Confidential Letter

FCC ID: TV7GROOVE-5HN

Cover Letter(s)

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FCCID_1466322

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




     May 12, 2011

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

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

     Applicant:       Mikrotikls SIA
                      Pernavas 46
                      Riga, Latvia LV-1009

     Re: Confidentiality for submittal information regarding FCC ID number TV7GROOVE-5HN

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

     Dear Sirs:
     Mikrotikls SIA 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 Commission’s Rules, 47 C.F.R., following grant of
     the application. In support of this request, Mikrotikls submits the following:

     Long Term Confidential Files Include
     Schematics                        File Name          Conf Schem Groove A5Hn.pdf
     Block diagram                     File Name          Conf BlkDia Groove A5Hn.pdf
     Operational Description           File Name          Conf OpDes Groove A5Hn.pdf

1.   Identification of the specific information for which confidential treatment is sought:
     The materials set forth 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:
     TV7GROOVE-5HN

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.   Explaanation of the degree to which the inform    mation concern  ns a service thaat is subject too competition::
     The material
         m        for whiich confidentiaality is sought is
                                                         i employed in the design andd manufacture of this transmiitting
     equipmment that is offfered on a highhly competitivee basis. Custom
                                                                       mers for this eqquipment have a variety of coompeting
     sourcees.

5.   Explaanation of how   w disclosure off the informatiion could resu ult in substanttial competitivve harm:
     Discloosure would, in n effect, give aw              o the labors off Mikrotik enggineering personnel, who havee designed
                                           way the fruits of
     the equuipment and th  he manufacturiing process. Disclosure
                                                        D          woulld also offer coompetitors addiitional unwarraanted
     insighht into the state of the productt development, thereby allow
                                                                      wing competitorrs an advantagee, not availablee to
     Mikrotikls SIA

6.   Identiification of any measures taaken by the su    ubmitting partty to prevent unauthorized
                                                                                      u              disclosure:
     The innformation for which confidential treatmentt is sought is keept confidentiaal by Mikrotikls SIA and not made
     availabble to third parrties except purrsuant to non-ddisclosure agreeements.

7.   Identiification of wh hether the infoormation is avvailable to the public and th  he extent of anny previous dissclosure
     of the information to t third partiees:
     To thee knowledge off those preparinng this applicattion, the informmation has not been disclosedd publicly hereetofore.
     While the general theory of operatiion of this equiipment has beeen the subject of o numerous diisclosures in inndustry and
     standaards groups as well
                            w as in rule making proceeedings of the FCC,F     the protecction sought is narrowly draw
                                                                                                                    wn and
     pertainns to certain sp
                           pecific implemeentations of thiis radio technoology.

8.   Justifi
          fication of the period duringg which the su    ubmitting partty asserts thatt the material should not be available
     for pu
          ublic disclosurre:
     This material
          m         shouldd not be disclossed for at least 25 years. Whiile improvemennts in design are a made relativvely
     frequeently, disclosurre of the designn information would
                                                          w      lead to innsights into booth design and manufacturingg
     techniques that could d have an adveerse competitivve effect for maany years to coome. As such, it is important that the
     designn not be made available
                           a          to unnauthorized perrsons who mighht attempt to use knowledge of the design too
     comprromise the appllications for which
                                          w      the equipmment will be emmployed.

     Shouldd you require any
                         a further infoormation, pleasse contact the undersigned.
                                                                     u
     Thankk you for your consideration
                         c             i this matter.
                                       in

     Sincerrely,

     Scot Rogers
          R



Document Created: 2011-05-12 12:18:27
Document Modified: 2011-05-12 12:18:27

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