ROGERS LABS, INC. 4405 West 259th Terrace Louisburg, KS 66053 913 837-3214 December 2, 2019 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-03309 Product: Transmitter operated under 47CFR paragraph 87 Dear Sirs:
Garmin International, Inc. requests that the material in the Block Diagram, Operational Description, Parts List, Schematics, and Tune Up Procedure be withheld from public disclosure pursuant to Sections 0.457 and 0.459 of the Commissions Rules following grant of the application. In support of this request, Garmin International, Inc. submits the following information. File Exhibit Block Diagram GMN02002 TNB Conf BlkDia.pdf Operational Description GMN02002 TNB Conf OpDes.pdf Parts List Schematics Tune Up Procedure GMN02002 TNB Conf PartsList.pdf GMN02002 TNB Conf Schem.pdf GMN02002 TNB Conf TunPro.pdf 1. Identification of the specific information for which confidential treatment is sought:
The materials set forth in the Block Diagram, Operational Description, Parts List, Schematics and Tune Procedure 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-03309 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, parts list, schematic, and tune procedure. 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