FCC ID: 2AJY7011 RF Module

User Guide Quickstart Guide Open ATAK Turn on Beartooth Pairing Device Start pairing to Beartooth device Pairing Device Choose your device and verify serial number Communication Navigate to broadcast group Communication Open broadcast group Communication 2 1 1. Push to talk 2. Send with arrow Communication 2 1 1. Enter message 2. Send with arrow LegalNotices Transmission Modules The MK II contains the following transmitter modules:

Contains:

Contains:

HVIN: MK II TX1 FCC ID: 2AJY7011 IC ID: 22043-011 HVIN: MK II TX2 FCC ID: 2AJY7012 IC ID: 22043-012 LegalNotices FCC Interference Statement 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 output on a circuit different from that to which the receiver is connected. Consult the dealer or an experienced radio/TV technician for help. Caution:

IMPORTANT! Changes or modifications not expressly approved by Beartooth could void the users authority to operate the equipment. 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. This device has been tested for RF emissions and has been deemed safe for human exposure as determined by the governments SAR testing standards. This device complies with Industry Canada licence-exempt RSS standard(s). Operation is subject to the following two conditions: (1) This device may not cause harmful interference. and (2) this device must accept any interference received, including interference that may cause undesired operation of the device. LegalNotices Canada, Industry Canada (IC) Notices Cet appareil est conforme la norme RSS d'Industrie Canada exempte de licence. Son fonctionnement est soumis aux deux conditions suivantes: (1) Ce dispositif ne doit pas causer d'interfrences nuisibles, et (2) cet appareil doit accepter toute interfrence reue, y compris les interfrences pouvant entraner un fonctionnement indsirable. CAN ICES-3 (B)/NMB-3(B) This Class B digital apparatus complies with Canadian ICES-003. Cet appareil numriqu de la classe B est conform la norme NMB-003 du Canada. This equipment complies with portable radiation exposure limits set forth for uncontrolled environment. Cet quipement est conforme aux limites d'exposition aux rayonnements portables fixes pour un environnement non contrl. Important Safety Information for Data Radios:

Your Beartooth device contains a RF transceiver. Your device has been tested for and passed the FCCs RF exposure guidelines for regular body-worn operation without any modification of the hardware. Any modification of the hardware or use of the device not in line with provided instructions may not ensure compliance with RF exposure guidelines. Unauthorized modifications or attachments could damage the device and also violate FCC regulations. This device must not be co-located with other transmitters.

The label will be placed in the location shown in Figure 2. Note that the label shown in Figure 2 is not the label that will be used. The correct label is the one shown in Figure 1. Figure 2 - Beartooth Radio MK II label location Figure 1 Beartooth Radio BT MK II label

Label & Label Location Revision 2 Description:

Model Name:

HVIN:

FCC ID IC ID Module MK II TX1 MK II TX1 2AJY7011 22043-011 Beartooth Radio, Inc. 5 W Mendenhall STE 202 Bozeman MT 59715 By TEM Consulting, LP 140 River Rd. Georgetown, TX 78628 August 2022 Figure 1 Beartooth Radio BT MK II label for 2AJY7011 module The size of the label is 24mm x 19mm. The label is made of water resistant Vinyl with optimal adhesion. The label will be placed over the original label, in the location shown in Figure 2. Note that the label shown in Figure 2 is not the label that will be used. The correct label is the one shown in Figure 1. Figure 2 - Beartooth Radio MK II internal photo Figure 3 Label to be covered by the label shown in Figure 1

Certification Application Attestation Statements Date: February 13, 2023 American Certification Body, Inc. 313 Park Avenue Suite 300 Falls Church, VA 22046 To Whom It May Concern:

Statement for 47 CFR section 2.911(d)(5)(i) _Beartooth Radio______ certifies that as of the date of the application the equipment for which authorization is sought is not covered equipment[1] prohibited from receiving an equipment authorization pursuant to section 2.903 of the FCC rules. If the equipment for which the applicant seeks authorization is produced by any of the entities identified on the current Covered List, including affiliates or subsidiaries of the named companies, the applicant must include an explanation on why the equipment is not covered equipment. Additional Explanation: <N/A>

