FCC ID: U9YAL5834 UWB USB Interface Module (SBU & SAB)

www.alereon.com | 10800 Pecan Park Blvd. | Suite 100 | Austin,Tx 78750 | 512.345.4200 | 512.345.4201 ALER03 Compliance Statement for Combat256 AL5834: FCC ID: U9YAL5834 This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions:

(1) This device may not cause harmful interference.

(2) This device must accept any interference received, including interference that may cause undesired operation. CAUTION: Changes or modifications not expressly approved by the party responsible for compliance could void the user's authority to operate the equipment. NOTE: This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to Part 15 of the FCC Rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates uses and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications. However, there is no guarantee that interference will not occur in a particular installation. If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one or more of the following measures:

- Reorient or relocate the receiving antenna.

- Increase the separation between the equipment and receiver.

- Connect the equipment into an outlet on a circuit different from that to which the receiver is connected.

- Consult the dealer or an experienced radio/TV technician for help. FCC Radiation Exposure Statement:

This equipment complies with FCC radiation exposure limits set forth for an uncontrolled environment. This equipment should be installed and operated with minimum distance 0cm between the radiator & your body. OEM INTEGRATION INSTRUCTIONS:

This device is intended only for OEM integrators under the following conditions:

The module must be installed in the host equipment that must be handheld, i.e., they are relatively small devices that are primarily handheld while being operated and do not employ a fixed infrastructure and the transmitter module may not be co-located with any other transmitter or antenna. The module shall be only used with the internal on-board antenna that has been originally tested and certified with 4/14/2021 CONFIDENTIAL 1 of 2 this module. External antennas are not supported. As long as these 3 conditions above are met, further transmitter tests will not be required. However, the OEM integrator is still responsible for testing their end-product for any additional compliance requirements required with this module installed (for example, digital device emissions, PC peripheral requirements, etc.). The end-

product may need Verification testing, Declaration of Conformity testing, a Permissive Class II Change or new Certification. Please involve a FCC certification specialist in order to determine what will be exactly applicable for the end-product. Validity of using the module certification:

In the event that these conditions cannot be met (for example certain laptop configurations or co-location with another transmitter), then the FCC authorization for this module in combination with the host equipment is no longer considered valid and the FCC ID of the module cannot be used on the final product. In these circumstances, the OEM integrator will be responsible for re-evaluating the end product (including the transmitter) and obtaining a separate FCC authorization. In such cases, please involve a FCC certification specialist in order to determine if a Permissive Class II Change or new Certification is required. Upgrade Firmware:

The software provided for firmware upgrade will not be capable to affect any RF parameters as certified for the FCC for this module, in order to prevent compliance issues. End product labeling: This transmitter module is authorized only for use in device where the antenna may be installed such that 0 cm may be maintained between the antenna and users. The final end product must be labeled in a visible area with the following: Contains FCC ID: U9YAL5834. Information that must be placed in the end user manual:

The OEM integrator has to be aware not to provide information to the end user regarding how to install or remove this RF module in the user's manual of the end product which integrates this module. The end user manual shall include all required regulatory information/warning as show in this manual. This device is authorized under 47 CFR 15.519 (the FCC Rules and Regulations). The operation of this device is subject to the following restriction: This UWB device shall transmit only when it is sending information to an associated receiver. This UWB device shall cease transmission within 10 seconds unless it receives an acknowledgement from the associated receiver that its transmission is being received. An acknowledgement of reception must continue to be received by the transmitting device at least every 10 seconds of operation or the UWB device must cease transmitting 4/14/2021 CONFIDENTIAL 2 of 2

www.alereon.com | 10800 Pecan Park Blvd. | Suite 100 | Austin,Tx 78750 | 512.345.4200 | 512.345.4201 To whom it may concern, The AL5834 Combat256 module is too small for attaching an FCC identification label. Instead, the following statements will be added to the Users Manual. In addition, the same statements will be printed on a sticker and adhered to the packaging for each module that is shipped. This device contains FCC ID U9YAL5834. This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions:(1) This device may not cause harmful interference.(2) This device must accept any interference received, including interference that may cause undesired operation. Thanks, Parmveer Singh Director of Systems Applications Alereon, Inc. 3/22/2021 3/22/2021 CONFIDENTIAL 1 of 1

