03402 Low Power Transmitter 2402-2480 MHz Cover Letter Confidentiality Letter Garmin International Inc

Garmin International Inc Low Power Transmitter 2402-2480 MHz

Page 1 of 03402 Low Power Transmitter 2402-2480 MHz Cover Letter Confidentiality Letter Garmin International Inc
Page 2 of 03402 Low Power Transmitter 2402-2480 MHz Cover Letter Confidentiality Letter Garmin International Inc

ROGERS LABS, INC.
4405 West 259th Terrace
Louisburg, KS 66053
913 837-3214
March 1, 2018
Timco Engineering Inc.
849 NW State Road 45
Newberry, FL 32669
Applicant:
Garmin International, Inc.
1200 East 151st Street
Olathe, KS 66062
Re: Confidentiality for submittal information regarding
FCC ID: IPH-03402
PRODUCT:
Transmitter operated under 47CFR Section 15C
Dear Sirs:
Garmin International, Inc. requests that the material in the Schematics, Block Diagram, and
Operational Description 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, Garmin
International, Inc. submits the following information.
CONFIDENTIAL FILES
A03402 Conf BlkDia.pdf
A03402 Conf OpDes.pdf
A03402 Conf Schem.pdf
1. Identification of the specific information for which confidential treatment is sought:
The materials set forth in the Operational Description, block diagram, parts list, 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: IPH-03402
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, and schematic. As such, this
material is treated as highly confidential business information.
Page 1 of 2
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 Garmin International, Inc.’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 Garmin International, Inc.
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 Garmin
International, Inc. 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
Page 2 of 2
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Document ID3786946
Application IDZg/55ZBaM+EklwG4v5Nk1A==
Document DescriptionConfidentiality Letter
Short Term ConfidentialNo
Permanent ConfidentialNo
SupercedeNo
Document TypeCover Letter(s)
Display FormatAdobe Acrobat PDF - pdf
Filesize10.69kB (133572 bits)
Date Submitted2018-03-19 00:00:00
Date Available2018-03-19 00:00:00
Creation Date2018-03-01 14:52:09
Producing SoftwareMicrosoft® Word 2016
Document Lastmod2018-03-01 14:52:09
Document TitleConfidentiality Letter
Document CreatorMicrosoft® Word 2016

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