Statement for 47 CFR section 2.911(d)(5)(ii) Beartooth Radio, Inc. | 5 W Mendenhall St. Suite 202 | Bozeman, Montana, 59715 | Telephone +1 917 385 0195 | www.Beartooth.com _Beartooth Radio______ (the applicant) certifies that, as of the date of the filing of this application, the applicant is not identified on the Covered List as an entity producing covered equipment. Thank you, By: __________________________ Michael C. Monaghan_

(Signature[2]) (Print name) Title: _President Company: _____Beartooth Radio Inc.________ Telephone: _+1 917 385 0195__ 2

U.S. Agent Designation for Service of Process

(Applicant is Both Grantee and U.S. Agent) TO: American Certification Body, Inc. 313 Park Avenue Suite 300 Falls Church, VA 22046 ATTENTION: FCC Certification Section 2.911(d)(7) Information This letter is to confirm that the Applicant will also serve as the U.S. Agent for Service of Process as required by 47 CFR 2.911(d)(7). The Applicant acknowledges that they must maintain an agent for no less than one year after terminating all marketing and importation OR the conclusion of any Commission-related proceeding involving the equipment. The Applicant further acknowledges their responsibility to inform the FCC whenever the Designated U.S. Agent information changes. Beartooth Radio, Inc. | 5 W Mendenhall St. Suite 202 | Bozeman, Montana, 59715 | Telephone +1 917 385 0195 | www.Beartooth.com Applicant Company name: Beartooth Radio, Inc. Grantee Code: 2AJY7 Contact Name: Michael C Monaghan Street Address: 5 W Mendenhall Street Ste 202 City/Province/Zip: Bozeman, Montana 59715 Telephone No: +1 917 385 0195 Email: michael@beartooth.com Michael C. Monaghan President February 13, 2023 2

C2PCRequest Date:October2,2022 ToWhomitmayconcern, BeartoothRadioInc.requestsaclass2permissivechange(C2PC)formoduleFCCID2AJY7011. Inthesubjectproduct,theFCCID2AJY7011moduleiscollocatedwiththeFCCID2AJY7012. Inadditiontocolocation,theproductisoftenusedcloserthan20cmfromtheuser. Testdataisprovidedtodemonstratethat,asusedinthesubjectproduct,bothcolocationandRF exposurerequirementsaremeet.Therefore,thisC2PCissubmittedforapproval. H.StephenBerger RegulatoryRepresentative

A09-HASM-675 DIPOLE RPSMA MALE ALL DIMENSIONS ARE IN INCHES UNLESS OTHERWISE SPECIFIED Date:

05 JAN 04 Revision #:

Part Number:

A09-HASM-675 Drawing Number 1 A09-HASM-675.pdf DO NOT SCALE DRAWINGS FOR DIMENSIONS Property of:

Part Description:

MaxStream, Inc. Lindon, Utah, USA 900 MHZ DIPOLE ANTENNA WITH ARTICULATED RPSMA Drawn By:

Approved By:

The Beartooth MK II uses the XBee Pro SX module, FCC ID MCQ-XBPSX, for its 900 MHz radio. In the XBee-PRO 900 MHz test report, filed as an exhibit in its FCC equipment grant application, the module is reported as limited to an 11% duty cycle. This limitation may be found on page 17 of the FCC report:

The XBEE Modules ship with a default 250 kbps data rate. We do not make any changes to this setting. Hence the MK II operates using the 250 kbps data rate Per the test report we can make the following calculations from this table:

Maximum time on one channel in 10 seconds = 0.021 Maximum time on one channel in 1 seconds = 0.0021 Number of channels = 50 Maximum time transmitting in 1 second = 0.0021 * 50 = .105 Max throughput Duty cycle = .105 / 1s = 11%

This rate set in the XBee-PRO SX module and is the limit for the MK II. Dated: February 16, 2023 Michael C. Monaghan Founder | CEO Beartooth Radio and H. Stephen Berger Regulatory Agent for Beartooth Radio, Inc. 070920-02b