alereo;n. www.alereon.com | 10800 Pecan Park Blvd. | Suite 100 | Austin, Tx 78750 | 512.345.4200 | 512.345.4201 AGENT AUTHORIZATION Company: Alereon, Inc. Address: 10800 Pecan Park Bivd., Suite 100, Austin, TX 78750 Product Name: Impact, Octal, Commander256, Destroyer256, Combat256, Camouflage256 Model Number(s): AL5804_Impact_Rev1, AL5808_Octal_Rev1, AL5830_Commander256_Rev1, AL5833_Destroyer256_Rev1, AL5834_Combat256, Rev1, AL5835_Camouflage256_Rev1 Product Description: Alereon UWB 16-bit parallel! interface, USB and Serial Modules We authorize MiCOM Labs Inc., 575 Boulder Court, Pleasanton, California 94566, USA, to act on our behalf on all matters concerning the certification of above named equipment. We declare that MiCOM Labs Inc. is allowed to forward all information related to the approval and certification of equipment to the regulatory agencies as required and to discuss any issues concerning the approval application. Any and all acts carried out by MiCOM Labs on our behalf shall have the same effect as acts of our own. en a Title:

Company:

2/25/2021 CONFIDENTIAL Loft

slerecnr. www.alereon.com | 10800 Pecan Park Blvd. | Suite 100 | Austin,Tx 78750 | 512.345.4200 | 512.345.4201 March 22, 2021 Federal Communications Commission Equipment Authorization Division 7435 Oakland Mills Road Columbia, MD 21046 USA Attn: OET Dept. Subject: FCC ID: U9YAL5834 To Whom It May Concern:

We hereby attest to the fact that we have applied the Declaration of Conformity procedure for a Class B Computer Peripheral to the digital portion of this composite filing. The procedures identified in 47CFR 2.948(d) and 2.948(e), along with the requirements listed in KDB 349827 have been followed. The report has been issued by Micom Labs at 575 Boulder Court, Pleasanton, CA 94566 and can be identified by report number ALERO3-U4. Sincerely, 10800 Pecan Park Blvd., Suite 100 Austin, TX 78750

(512) 418-2027 3/22/2021 CONFIDENTIAL 1 of 1

slereocn. www.alereon.com | 10800 Pecan Park Blvd. | Suite 100 | Austin,Tx 78750 | 512.345.4200 | 512.345.4201 Federal Communications Commission Equipment Authorization Division 7435 Oakland Mills Road Columbia, MD 21046 USA Date: 3/22/2021 Subject: Modular Transmitter Application Company name: Alereon, Inc. FCC ID: USYAL5804, USYAL5808, U9YAL5830, U9YAL5833, U9YAL5834 and U9YAL5835 Dear Sir/Madam, This letter includes the FCC application requirements for Modular Transmitter Approval Request for;-

FCC KDB 996369 DO1 Module Certification Guide v02; and FCC KDB 996369 D03 OEM Manual v01 In accordance with 47CFR 15.212 Modular Transmitters and KDB 996369 DO1 Module Equip Auth Guide v02. FCC ID U9YAL5804, USYAL5808, U9YAL5830, U9YAL5833, U9YAL5834 and U9YAL5835 have been examined against the following requirements. Requirement per 15.212 and KDB 996369 D01 Explanation from Grantee

(do not write yes/no, but explain why product complies/how it is achieved) All shielding necessary for normal operation is accomplished by the multi-layer construction of the printed wiring board which incorporates multiple ground layers in its construction. As this transmitter is designed to operate stand-alone in its own enclosure, connected to an The radio elements must have the radio frequency circuitry industry-standard USB 2.0 interface shielded. Physical components and tuning capacitor(s) may be no additional shielding is , located external to the shield, but must be on the module : : , assembly. incorporated to minimize coupling such as may occur if the module were incorporated into another unit. In addition, a tamper proof coating will cover a majority of the module, making it impossible to adjust any of the RF parameters. This firmware is locked down with a strict requirement not to allow any changes. 3/22/2021 CONFIDENTIAL 1 of 4 The module must have buffered modulation/data inputs to ensure that the device will comply with Part 15 requirements with any type of input signal. The Alereon modules receive data via the industry-standard USB 2.0 interface. All interfaces are implemented within the AL5350 integrated circuit as may be seen on the schematic diagram included in the filing for FCC Equipment Authorization. These interfaces limit the data rate to those defined by their standards The module must contain power supply regulation on the module. The Alereon modules receive power from the host system. The +5.0 Volt source from the host system is regulated on the module to power a

