FCC ID: E2K-QCNCM825 WiFi 7/BT Combo module

PROPOSED FCC ID LABEL AND LOCATION QUALCOMM TECHNOLOGIES, INC. FCC ID:E2K-QCNCM825 1C:1514B-QCNCM825 Model: QCNCM825 Top of EUT FCC/IC Label Location

(on Shielding cover)

Date: December 25, 2023 FCC Laboratory 7435 Oakland Mills Rd Columbia MD 21046 To whom it may concern, This Change of Identification request applies for a new FCC ID as established in 47 CFR 2.933 for a currently approved device. This application by Dell Inc. will establish a new FCC ID: E2K-QCNCM825 under Dell Inc. grantee code for the purpose of marketing. The original grant to Qualcomm Technologies, Inc. will remain in effect. Per 2.933(b) 1. The original identification is J9C-QCNCM825. 2. The original grant date is 08/27/2023. 3. The equipment is electrically identical. Only the trade name, and FCC ID number are different. 4. The original test results continue to be representative of and applicable to the equipment bearing the changed identification. 5. Exterior photographs are included in this application. The following files are electronically submitted as attachments:

s s s Cover Letter External Photos FCC ID label format and location Should there be any question, please feel free to contact us. Sincerely yours, William Wei Regulatory Compliance Engineering Email: William.Wei@dell.com

Date: December 25, 2023 FCC Laboratory 7435 Oakland Mills Rd Columbia MD 21046 Subject: Request for Confidentiality FCC ID: E2K-QCNCM825 To Whom It May Concern, Pursuant to the provisions of Sections 0.457 and 0.459 of Commissions rules (47CFR0.457, 0.459), we are requesting the Commission to withhold the following attachment(s) as confidential document from public disclosure indefinitely. l Operational description Above mentioned document contains detailed system and equipment description are considered as proprietary information in operation of the equipment. The public disclosure of above documents might be harmful to our company and would give competitor an unfair advantage in the market. In additional to above mentioned documents, pursuant to Public Notice DA 04-1705 of the Commission s policy, in order to comply with the marketing regulations in 47 CFT 2.803 and the importation rules in 47 CFR 2.1204, while ensuring that business sensitive information remains confidential until the actual marketing of newly authorized devices. We are requesting the commission to grant short-term confidentiality request on the following attachment(s). For the short term confidential release date, please refer to application form. l External Photos It is our understanding that all measurement test reports, FCC ID label format and correspondent during certification review process cannot be granted as confidential documents and those information will be available for public review once the grant of equipment authorization is issued. Best Regards, ______________________ William Wei Regulatory Compliance Engineering Email: William.Wei@dell.com

Request for Modular Approval for FCC ID: E2K-QCNCM825 Date: December 25, 2023 Item Requirements EUT 1. 2. 3. 4. The modular transmitter must have its own The radio portion of this module has been shielded, RF shielding. please see exhibition External Photo. The modular transmitter must have buffered The EUT has buffered data inputs, it is integrated in modulation / data inputs. chip WCN7851. The modular transmitter must have its own The part number of this regulator is WCN7851. power supply regulation. The module must contain a permanently The EUT meets the FCC antenna requirements. The attached antenna, or contain a unique spurious emission, unique antenna connector and antenna connector, and be marketed and photo of antennas are shown in the test report. operated only with specific antenna(s), 5. The modular transmitter must be tested in a The EUT was tested in a stand-alone configuration stand-alone configuration. via an ExpressCard connector. Please see section Photographs of Test Configuration in the test report, the EUT was plugged in this extender. 6. The modular transmitter must be labeled Please see exhibition Label Sample for the FCC ID with its own FCC ID number. of this module. And also in the exhibition User's Manual, there are instructions give to the OEM on how to label the end product. 7. The modular transmitter must comply with The EUT is compliant with all applicable FCC any specific rule or operating requirements rules. Detail instructions for maintaining applicable to the transmitter and the compliance are given in the User's Manual. manufacturer must provide adequate instructions along with the module to explain any such requirements. 8. The modular transmitter must comply with The EUT is compliant with all applicable RF any applicable RF exposure requirement. exposure requirements. RF Exposure is addressed in the RF exposure exhibition. ______________________ William Wei Regulatory Compliance Engineering Email: William.Wei@dell.com