Authority to Act as Agent Date: May 235, 2022 American Certication Body, Inc. 6731 Whittier Avenue Suite C110 McLean, VA 22101 To Whom It May Concern:

______Steve Koster______ is authorized to act on our behalf, until otherwise notied, for applications to American Certication Body, Inc. (ACB). We certify that we are not subject to denial of federal benets, that includes FCC benets, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 862. Further, no party, as dened in 47 CFR 1.2002 (b), to the application is subject to denial of federal benets, that includes FCC benets. We also declare that the information provided to the FCC is true and correct to the best of our knowledge (47 CFR 2.911(d)) and we have been informed of the grantee responsibilities (47 CFR 2.909) with regard to certied equipment. Thank you, Agency Agreement Expiration Date: _____May 23, 2023____ By: __________________________H. Stephen Berger

(Signature) (Print name) Title: ________Regulatory Consultant__________________ On behalf of: _____Beartooth Radio, INC_____________________

(Company Name) Telephone: ____+1 512 864-3365_______________________ Beartooth Radio, Inc. | 5 W Mendenhall St. Suite 202 | Bozeman, Montana, 59715 | Telephone +1 917 385 0195 | www.Beartooth.com

TEM Consulting, LP Memorandum Date:

January 31, 2023 From:

Stephen Berger Phone

(512) 864-3365 Subject: MK II Maximum Duty Cycle This memo describes the testing performed to determine the maximum duty cycle the MK II is capable of. Maximum Duty Cycle The maximum duty cycle was measured at 14.1% while transmitting data at the maximum possible data rate. Once the phones are configured a picture is transmitted from one phone to the other, creating a high rate of data transfer. The MK IIs will be transmitting data at their maximum power as fast as they can transfer data. Data Sources & Loads The MK II can receive data for transmission through three processes:

Transmission of a text message (The source may be a voice message which has been transcribed into a text message.) Transmission of a GPS location Transmission of a picture While all of these require user actions to initiate a transmission by the MK II, the first two result in a small amount of data and so a short transmission. A consequence is that the amount of time required for the user to setup a series of transmissions will dominate the time between each transmission. Transmitting a picture is different from the first two processes in that, which the user must still setup the transmission, the data in a picture file is much greater resulting in the MK II transmitting at its maximum rate of speed until the file has been sent. This is the process used to make the duty cycle measurement reported in this memo. Measurement Overview The balance of this memo gives detailed descriptions of the connection and transmission process. 1 A spectrum analyzer, connected to an antenna, was used to monitor the transmission. The antenna was placed close to the MK II that would be transmitting the picture. Once the transmission started the frame duration and transmission time were measured multiple time. The duty cycle reported is the transmission time divided by the frame duration. As reported above, the maximum duty cycle measured was 14.1%. The balance of this memo describes in detail the setup and measurement process. Connect Phones to MK IIs Power on the 1st phone. At the 1st screen swipe up from the bottom of the screen. The following screen should appear:

Select the ATAK app. The following screen should now be displayed:

2 Select the icon on the top right, the 3 horizonal bars. Scroll through the options until the Beartooth MK II option appears:

Select Beartooth MK II option. Now turn on one of the MK IIs. Its serial number will appear on the screen:

3 Select the MK II and the Pixel 3 XL will connect to it. Now repeat these steps with the other phone and MK II to connect them. Connect Phones On the 2nd phone select the left icon, showing three figures. Several contacts will appear, choose Beartooth Broadcast. This will bring up the next screen:

4

Tap Tap to speak and speak a message. Then hit the send icon to the right of the message:

Hitting the icon with the three figures will bring back the list of contacts. A new contact should be entered, this is the other phone, in this case listed as Knife. The phones are now connected to each other. When sending a picture you will select the other phone individually, in this case selecting Knife as the recipient. 5 Sending a picture Return to the 1st phone. select the right icon, showing three horizontal bars. Scroll down until you reach the Quick Pic option:

This brings up the camera on the right side of the screen. Take a picture. In the example below a picture of a window was taken:

In the group of icons at the bottom left, select the send icon at the right of the group. This will bring up the following screen:

6 Choose Beartooth MK II. This will bring back the list of contacts:

Select the companion device, in this case Knife and select Send at the bottom of the screen. Now, if you swipe from top to bottom a progress screen will appear, showing the progress in transmitting the picture:

7 It should show the percentage transmitted as the picture is sent:

However, it is possible that there will be a problem in the transmission and an error might be reported:

8 In this case, reestablish the connections and try again. 9

RequesttoChangeFCCID Date:June9,2022 ToWhomitmayconcern, BeartoothRadioInc.requestsachangeofIDforthefollowingmoduleusedinitsmodelMKII:

FROM:

TO:

FCCID:

MCQXBPSX GrantDate:

12/22/15 FCCID:

2AJY7011 H.StephenBerger RegulatoryRepresentative

Request for Modular/Limited Modular Approval Date: September 15, 2022 Subject: Manufacturers Declaration for - Modular Approval

- Split Modular Approval

- Limited Modular Approval - Limited Split Modular Approval Confidentiality Request for: ______2AJY7011______ 8 Basic Requirements FCC Part 15.212(a)(1) For Items Marked NO(*), the Limited Module Description Must be Filled Out on the Following Pages Modular Approval Requirement 1. The modular transmitter must have its own RF shielding. This is intended to ensure that the module does not have to rely upon the shielding provided by the device into which it is installed in order for all modular transmitter emissions to comply with FCC limits. It is also intended to prevent coupling between the RF circuitry of the module and any wires or circuits in the device into which the module is installed. Such coupling may result in non-compliant operation. The physical crystal and tuning capacitors may be located external to the shielded radio elements. 15.212(a)(1)(i) Requirement Met

- YES - NO(*) Details: <example The module contains a metal shield which covers all RF components and circuitry. The shield is located on the top of the board next to antenna connector>

2. The modular transmitter must have buffered modulation/data inputs (if such inputs are provided) to ensure that the module will comply with FCC requirements under conditions of excessive data rates or over-modulation. 15.212(a)(1)(ii)

- YES - NO(*) Details: <example Data to the modulation circuit is buffered as described in the operational description provided with the application>

3. The modular transmitter must have its own power supply regulation on the module. This is intended to ensure that the module will comply with FCC requirements regardless of the design of the power supplying circuitry in the device into which the module is installed. 15.212(a)(1)(iii)

- YES - NO(*) Details: <example The module contains its own power supply regulation. Please refer to schematic filed with this application>

4. The modular transmitter must comply with the antenna and transmission system requirements of 15.203, 15.204(b), 15.204(c), 15.212(a), and 2.929(b). The antenna must either be permanently attached or employ a unique antenna coupler (at all connections between the module and the antenna, including the cable). The professional installation provision of 15.203 is not applicable to modules but can apply to limited modular approvals under paragraph 15.212(b). 15.212(a)(1)(iv)

- YES - NO(*) Details: <example The module connects to its antenna using an UFL connector which is considered a non-standard connector. A list of antennas tested and approved with this device may be found in users manual provided with the application>

5. The modular transmitter must be tested in a stand-alone configuration, i.e., the module must not be inside another device during testing. This is intended to demonstrate that the module is capable of complying with Part 15 emission limits regardless of the device into which it is eventually installed. Unless the transmitter module will be battery powered, it must comply with the AC line conducted requirements found in Section 15.207. AC or DC power lines and data input/output lines connected to the module must not contain ferrites, unless they will be marketed with the module (see Section 15.27(a)). The length of these lines shall be length typical of actual use or, if that length is unknown, at least 10 centimeters to insure that there is no coupling between the case of the module and supporting equipment. Any accessories, peripherals, or support equipment connected to the module during testing shall be unmodified or commercially available (see Section 15.31(i)). 15.212(a)(1)(v)

- YES - NO(*) Details: <example The module was tested stand-alone as shown in test setup photographs filed with this application>

070920-02b Modular Approval Requirement 6. The modular transmitter must be labeled with its own FCC ID number, or use an electron display Requirement Met

