FCC ID: IPH-03804 Low power data transceiver

January 10, 2022 SENT VIA EMAIL Federal Communications Commission (FCC) c/o CETECOM Inc., 411 Dixon Landing Road, Milpitas, CA 95035 (James Donnellan) Authorization and Evaluation Division 1435 Oakland Mills Road Columbia, MD 21046 email: James.Donnellan@cetecom.com Re: Request for Dismissal Without Prejudice FCC IDs: IPH-03804 Equipment Class: Part 15(c) Low Power Communication Device To whom it may concern:

Pursuant to 47 C.F.R. 1.934(a)(1)(ii), Garmin International, Inc. (the Applicant) hereby requests that the Federal Communications Commission (the FCC) dismiss without prejudice FCC IDs IPH-03804. Information on the grants associated with each FCC ID subject to this Request for Dismissal Without Prejudice is provided in the table below. FCC ID TC Number(s) IPH-03804 TC706741 TC755762 TC762775 Grant Date 7/28/2021 Applicant represents and warrants that no product has been placed on the market, offered for sale, sold domestically or internationally or imported for use other than as permitted by 47 C.F.R. 2.1204 under the aforementioned FCC ID: IPH-03804. As Applicant has determined that the applications associated with FCC ID: IPH-03804 require further evaluation regarding their modes of operation, Applicant is preparing materials for submission as soon as practicable and intends to re-use these FCC IDs. Therefore, Applicant respectfully requests that this Request for Dismissal Without Prejudice be considered without delay. Should you have any questions related to this matter, please contact me for additional information. Best regards, Chris Strauss Team Leader Compliance Engineering Garmin International, Inc. 1200 E. 151st Street Olathe, Kansas 66062 chris.Strauss@garmin.com

Letter of Authorization and Anti‐Drug Statement 

Applicant Name: Garmin International, Inc. 

Address: 1200 East 151st Street, Olathe, KS 66062 

Product Name: A03804 

Model Number: A03804 

FCC ID: IPH‐03804 

We authorize: 

CETECOM Inc., to act on our behalf on all matters concerning the above named equipment.  

We declare that CETECOM Inc. is allowed to forward all information related to the approval project to 

the Federal Communications Commission and discuss any issues concerning the approval application. 

The applicant must certify that neither the applicant nor any party to the application is subject to

a denial of Federal benefits, that include FCC benefits, pursuant to Section 5301 of the Anti-Drug

Abuse Act of 1988, 21 U.S.C. § 862 because of a conviction for possession or distribution of a

controlled substance. See 47 CFR 1.2002(b) for the definition of a "party" for these purposes.

Does the applicant or authorized agent so certify? ☒ Yes

I certify that I am authorized to sign this application. All of the statements herein and the

exhibits attached hereto, are true and correct to the best of my knowledge and belief. In

accepting a Grant of Equipment Authorization as a result of the representations made in this

application, the applicant is responsible for (1) labeling the equipment with the exact FCC ID

specified in this application, (2) compliance statement labeling pursuant to the applicable rules,

and (3) compliance of the equipment with the applicable technical rules. If the applicant is not

the actual manufacturer of the equipment, appropriate arrangements have been made with the

manufacturer to ensure that production units of this equipment will continue to comply with the

FCC's technical requirements.

Authorizing an agent to sign this application, is done solely at the applicant's discretion;

however, the applicant remains responsible for all statements in this application.

If an agent has signed this application on behalf of the applicant, a written letter of authorization

which includes information to enable the agent to respond to the above section 5301 (Anti-Drug

Abuse) Certification statement has been provided by the applicant. It is understood that the

letter of authorization must be submitted to the FCC upon request, and that the FCC reserves the

right to contact the applicant directly at any time.

