G020G Smartphone Cover Letter Google

Google Smartphone

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Federal Communications Commission
7435 Oakland Mills Road
Columbia MD 21046

Date:          January 11, 2019
Subject:       Request for Confidentiality
FCC ID:        A4RG020G

To Whom It May Concern:

Pursuant to Sections 0.457 and 0.459 of the Commission’s rules (47 C.F.R. §§ 0.457, 0.459),
Google LLC (Google) requests that the Commission indefinitely withhold from public disclosure
the following attachments associated with the certification application for the above-referenced
FCC ID: A4RG020G:

      Theory of Operation (Operational and Technical Description)
      Block Diagram
      Schematic Diagram
      Tune-up Procedure

In support of this request, Google provides the following information:

   1. Identification of the specific information for which confidential treatment is sought
      (§0.459(b)(1)): Google requests that all of the information contained in the above-
      referenced exhibits to the certification application be withheld from routine public
      disclosure.

   2. Identification of the Commission proceeding in which the information was
      submitted or a description of the circumstances giving rise to the submission
      (§0.459(b)(2)): The material is being submitted in connection with Google’s certification
      application for FCC ID A4RG020G.


   3. Explanation of the degree to which the information is commercial, or financial or
      contains a trade secret or is privileged (§0.459(b)(3)): The market for the technology
      that is the subject of the certification application is highly competitive, with numerous
      companies competing for the business of potential customers. Were Google’s
      competitors to become aware of the facts set forth in the above-referenced exhibits to the
      application at this time, it could have an adverse impact on Google’s competitive
      standing and deprive Google of the marketplace benefit it otherwise might achieve by
      virtue of having the product available before other competitors. If any of the information
      for which confidential treatment is sought were to be made publicly available, Google’s
      competitors could reasonably determine the scope and status of our activities.

   4. Explanation of the degree to which the information concerns a service that is
      competitive (§0.459(b)(4)): The technology that is the subject of the certification
      application is subject to intense competition from other manufacturers and service
      providers that are developing competing services and technology.

   5. Explanation of how disclosure of the information could result in substantial
      competitive harm (§0.459(b)(5)): As noted above, were Google’s competitors to
      become aware of the facts set forth in the above-referenced exhibits to the application, it
      could have an adverse impact on Google’s competitive standing and deprive Google of
      the marketplace benefit it otherwise would achieve by virtue of having the product
      available before other providers.

   6. Identification of any measures taken by the requesting party to prevent
      unauthorized disclosure (§0.459(b)(6)): The information contained in the above-
      referenced exhibits to the certification application has been strictly controlled by Google,
      with distribution limited to internal use only and for the specific purpose of conducting
      research, development, and testing of the technology.

   7. Identification of whether the information is available to the public and the extent of
      any previous disclosures of the information to any third parties (§0.459(b)(7)): The
      information that Google requests be maintained as confidential is not available publicly.
      The information has been protected and kept confidential by limiting external contacts to
      privileged and confidential communications.

   8. Justification of the period during which the submitting party asserts that material
      should not be available for public disclosure (§0.459(b)(8)): Given the competitive
      nature of the marketplace, any disclosure that Google has developed the technology
      discussed in the above-reference exhibits to the certification application would harm
      Google’s competitive position. The information subject to this request for confidentiality
      should not be made available for public disclosure at any time.

In addition, pursuant to Public Notice DA 04-1705, and in order to comply with the marketing
regulations in 47 C.F.R. §2.803 and the importation rules in 47 C.F.R. §2.1204 while ensuring


that business-sensitive information remains confidential until the actual marketing of newly
authorized devices, Google also requests that the Commission grant temporary confidential
treatment and not release the following attachments for routine public disclosure until 180 days
following the grant of this certification application:

      Internal Photos
      External Photos
      Test Setup Photos
      User Manual

It is our understanding that test measurement reports and correspondence during the certification
review process cannot be granted confidential treatment, and such information will be available
for public review once the grant of equipment authorization is issued.




Sincerely Yours,




Hedy Hsieh
Regulatory Certification Program Manager
Google LLC
1600 Amphitheatre Parkway
Mountain View, CA 94043, USA
Phone: +886 2 8729 0540
Email: hedyhsieh@google.com



Document Created: 2019-01-14 14:27:22
Document Modified: 2019-01-14 14:27:22
Download: G020G Smartphone Cover Letter  Google
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Document ID4153215
Application IDph85gAF35JzMn71ct3JjNw==
Document DescriptionAttestations_20190115_v1 - Confidentiality Request
Short Term ConfidentialNo
Permanent ConfidentialNo
SupercedeNo
Document TypeCover Letter(s)
Display FormatAdobe Acrobat PDF - pdf
Filesize19.95kB (249358 bits)
Date Submitted2019-01-30 00:00:00
Date Available2019-02-25 00:00:00
Creation Date2019-01-14 14:27:22
Producing SoftwareMicrosoft Word 2016
Document Lastmod2019-01-14 14:27:22
Document TitleCover Letter(s)
Document CreatorMicrosoft Word 2016
Document Author: Celina Cui