(see KDB Publication 784748). If using a permanently affixed label with its own FCC ID number, if the FCC ID is not visible when the module is installed inside another device, then the outside of the device into which the module is installed must also display a label referring to the enclosed module. This exterior label can use wording such as the following: Contains Transmitter Module FCC ID: XYZMODEL1 or Contains FCC ID: XYZMODEL1. Any similar wording that expresses the same meaning may be used. The Grantee may either provide such a label, an example of which must be included in the application for equipment authorization, or, must provide adequate instructions along with the module which explain this requirement. In the latter case, a copy of these instructions must be included in the application for equipment authorization. If the modular transmitter uses an electronic display of the FCC identification number, the information must be readily accessible and visible on the modular transmitter or on the device in which it is installed. If the module is installed inside another device, then the outside of the device into which the module is installed must display a label referring to the enclosed module. This exterior label can use wording such as the following: Contains FCC certified transmitter module(s). Any similar wording that expresses the same meaning may be used. The user manual must include instructions on how to access the electronic display. A copy of these instructions must be included in the application for equipment authorization. 15.212(a)(1)(vi)

- YES - NO(*) Details: <example There is a label on the module as shown in the labeling exhibit filed with this application. Host specific labeling instructions are shown in the installation manual .filed with this application.>

7. The modular transmitter must comply with all specific rule or operating requirements applicable to the transmitter, including all the conditions provided in the integration instructions by the grantee. A copy of these instructions must be included in the application for equipment authorization. For example, there are very strict operational and timing requirements that must be met before a transmitter is authorized for operation under Section 15.231. For instance, data transmission is prohibited, except for operation under Section 15.231(e), in which case there are separate field strength level and timing requirements. Compliance with these requirements must be assured. 15.212(a)(1)(vii)

- YES - NO(*) Details: <example The module complies with FCC Part 15C requirements. Instructions to the OEM installer are provided in the installation manual filed with this application.>

8. The modular transmitter must comply with any applicable RF exposure requirements. For example, FCC Rules in Sections 2.1091, 2.1093 and specific Sections of Part 15, including 15.319(i), 15.407(f), 15.253(f) and 15.255(g), require that Unlicensed PCS, UNII and millimeter wave devices perform routine environmental evaluation for RF Exposure to demonstrate compliance. In addition, spread spectrum transmitters operating under Section 15.247 are required to address RF Exposure compliance in accordance with Section 15.247(b)(4). Modular transmitters approved under other Sections of Part 15, when necessary, may also need to address certain RF Exposure concerns, typically by providing specific installation and operating instructions for users, installers and other interested parties to ensure compliance. 15.212(a)(1)(viii)

- YES - NO(*) Details: <example The module meets Portable exclusion levels as shown in the RF exposure information filed with this application.>

070920-02b Limited Module Description When Applicable

* If a module does NOT meet one or more of the above 8 requirements, the applicant may request Limited Modular Approval (LMA). This Limited Modular Approval (LMA) is applied with the understanding that the applicant will demonstrate and will retain control over the final installation of the device, such that compliance of the end product is always assured. The operating condition(s) for the LMA; the module is only approved for use when installed in devices produced by grantee. A description regarding how control of the end product, into which the module will be installed, will be maintained by the applicant/manufacturer, such that full compliance of the end product is always ensured should be provided here. Details: <example - N/A>

Software Considerations KDB 594280 / KDB 442812 (One of the following 2 items must be applied) Requirement Requirement Met 1. For non-Software Defined Radio transmitter modules where software is used to ensure compliance of the device, technical description must be provided about how such control is implemented to ensure prevention of third-party modification; see KDB Publication 594280.

- Provided in Separate Cover Letter

- N/A Details: <example The firmware of the device can not be modified or adjusted by the end user as described in a separate cover letter filed with this application. >

2. For Software Defined Radio (SDR) devices, transmitter module applications must provide a software security description; see KDB Publication 442812.

- Provided in Separate Cover Letter

- N/A Details: <example N/A>

Split Modular Requirements Requirement Provided in Manual 1. For split modular transmitters, specific descriptions for secure communications between front-end and control sections, including authentication and restrictions on third-party modifications; also, instructions to third-party integrators on how control is maintained.

