confidentiality request letter

FCC ID: TV7R11E5HAM

Cover Letter(s)

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FCCID_4159675

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



   January 31, 2019

   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: TV7R11E5HAM

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

   Dear Sirs:
   Mikrotikls SIA requests that the material in the Schematics, Block Diagram, and Operational
   Descriptions be withheld from public disclosure pursuant to Sections 0.457 and 0.459 of the
   Commission’s Rules following grant of the application. In support of this request, Mikrotikls submits
   the following:

   Long Term Confidential Files Include
   Schematics                  File Name         Conf Schem R11E5HACD.pdf
   Block diagram               File Name         Conf BlkDia R11E5HACD.pdf
   Operational Description     File Name         Conf OpDes R11E5HACD.pdf
   Operational Description     File Name         Conf OpDes KDB 594280 R11E5HACD.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: TV7R11E5HAM


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 Mikrotikls SIA 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 Mikrotikls SIA.

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 Mikrotikls SIA 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. 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: 2019-01-31 14:22:12
Document Modified: 2019-01-31 14:22:12

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