December 25, 2023 Attestation We, Dell Inc., attest that this device under FCC ID: E2K-QCNCM825 complies with device protocol requirements and operational restrictions for Client Devices. a) This device will only associate and connect with an indoor access point or subordinate device and never directly connects to other client devices. b) Client devices must be under control of an U-NII-4, Indoor access point or subordinate device. c) d) Clients shall passively scan to associate with access point or subordinate. Clients are permitted to initiate a brief probe message requesting to join and associated with a specific Access Point or Subordinate. e) Clients cannot have a direct connection to the internet to source the internet to other clients, access points, subordinates or clients from a wired or direct connection. __________________ William Wei Regulatory Compliance Engineering Email: William.Wei@dell.com

December 25, 2023 Attestation We, Dell Inc., attest the followings for our device FCC ID: E2K-QCNCM825. a. this device will only associate and connect with a low-power indoor Access Point, subordinate device, or standard access point and never directly link to any other client devices b. this device will always initiate transmission under the control of a low power indoor AP or subordinate or standard client except access point for brief communications before joining a network. These quick messages will only occur if the client has detected an indoor AP, subordinate, or standard access point operating on a channel. These brief messages will have a time-out mechanism such that if it does not receive a response from an AP it will not continually repeat the request. c. this device, when associated and connected with a low-power indoor access point, subordinate or standard access point device, will operate at a power lower as advertised by the indoor access point, subordinate, or standard access point:

i. lower than or equal to the power advertised by the low-power indoor access point or subordinate and never above the maximum output power allowed by the FCC grant for clients associated with indoor clients or subordinates. ii. lower than or 6 dB below the power advertised by the standard access point. d. Contention-based protocol as demonstrated in the test report is permanently embedded in the module and is not host-dependent based protocol demonstrated in the test report. e. We acknowledge this device is subject to and in full compliance with the device restrictions listed below. All users are notified of these restrictions through the user manual. Prohibited for control of or communications with unmanned aircraft systems, including drones. __________________ William Wei Regulatory Compliance Engineering Email: William.Wei@dell.com

Date: December 25, 2023 To whom it may concern, Please be notified that I, William Wei, have designated Jones Tsai in Sporton International Inc. as the person being responsible for this project and to sign the form 731 and other documentation. Any and all acts carried out by Jones Tsai in Sporton International Inc. on the matters of relating to all processes required in the FCC approval and any communication needed with the national authority, shall have the same legal authority as acts on our own behalf. We further certify that neither the applicant nor any party to this application, as defined in 47 CFR Ch. 1.2002 (b), is subject to a denial to Federal benefits, that include FCC benefits, pursuant to section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 862. This authorization is limited to the product of as following:

FCC ID: E2K-QCNCM825 If you have any acknowledgement and response, please send it to Sporton International Inc. directly. Sincerely yours, William Wei Regulatory Compliance Engineering Email: William.Wei@dell.com

Qualcomm Technologies, Inc. 5775 Morehouse Drive, San Diego, CA 92121 www.qualcomm.com Tuesday, March 14, 2023 Federal Communications Commission 7435 Oakland Mills Road Columbia MD 21046 Subject: Authorization of Handling FCC Regulatory Applications FCC Grantee Code J9C To Whom It May Concern:

I, hereby, authorize Mr. Stanley Lin, to handle FCC Regulatory related applications for Qualcomm Technologies, Inc. FCC Grantee Code J9C and sign all required application documents. Best Regards, ________________________ Paul Guckian Qualcomm Technologies, Inc. VP, Engineering, EMC-Regulatory pguckian@qti.qualcomm.com