- Provided in Separate Cover Letter

- N/A Details: <example N/A >

070920-02b OEM Integration Manual Guidance KDB 996369 D03 Section 2 Clear and Specific Instructions Describing the Conditions, Limitations, and Procedures for third-parties to use and/or integrate the module into a host device. Requirement Is this module intended for sale to third parties?

- YES

- No, If No, and LMA applies, the applicant can optionally choose to not make the following detailed info public. However there still needs to be basic integration instructions for a users manual and the information below must still be included in the operational description. If the applicant wishes to keep this info confidential, this will require a separate statement cover letter explaining the module is not for sale to third parties and that integration instructions are internal confidential documents. Items required to be in the manual See KDB 996369 D03, Section 2 As of May 1, 2019, the FCC requires ALL the following information to be in the installation manual. Modular transmitter applicants should include information in their instructions for all these items indicating clearly when they are not applicable. For example information on trace antenna design could indicate Not Applicable. Also if a module is limited to only a grantees own products and not intended for sale to third parties, the user instructions may not need to be detailed and the following items can be placed in the operational description, but this should include a cover letter as cited above. 1. List of applicable FCC rules. KDB 996369 D03, Section 2.2 a. Only list rules related to the transmitter. 2. Summarize the specific operational use conditions. KDB 996369 D03, Section 2.3 a. Conditions such as limits on antennas, cable loss, reduction of power for point to point 3. Limited Module Procedures. KDB 996369 D03, Section 2.4 systems, professional installation info a. Describe alternative means that the grantee uses to verify the host meets the necessary limiting conditions b. When RF exposure evaluation is necessary, state how control will be maintained such that compliance is ensured, such as Class II for new hosts, etc. 4. Trace antenna designs. KDB 996369 D03, Section 2.5 a. Layout of trace design, parts list, antenna, connectors, isolation requirements, tests for design verification, and production test procedures for ensuring compliance. If confidential, the method used to keep confidential must be identified and information provided in the operational description. 5. RF exposure considerations. KDB 996369 D03, Section 2.6 a. Clearly and explicitly state conditions that allow host manufacturers to use the module. Two types of instructions are necessary: first to the host manufacturer to define conditions (mobile, portable xx cm from body) and second additional text needed to be provided to the end user in the host product manuals. 6. Antennas. KDB 996369 D03, Section 2.7 a. List of antennas included in the application and all applicable professional installer instructions when applicable. The antenna list shall also identify the antenna types

(monopole, PIFA, dipole, etc note that omni-directional is not considered a type) 7. Label and compliance information. KDB 996369 D03, Section 2.8 a. Advice to host integrators that they need to provide a physical or e-label stating Contains FCC ID: with their finished product 8. Information on test modes and additional testing requirements. KDB 996369 D03, Section 2.9 a. Test modes that should be taken into consideration by host integrators including clarifications necessary for stand-alone and simultaneous configurations. b. Provide information on how to configure test modes for evaluation 9. Additional testing, Part 15 Subpart B disclaimer. KDB 996369 D03, Section 2.10

- All Items shown to the left are provided in the Modular Integration Guide (or UM) for Full Modular Approval

(MA) or LMA.

- An LMA applies and is approved ONLY for use by the grantee in their own products, and not intended for sale to 3rd parties as provided in a separate cover letter. Therefore the information shown to the left is found in the theory of operation. Dated: September 15, 2022 H. Stephen Berger Regulatory Agent for Beartooth Radio, Inc. Signed by:

070920-02b

Date: May 2, 2022 Federal Communications Commission 7345 Oakland Mills Road Columbia MD 21046 Subject:

Reference: FCC ID: MCQ-XBPSX Authorization of Change in Identification To whom this may concern:

This letter grants authorization for representatives of:

Beartooth Radio INC 5 W Mendenhall STE 202 Bozeman MT 59715 To apply for a change in identification as specified under 47CFR 2.933(b) of the FCC rules. Applicant FCC ID: 2AJY7011 The original identification for the Digi International module is FCC ID: MCQ-XBPSX The original grant date is: 12/22/2015 Erik Reynolds Director of Engineering erik.reynolds@digi.com

+1 (952) 912-4248