+3.3V domain and the main +1.2V digital subsystem domain. The +3.3V domain is also regulated on the module to produce three additional power domains required by the module circuitry;

+2.4V, +1.2V and +0.9V. The power regulation topology may be seen on the schematic diagram included in the filing for FCC Equipment Authorization. The module must contain a permanently attached antenna, or contain a unique antenna connector, and be marketed and operated only with specific antenna(s), per 15.203, 15.204(b), 15.204(c), 15.212(a), 2.929(b). The antenna of the Alereon UWB is a chip antenna as tested in the report. The antenna can be connected via a 40mm coaxial cable with a type U.FL connector. The antenna is intended to be permanently attached to or within the product housing and the connector is not accessible to the user. The U.FL connector complies with the requirement of FCC 15.203 for a unique coupling. The module must demonstrate compliance in a stand-alone configuration. As described in the test report included in the filing for FCC Equipment Authorization, the UWB Modules plus antenna were tested without a housing. For the tests reported the module was attached to an Alereon designed test environment which provided power and a USB interface to the controlling computer. The module must be labeled with its permanently affixed FCC ID label, or use an electronic display (see KDB Publication 784748). The Alereon modules are intended to be placed within the host system enclosure unique to the brand 1.D. of the host system. The 3/22/2021 CONFIDENTIAL 2 of 4 EEUU CO prescribed label with the FCC Identifier will be included in the compliance statement. Part 15.519 of the FCC rules and Regulations requires that a UWB transmitter shall transmit only when it is sending information to an associated receiver. That rules part also requires that the UWB intentional radiator shall cease transmission within 10 seconds

. unless it receives an The module must comply with all specific rules applicable to the transmitter, including all the conditions provided in the integration acknowledgement from the instructions by the grantee. associated receiver that its transmission is being received. An acknowledgment of reception must continue to be received by the UWB intentional radiator at least every 10 seconds or the UWB device must cease transmitting. This requirement is met by design and is implemented by the firmware encoded into the device. An MPE evaluation has been conducted and the part meets RF The module must comply with RF exposure requirements exposure requirements. Integration Instructions for host product manufacturers The following items are submitted in support of application for Modular Transmitter FCC ID as noted above as required by the FCC KDB 996369 DO3 OEM Manual v01. These items are provided as integration instructions for host product manufacturers (e.g., OEM instruction manual) to use when integrating a module in a host product. Any requirements that are not applicable to the Module are as indicated below. Summary of requirements and Checklist. Refer to the KDB for description of the complete requirements;

KDB Requirements of KDB 996369 D03 User Manual Page Number Ref Sect reference 2.2 List of applicable FCC rules 15.519 (UWB), 15.212

(Modular Approval) 2.3 Summarize the specific operational use conditions N/A. Only equivalent antennas(same type with equal or less antenna gain) can be used. Other antennas

| will require additional

| evaluations. All modules are

| pre-calibrated to the 3/22/2021 CONFIDENTIAL 3 of 4 ee appropriate FCC limits from the module supplier. The integrator cannot change the TX power. Also, the modules ship with the same antenna that was used when performing FCC certification testing. 2.4 Limited module procedures N/A. This requirement does not apply since this is not a limited modular certification. 2.5 Trace antenna designs N/A. The module does not contain a trace antenna. 2.6 RF exposure considerations Section 10.7. Page 33. Please also refer to RF Exposure, Report No. ALERO3 MPE RevA. 2.7 Antennas Section 10.7. Page 33 2.8 Label and compliance information Section 10.7. Page 33 2.9 Information on test modes and additional testing N/A. This requirement does requirements not apply because our modules are FIPS 140-2 compliant. Due to this, there are no test modes or additional testing requirements exposed to the integrator. 2.10 Additional testing, Part 15 Subpart B disclaimer Section 10.7. Page 33 Name: Parmveer Singh Date: 3/22/2021 Title: Director of Systems Appli Signature of applicant:

3/22/2021 CONFIDENTIAL 4 of 4

salereocn. www.alereon.com {| 10800 Pecan Park Blvd. | Suite 100 ; Austin,Tx 78750 | 512.345.4200 | 512.345.4201 Office of Engineering Technology Federal Communications Commission 7435 Oakland Mills Road Columbia, MD 21046 USA Date: 3/30/2021 Subject; Request for Confidentiality FCC ID: U9YAL5834 To Whom It May Concern, Pursuant to the provisions of the Commissions rules Title 47 Sections 0.457 and 0.459, we are requesting the Commission to withhold the following attachment(s) as confidential documents from public disclosure indefinitely. These documents contain detailed system and equipment descriptions and are considered as proprietary information in operation of the equipment. The public disclosure of these documents might be harmful to our company and would give competitors an unfair advantage in the market.

[x] Schematic Diagram x] Block Diagram XX] Parts List

[x] Operational Description

[-] Tune-up Procedure In additional to above mentioned documents, in order to comply with the marketing regulations in Title 47 CFR 2.803 and the importation rules in Title 47 CFR 2.1204, while ensuring that business sensitive information remains confidential until the actual marketing of newly authorized devices, we request Short Term Confidentiality of the following attachment(s):

External Photos Test Setup Photos Internal Photos

[|] User Manual

| For 45 days, pursuant to Public Notice DA 04-1705. OR For 180 days pursuant to KDB 726920 D01. It is our understanding that all measurement test reports, FCC ID label format and correspondence during the certification review process cannot be granted as confidential 1 of 2 FCC Short & Long Term Confidentiality Request Rev4.1-AL5834.di Name: Parmveer Singh Title: Director of Systems Applications 3/30/2021 CONFIDENTIAL 2 of 2

slereocn. www.alereon.com | 10800 Pecan Park Blvd | suite 100 | austin, tx 78750 | 512.345.4200 | 512.345.4201 Dear FCC Team, This is an addendum to the request for confidentiality for the following IDs issued to Alereon: U9gYAL5835, U9YAL5834, U9YAL5830, U9YAL5833, U9YAL5808, and UgYAL5804. We wish to make the following points:

1. Alereon acknowledges that this is a post grant confidentiality request. 2. Alereon acknowledges that the information was public as of 04/21/2021. 3. Alereon understands that third-party websites may still be displaying the information publicly and that the commission has no control over or obligation to correct. _ t /

Saal: Kh Abbe. oon David Shoemaker CEO Alereon, Inc. 7/9/2021 CONFIDENTIAL 1ofi i i i

slereocn. www.alereon.com | 10800 Pecan Park Blvd | suite 100 | austin, tx 78750 | 512.345.4200 | 512.345.4201 Dear FCC Team, We recently received certification for six similar UWB modules. The IDs are:

U9gYAL5835, U9YAL5834, U9YAL5830, U9YAL5833, UQYAL5808, and U9YAL5804. We would like to request long-term confidentiality for the User Guides for each of these modules. These modules are used for military applications, and the specification of the Embedment Guide (User Guide) has a variety of FOUO markings indicating that they are not for public release. The government has reviewed these documents and decided that these documents should not be distributed. All sales of these modules must first go through a government approval, and the Embedment Guide (User Guide) is only released after a strict NDA is signed. The document itself has these marking indicating the level of protection they should have, but the NDA signed by companies using these module explicitly prevents them from sharing the documentation and required them to destroy the documents once the project is over. The documents themselves are held on a private server, and anybody requesting a copy must receive government approval before receiving them. The classification of the document itself indicates that it can not be freely shared. I have also attached a copy of the NDA we require people to sign. The products that embed these modules are ITAR protected, and the product have a NIST FIPS 140-2 level of security (or higher). As a result, no data can be shared with third parties, and users of the module have strict NDA requirements. Please consider the User Guide to under long term confidentiality for each of these 6 modules. I have attached a copy of the NDA that gets signed. I can also get further government support to remove these documents if required. Aad ener |

David Shoemaker CEO Alereon, Inc.

7/7/2021 CONFIDENTIAL lofi ad; 2) DE Er