose. • When testing equipment with multiple mains cords, those cords not under test are connected to an artificial mains network (AMN) different than the AMN used for the mains cord under test. For testing, desktop EUT are placed on a non-conducting table at least 0.8 meters from the metallic floor and placed 40 cm from the vertical coupling plane (copper plating in the wall behind EUT table). Floor standing equipment is placed directly on the earth grounded floor. Date of Due Date Type of Model Asset Manufacturer Last of Equipment Number Number Calibration Calibration Spectrum Analyzer Hewlett Packard 8566B V048078 05/26/2019 05/26/2020 Quasi-Peak Hewlett Packard 85650A V039474 05/02/2018 05/02/2020 Detector LISN Teseq NNB 51 V045406 07/13/2018 07/12/2020 Conductance Cable VPI Labs Cable J V034832 01/08/2019 01/08/2020 Wanship Upper Site Filter VPI Labs 47038 V047038 01/03/2019 01/03/2020 Test Software (AC) VPI Labs Revision 01 V035674 N/A N/A Table 5: List of equipment used for conducted emissions testing at mains ports. V048427_02_LTU-LR_FCC_C_BLE Page 26 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 Figure 1: Conducted Emissions Test 7.2 Radiated Emissions The radiated emissions from the EUT were measured using a spectrum analyzer with a quasi-peak adapter for peak and quasi-peak readings. A preamplifier with a fixed gain of 51 dB was used to increase the sensitivity of the measuring instrumentation. The quasi-peak adapter uses a bandwidth of 120 kHz, with the spectrum analyzer's resolution bandwidth set at 1 MHz, for readings in the 30 to 1000 MHz frequency ranges. For frequencies below 30 MHz, a 9 kHz resolution Bandwidth was used. A loop antenna was used to measure frequencies below 30 MHz. A biconilog antenna was used to measure the frequency range of 30 to 1000 MHz, at a distance of 3 meters from the EUT. The readings obtained by these antennas are correlated to the levels obtained with a tuned dipole antenna by adding antenna factors. A double-ridged guide antenna was used to measure the emissions at frequencies above 1000 MHz at a distance of 3 and/or 1 meter from the EUT. The configuration of the EUT was varied to find the maximum radiated emission. The EUT was connected to the peripherals listed in Section 2.3 via the interconnecting cables listed in Section 2.4. A technician manually manipulated these interconnecting cables to obtain worst-case radiated emissions. The EUT was rotated 360 degrees, and the antenna height was varied from 1 to 4 meters to find the maximum radiated emission. Where there were multiple interface ports all of the same type, cables are either placed on all of the ports or cables added to these ports until the emissions do not increase by more than 2 dB. Desktop EUT are measured on a non-conducting table 0.8 meters above the ground plane. For frequencies above 1000 MHz, the EUT is placed on a table 1.5 meters above the ground plane. The table is placed on a turntable, which is level with the ground plane. For equipment normally placed on floors, the equipment shall be placed directly on the turntable. V048427_02_LTU-LR_FCC_C_BLE Page 27 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 For radiated emissions testing that is performed at distances closer than the specified distance; an inverse proportionality factor of 20 dB per decade is used to normalize the measured data for determining compliance. Date of Due Date Type of Model Asset Manufacturer Last of Equipment Number Number Calibration Calibration Spectrum Rohde & ESU40 V033119 07/16/2018 07/16/2019 Analyzer/Receiver Schwarz Spectrum Analyzer Hewlett Packard 8566B V048078 05/26/2019 05/26/2020 Quasi-Peak Hewlett Packard 85650A V039474 05/02/2018 05/02/2020 Detector Loop Antenna EMCO 6502 V034216 02/11/2019 02/11/2021 Biconilog Antenna EMCO 3142E-PA V035736 07/05/2018 07/05/2020 Double Ridged EMCO 3115 V033469 04/13/2018 04/13/2020 Guide Antenna Standard Gain Horn ETS-Lindgren 3160-09 V034223 ICO ICO Standard Gain Horn ETS-Lindgren 3160-10 V034224 ICO ICO High Frequency AMF-65F- Amplifier L3 Narda-Miteq 18004000-37- V042464 01/08/2019 01/08/2020 (18 – 40 GHz) 8P High Frequency AFS4- Amplifier Miteq 001018000-35- V033997 01/08/2019 01/08/2020 (1 – 18 GHz) 10P-4 2.4 GHz Notch 01/08/2019 01/08/2020 Micro-Tronics BRM50702-03 V034213 Filter 6’ High Frequency UFB197C-0- 01/08/2019 01/08/2020 Microcoax V033638 Cable 0720-000000 20’ High Frequency UFB197C-1- 01/08/2019 01/08/2020 Microcoax V033979 Cable 3120-000000 3 Meter Radiated UFB205A-0- Emissions Cable Microcoax V033639 01/08/2019 01/08/2020 4700-000000 Wanship Upper Site Test Software VPI Labs Revision 01 V035673 N/A N/A (FCC) Table 6: List of equipment used for radiated emissions testing. V048427_02_LTU-LR_FCC_C_BLE Page 28 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 Figure 2: Radiated Emissions Test 7.3 Equipment Calibration All applicable equipment is calibrated using either an independent calibration laboratory or VPI Laboratories, Inc. personnel at intervals defined in ANSI C63.4:2014 following outlined calibration procedures. All measurement instrumentation is traceable to the National Institute of Standards and Technology (NIST). Supporting documentation relative to tractability is on file and is available for examination upon request. 7.4 Measurement Uncertainty Test Uncertainty (±dB) Confidence (%) Conducted Emissions 2.8 95 Radiated Emission (9 kHz to 30 MHz) 3.3 95 Radiated Emissions (30 MHz to 1 GHz) 3.4 95 Radiated Emissions (1 GHz to 18 GHz) 5.0 95 Radiated Emissions (18 GHz to 40 GHz) 4.1 95 V048427_02_LTU-LR_FCC_C_BLE Page 29 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 8 Photographs Photographs are contained in an external appendix. V048427_02_LTU-LR_FCC_C_BLE Page 30 of 31 PROPRIETARY

313 West 12800 South, Suite 311, Draper, UT 84020 • (801) 260-4040 --- End of Report --- V048427_02_LTU-LR_FCC_C_BLE Page 31 of 31 PROPRIETARY


Document Created: 2019-07-24 13:15:19
Document Modified: 2019-07-24 13:15:19
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