FCC ID: 2BBDZ166-53-05NC-E GroundSense 166-53-05NC-E

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Label Location Company Name: GPR, Inc. Address:

444 Somerville Ave Somerville, MA 02143 Model: 166-53-05NC-E FCC ID: 2BBDZ166-53-05NC-E IC ID: 31259-1665305NCE ID Label:

The statement shall be shown in its User Manual:

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. FCC/IC ID Label Location:

ID Label

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Agency Authorization I herewith authorize Wei Li, Senior Manager Advanced Compliance Laboratory Inc. Hillsborough, NJ 08844 USA To act on our behalf in all matters relating to the application for authorization of the equipment Name: GroundSense Model: 166-53-05NC-E FCC: 2BBDZ166-53-05NC-E IC: 31259-1665305NCE At the Federal Communications Commission (FCC) and Industry Canada (IC) and according to the applicable FCC and IC rule parts. We confirm that we are aware of the responsibilities of applicants / grantees related to the authorization of the identified equipment, including those applying for the period after the authorization has been granted and that those responsibilities still reside with us. by / on:

(signature / date)

(print name) Title:

__________________________ on behalf of: __________________________

(company name) Telephone & Email: __________________________ Moran David3/27/2024CEOGPR, Inc.moran@gpr.com 617-902-0318

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 CFR 47 2.911 (d)(7) Agent Designation Attestation Date: 3/27/2024 FCC ID: 2BBDZ166-53-05NC-E FRN: 0027311752 To: Federal Communications Commission 7435 Oakland Mills Road Columbia, MD 21046 USA GPR, Inc. (the applicant) with FRN: 0027311752 as required by section 2.911(d)(7), will also serve as the agent for service of process for the above referenced FCC ID. The applicant acknowledges that they will maintain an agent for no less than one year after the grantee has terminated 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 agent information changes. Sincerely yours, __________________ Moran David CEO GPR, Inc. 444 Somerville Ave Somerville, MA 02143 moran@gpr.com

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 USA Date: 3/27/2024 Ref: Attestation Statements Part 2.911(d)(5)(i) Filing FCC ID: 2BBDZ166-53-05NC-E To Whom It May Concern:

GPR Inc. (the applicant) certifies that the equipment for which authorization is sought is not covered equipment prohibited from receiving an equipment authorization pursuant to section 2.903 of the FCC rules. Sincerely, __________________ Moran David CEO GPR, Inc. 444 Somerville Ave Somerville, MA 02143 moran@gpr.com

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 USA Date: 3/27/2024 Ref: Attestation Statements Part 2.911(d)(5)(ii) Filing FCC ID: 2BBDZ166-53-05NC-E GPR Inc. (the applicant) certifies that, as of the date of the filing of the application, the applicant is not identified on the Covered List (as a specifically named entity or any of its subsidiaries or affiliates) as an entity producing covered equipment. Sincerely, __________________ Moran David CEO GPR, Inc. 444 Somerville Ave Somerville, MA 02143 moran@gpr.com

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Confidentiality Letter Internal Photos Date: 3/27/2024 Applicant Name: GPR, Inc. Applicant FRN:

Address:

0027311752 444 Somerville Ave Somerville, MA 02143 FCC ID: 2BBDZ166-53-05NC-E IC ID: 31259-1665305NCE To Whom It May Concern:

The internal photographs submitted with this application are the same as was EMI tested. Regards, __________________ Moran David CEO GPR, Inc. 444 Somerville Ave Somerville, MA 02143 moran@gpr.com 617.902.0318

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Confidentiality Letter Internal Photos Date: 3/27/2024 FCC ID: 2BBDZ166-53-05NC-E IC ID: 31259-1665305NCE To Whom It May Concern:

The above-referenced application, filed by GPR, Inc., seeks certification for a ground-

penetrating radar (GPR) device. The application shows compliance with the Bureau's Rules and waiver orders DA 23-1041 and DA 23-1109. We request that certain photographs showing the interior of the devices be withheld from public disclosure. FACTUAL BASIS FOR CONFIDENTIALITY REQUEST Ordinarily the Bureau denies confidentiality to photographs of a device on the grounds that the information they contain is freely available to a competitor, simply by purchasing the device and (if necessary) unscrewing the cover. The device in question is different. The interior is sealed, and its internal appearance is inaccessible to the purchaser. To gain access to the views shown in the interior photographs, a competitor would have to purchase the device and then carry out the following steps:

