Confidential Letter

FCC ID: TV7-R5H

Cover Letter(s)

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FCCID_1037691

                            ROGERS LABS, INC.
                            4405 West 259th Terrace
                            Louisburg, KS 66053




     November 25, 2008

     Timco Engineering Inc.
     849 NW State Road 45
     Newberry, FL 32669

     Office of Engineering and Technology
     Federal Communications Commission
     Columbia, MD 21046

     Applicant:       MIKROTIK
                      Pernavas 46
                      Riga, Latvia LV-1009

     Re: Confidentiality for submittal information regarding FCC ID number TV7-R5H

     PRODUCT:         Broadband wireless Digital Transmission System operating under CFR47 part 15.247

     Dear Sirs:
     MIKROTIK requests that the material in the Schematic, block diagram, and Operational Description is withheld
     from public disclosure in accordance with Section 0.459 of the Commissions Rules, 47 C.F.R., following grant of
     the application. In support of this request, MIKROTIK submits the following:

     Long Term Confidential Files Include
     Schematics                        File Name         Conf Schem R5H.pdf
     Block diagram                     File Name         Conf BlkDia R5H.pdf
     Operational Description           File Name         Conf OpDes R5H.pdf

     Short Term Confidential files include
     External Photos           File Name         ExtPho R5H.pdf
     Internal Photos           File Name         IntPho R5H.pdf
     Test Setup Photos         File Name         TSup R5H.pdf
     User Manual               File Name         UserMan R5H.pdf

1.   Identification of the specific information for which confidential treatment is sought:
     The materials set fourth in the Operational Description, block diagram, and Schematics, which are segregated from
     the non-confidential exhibits of the application, are those for which confidentiality is sought.

2.   Identification of the Commission proceeding in which the information was submitted or a description of the
     circumstances giving rise to the submission:
     The proceeding is that involving the application for equipment authorization (certification) under FCC ID No:
     TV7-R5H


3.   Explanation of the degree to which the information is commercial or financial, or contains a trade secret or is
     privileged:
     This material includes a detailed theory of operation, circuit diagrams, (schematic diagrams) and any detail Parts
     List. As such, this material is treated as highly confidential business information.

4.   Explanation of the degree to which the information concerns a service that is subject to competition:
     The material for which confidentiality is sought is employed in the design and manufacture of this transmitting
     equipment that is offered on a highly competitive basis. Customers for this equipment have a variety of competing
     sources.

5.   Explanation of how disclosure of the information could result in substantial competitive harm:
     Disclosure would, in effect, give away the fruits of the labors of Mikrotik’s engineering personnel, who have
     designed the equipment and the manufacturing process. Disclosure would also offer competitors additional
     unwarranted insight into the state of the product development, thereby allowing competitors an advantage, not
     available to MIKROTIK

6.   Identification of any measures taken by the submitting party to prevent unauthorized disclosure:
     The information for which confidential treatment is sought is kept confidential by MIKROTIK and not made
     available to third parties except pursuant to non-disclosure agreements.

7.   Identification of whether the information is available to the public and the extent of any previous disclosure
     of the information to third parties:
     To the knowledge of those preparing this application, the information has not been disclosed publicly heretofore.
     While the general theory of operation of this equipment has been the subject of numerous disclosures in industry and
     standards groups as well as in rule making proceedings of the FCC, the protection sought is narrowly drawn and
     pertains to certain specific implementations of this radio technology.

8.   Justification of the period during which the submitting party asserts that the material should not be available
     for public disclosure:
     This material should not be disclosed for at least 25 years. While improvements in design are made relatively
     frequently, disclosure of the design information would lead to insights into both design and manufacturing
     techniques that could have an adverse competitive effect for many years to come. This equipment is designed for
     commercial, industrial, and governmental applications. As such, unlike most consumer equipment, this equipment
     could be used for more than a decade in some cases. As such, it is important that the design not be made available
     to unauthorized persons who might attempt to use knowledge of the design to compromise the applications for
     which the equipment will be employed.

     Should you require any further information, please contact the undersigned.
     Thank you for your consideration in this matter.

     Sincerely,

     Scot Rogers



Document Created: 2008-11-25 13:18:01
Document Modified: 2008-11-25 13:18:01

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