Signature of Authorized Person Filing:

Title: Associate General Counsel – Employment

& Regulatory Affairs

Date: June 21, 2021

Garmin International, Inc. A GARMIN. | 2002 P: 913-397-8200 F: 913-397-8282 Federal Communications Commission Equipment Authorization Division 7435 Oakland Mills Road Columbia, MD 21048 Date: July 6, 2021 Subject: Request for Permanent Confidentiality FCC ID: IPH-03804 To Whom It May Concern:

In accordance with 0.457(d) and 0.459 of CFR 47, and KDB 726920, Garmin International, Inc. hereby requests permanent confidentiality for documents filed under the following exhibit types:

Block Diagram Schematic Diagram Operational Description Parts List pwn Pp These items contain detailed system and equipment description and related information about the product which Garmin international, Inc. considers to be proprietary, confidential and a custom design which otherwise would not be released to the general public. Since this design is a basis from which future technological products will evolve, Garmin international, Inc. also feels that this information would be of benefit to its competitors, and that the disclosure of the information in these exhibits would give our competitors an unfair advantage in the market. We are aware that exhibit types cover letters, attestations, label document, test reports, RF exposure information (SAR and MPE reports), cannot be requested to be classified confidential and are thus subject to publication, as will be documents of all other exhibits types for which we have not requested a confidentiality classification. Best Regards, Signature Name: David Utt Title: Staff Compliance Engineer Company Name: Garmin International Address: 1200 East 151st Street, Olathe, KS 66062

Federal Communications Commission

Equipment Authorization Division

7435 Oakland Mills Road

Columbia, MD 21048

Date:

June 11, 2021

Subject:

To Whom It May Concern:

Request for Short Term Confidentiality

FCC ID: IPH‐03804

In accordance with §0.457(d) and §0.459 of CFR 47,

permanent confidentiality for documents filed under the following exhibit types:

hereby requests

Garmin International, Inc.

1. External Photographs

2.

Internal Photographs

3. User / Instruction Manuals

4. Test Set-up Photographs

until the product will be publicly announced.

These items contain detailed system and equipment description and related information

Short tern confidentiality release date / period: 180 days from grant issue date

about the product which Garmin international, Inc. considers to be proprietary, confidential

and a custom design which otherwise would not be released to the general public. Since this

design is a basis from which future technological products will evolve, Garmin international, Inc.

also feels that this information would be of benefit to its competitors, and that the

disclosure of the information in these exhibits would give our competitors an unfair advantage

in the market.

We are informed and aware of our obligation that we have to inform the involved TCB in writing

and in due time if we intend to market the product prior to the above specified confidentiality

release date so that the short-term confidentiality classification can be removed in accordance

We are aware that exhibit types cover letters, attestations, label document, test reports,

with §0.457(d) and §0.459 of CFR 47.

RF exposure information (SAR and MPE reports), cannot be requested to be classified confidential

and are thus subject to publication, as will be documents of all other exhibits types for which we

have not requested a confidentiality classification.

Best Regards,

Signature

Name: D

Title: S

Company Name: Garmin International

Address: 1200 East 151st Street, Olathe, KS 66062

Compliance Engineer

avid Utt

taff

Subject: Validity of Test Results from Testing / Certification of the Integrated Module To Whom It May Concern:

We, Garmin International, Inc., 1200 E 151st Street, Olathe, KS 66062, due hereby declare that that the test results from conducted tests applied to the radio module:

Manufacturer: Murata Model: LBADOXX1SC FCC ID: HSW-TY1SC IC: 4492A-TY1SC which is incorporated in our host equipment:

Manufacturer: Garmin International, Inc Model: A03804 FCC ID: IPH-03804 IC: 1792A-03804 and as reported in module test report(s):

Report Number: 103652106LEX-007, Issue Date: 05/13/2019 Cellular accurately represent the test results under the new conditions when the identified radio module is integrated in the identified host equipment. By integration of the said radio module into the identified host equipment no changes were made to it or by external adaptation circuitry that impacts the validity of the results of the original modules test reports; hence conducted signal measurements in the above listed reports also apply to Product/Model:

A03804. Sincerely, ME mw Jay Everett, Team Lead - System Validation