1. Remove all the tamper proof screws securing the cover to the rest of the enclosure. 2. With the custom antenna enclosure open the various electronic assemblies must be dissembled in a careful and properly ordered manner using enhanced ESD precautions to prevent irreversible damage to the components. 3. RF absorbers are incorporated into the enclosures of the transmitter elements. These absorbers possess distinct electrical properties and function optimally only when arranged according to the specific design. It is improbable that a competitor would possess access to the correct material or be aware of the appropriate material grade and orientations needed for effective installation. GPR, Inc. has never released instructions on how to disassemble its units and does not answer questions on how to do so. This information is kept internal to the company. If a unit arrives at the company's repair facility showing evidence of such tampering, the company does not repair it, but charges the customer for a new unit plus freight costs. 444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 The Bureau's publication of the images enables a competitor to circumvent the challenging and costly disassembly process. Through these photographs, a competitor can assess:

1. The expenses associated with manufacturing the printed circuit boards and 2. The labor hours needed for assembling the device. 3. Potential compatibility issues the manufacturer may encounter when developing new mechanical housing. systems. 4. The age of the electronic design, providing valuable competitive insights into upgrade and research and development (R&D) efforts. Allowing competitors access to interior photographs would essentially enable them to reverse engineer the product completely, even to the extent of generating a schematic. We respectfully argue against the notion that manufacturers should be obligated to provide competitors with the results of extensive and costly engineering efforts. Regards, __________________ Moran David CEO GPR, Inc. 444 Somerville Ave Somerville, MA 02143 moran@gpr.com

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Letter of Authorization and Anti- Drug Statement Applicant Name: GPR Inc. Address: 444 Somerville Ave, Somerville, MA 02143, USA Product Name: GroundSense Model Number: 166-53-05NC-E FCC ID: 2BBDZ166-53-05NC-E We authorize:

Advanced Compliance Laboratory Inc., to act on our behalf on all matters concerning the above named equipment. We declare that Advanced Compliance Laboratory 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:

Date:

CEO3/27/2024

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Company Name: GPR Inc. Address:

444 Somerville Ave Somerville, MA 02143 Model: 166-53-05NC-E FCC: 2BBDZ166-53-05NC-E IC: 31259-1665305NCE Declaration of Label Permanency In accordance with Title 47 Part 2.925 of the Federal Communications Commission

(FCC) regulations. The label is permanently affixed to the equipment and is indelibly printed or otherwise permanently marked on a permanently attached part of the equipment or on a nameplate of metal, plastic, or other material that is fastened to the equipment with a permanent adhesive. The nameplate is able to last the expected lifetime of the equipment in the environment in which it will be operated and is not readily detachable. Signature: __________________________ Moran David CEO GPR, Inc. 444 Somerville Ave Somerville, MA 02143 moran@gpr.com

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Federal Communications Commission Equipment Authorization Division 7435 Oakland Mills Road Columbia, MD 21048 Date: 3/27/2024 Subject:

Request for Permanent Confidentiality FCC ID: 2BBDZ166-53-05NC-E IC ID: 31259-1665305NCE To Whom It May Concern:

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

1. Block Diagram 2. Schematic Diagram 3. Operational Description 4. Internal Photos These items contain detailed system and equipment description and related information about the product which GPR 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, GPR 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: Moran David Title: CEO Company Name: GPR Inc. Address: 444 Somerville Ave, Somerville, MA 02143

444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 Federal Communications Commission Equipment Authorization Division 7435 Oakland Mills Road Columbia, MD 21048 Date: 3/27/2024 Subject:

Request for Short Term Confidentiality FCC ID: 2BBDZ166-53-05NC-E IC ID: 31259-1665305NCE To Whom It May Concern:

In accordance with 0.457(d) and 0.459 of CFR 47, GPR Inc. hereby requests short term confidentiality for documents filed under the following exhibit types:

1. External Photographs 2. User / Instruction Manual 3. Test Set-up Photographs Until the product will be publicly announced. Short term confidentiality release date / period: 180 days from grant issue date. These items contain detailed system and equipment description and related information about the product which GPR 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, GPR 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 written 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 reset prior to product launch. 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 444 Somerville Ave Somerville, MA 02143 www.gpr.com 617.902.0318 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: Moran David Title: CEO Company Name: GPR Inc. Address: 444 Somerville Ave, Somerville, MA 02143