WARNING:pdfminer.pdfpage:The PDF <_io.BufferedReader name='/Volumes/Scratch/Incoming/eg-scratch/6363515.pdf'> contains a metadata field indicating that it should not allow text extraction. Ignoring this field and proceeding. Use the check_extractable if you want to raise an error in this case Dell Inc. MS: PS4-30 One Dell Way Round Rock, Texas 78682 www.dell.com Don Bobo Distingished Member of Technical Staff EMC, Global Regulations and Standards Telephone 512.593.8560 e-mail don.bobo@dell.com Worldwide Regulatory Compliance Engineering & Environmental Affairs Federal Communication Commission Equipment Authorization Division, Application Processing Branch 7435 Oakland Mills Road Columbia, MD 21048 January 9, 2023 FCC authorization letter for Dell Regulatory employees To whom it may concern, I, the undersigned, as the authorized signatory for the Dell Inc. grantee code E2K, hereby authorize the following EMC & Wireless Regulatory Engineers of Dell Inc., to act on my behalf in all manners relating to processes required according to FCC rules for equipment authorization:

Bill Wang April Chang Fiona Y Chen Kay Chen Yan Papernov Jessie Goh Jack TS Huang Tommy Hwang Nai Ghee Koh Jason KP Lee Jason Limoges Leonel Lopez James V Nguyen Rex Wan William Wei Steve L Williams Julie Shen Leo Hong Dyllan Chang Ken Tai CY Chang Jessie Lin Greg Hsiao Chloe Lin Brad Chen This authorization shall be sent along with application when filing with the FCC Certification Division and is valid until further written notice from the applicant. If you have any questions or need additional information, please feel free to contact me at 512-593-8560 or 512-619-7976. Sincerely, Don Bobo, Dell Inc., FRN: 0008359580 Internal Use - Confidential

Qualcomm Technologies, Inc. 5775 Morehouse Drive, San Diego, CA 92121-1714 www.qualcomm.com Date: December 26, 2023 FCC Laboratory 7435 Oakland Mills Rd Columbia MD 21046 To whom it may concern, This letter grants authorization for representatives of Dell Inc. to apply to the FCC for a change in identification as specified under 47 CFR 2.933 of the FCC rules. This authorization applies to Qualcomm WiFi 7/BT Combo module FCC ID: J9C-QCNCM825, original grant date 08/27/2023. We are aware that Dell Inc. intends to market the above referred product under FCC ID: E2K-QCNCM825. The original test results continue to be representative of and applicable to the equipment bearing the changed identification. Should there be any question, please feel free to contact us. Sincerely yours, _______________________________ Stanley Lin/Wireless Regulatory, Staff Qualcomm Technologies, Inc. slin@qti.qualcomm.com

Global Regulatory Compliance E Federal Communications Commission Office of Engineering and Technology Equipment Authorization and Evaluation Division 7435 Oakland Mills Road Columbia MD 21046 ATTN: Reviewing Engineer Subject: Agent Appointment & Attestation Statement FCC ID: E2K-QCNCM825 Reference: a) FCC CFR 2.911(d)(5)(i) b) FCC CFR 2.911(d)(5)(ii) c) FCC CFR 2.911(d)(7) a) DELL Inc. (the applicant) certifies that the equi Covered equipment prohibited from receiving Title 47;

b) DELL Inc. (the applicant) certifies that, as of th not identified on the Covered List pursuant to affiliate of a specifically named entity) producing c) DELL Inc. (the applicant) hereby accepts and di engineering & Environmental Affairs Date: 2023/11/3 pment for which authorization is sought is not an equipment authorization pursuant to 2.903 of CFR 2 date of the filing of the application, the applicant is 1.50002 of CFR Title 47, as an entity (nor a subsidiary or Covered equipment;

2signates the following agent for service of process in the United States for matters related to the appl maintain the designated agent for service of pro:

either the grantee has permanently terminated ;

equipment within the U.S., or upon the conclusic proceedings involving the equipment, whichever Agent Designation:

Company name: DELL Inc. Street Address: One Dell Way City/Province/Zip: Round Rock, TX 78682, USA Contact Name: Don Bobo Telephone No: +1 (512) 593 8560 Email: don_bobo@dell.com FRN: 0008359580 Signature of Designated Agent/Applicant:

#7:

KA Printed name: Don Bobo Title: Distinguished Member Technical Staff RQFO401 icable equipment and accepts the obligation to cess in the United States for no less than one year after all marketing and importation of the applicable yn of any Commission related administrative or judicial is the latter.