FCC ID: PD9BE200NG Intel BE200

Model: P132F Brand: DELL WLAN label is sticked on the core side of D cover. BE200NGW Contains FCC ID : PD9BE200NG IC : 1000M-BE200NG

Federal Communications Commission 7435 Oakland Mills Road Columbia MD 21046 Subject:

Attestation Statement FCC ID:

PD9BE200NG Reference:

a) FCC CFR section 2.911(d)(5)(i) b) FCC Section 2.911(d)(5)(ii) a) b) Intel Corporation certifies that the equipment for which authorization is sought is not Covered equipment prohibited from receiving an equipment authorization pursuant to 2.903 of CFR title 47;

Intel Corporation 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;

Intel Corporation Street Address: 425 rue de Goa Le Cargo B6 City/Province/Zip: Antibes 06600, France Contact Name: Benjamin Lavenant Telephone No: +33493001400 Email: Benjamin.lavenant@intel.com

*Signature of Applicant Benjamin Lavenant, 10/31/2023

U.S. Agent Designation for Service of Process

(Applicant and U.S. Agent are Separate Parties) TO:

Federal Communications Commission 7435 Oakland Mills Road Columbia MD 21046 ATTENTION: FCC Certification Section 2.911(d)(7) Information Designated U.S. Agent Company Name: Intel Corporation Contact Name: Robert W Paxman Street Address: 2111 NE 25th Avenue City/Province/Zip: Hillsboro, OR 97124 Telephone No: (503) 712- 8077 Email: Robert.Paxman@Intel.com FRN #: 0023093867 This letter is to confirm that we (the Designated U.S. Agent) have accepted the responsibility to act as the Designated U.S. Agent for Service of Process as required by section 47 CFR 2.911(d)(7) on behalf of the Applicant noted below. U.S. Agent Signature:

Date: 10/26/2023 Signed by: Robert W Paxman / Wireless Product Regulations Engineer 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 above changes. Applicant Company name: Intel Corporation Grantee Code: PD9 Contact Name: Benjamin Lavenant Street Address: 425 rue de Goa City/Province/Zip: 06600 Telephone No: 0493001400 Email: benjamin.lavenant@intel.com FRN #: 0033159344 Applicant Signature:

Date:10/26/2023 Signed by: Benjamin Lavenant / Wireless Regulatory Engineer 1 - Letters must be placed on appropriate letterhead. 022423-17 Rev 6

Request for Modular/Limited Modular Approval October 16, 2023 Subject: Manufacturers Declaration for

- Modular Approval

- Limited Modular Approval

- Split Modular Approval

- Limited Split Modular Approval Confidentiality Request for: ______PD9BE200NG______ 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 Requirement Met 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)

- YES - NO(*) Details: 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. See photo provided with this filing. 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: 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: The module contains its own power supply regulation. Please refer to operational description 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: The module connects to its antenna using an UFL connector which is considered a non-standard connector. The antenna and connector specification are provided with this filing. 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 X

- NO(*) Details: The module was tested in OEM host PC and is limited to installation in the host described in this filing. 053019-02a Modular Approval Requirement 6. The modular transmitter must be labeled with its own FCC ID number, or use an electron display (see Requirement Met 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: 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: 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: The module meets mobile/portable conditions levels as shown in the RF exposure test report filed with this application. 053019-02a 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: The module was tested in the OEM host PC and is limited to installation in the PC described in this application. Software Considerations KDB 594280 / KDB 442812 (One of the following 2 items must be applied) Requirement 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. Requirement Met

- Provided in Separate Cover Letter

- N/A Details: The firmware of the device cannot 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 >

053019-02a 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

- All Items shown to X the left are provided in the Modular Integration Guide (or UM) for Full Modular Approval (MA) or LMA. Therefore the a. 8. Information on test modes and additional testing requirements. KDB 996369 D03, Section 2.9 Test modes that should be taken into consideration by host integrators including clarifications necessary for stand-alone and simultaneous configurations. Provide information on how to configure test modes for evaluation 9. Additional testing, Part 15 Subpart B disclaimer. KDB 996369 D03, Section 2.10 b. Sincerely, By:

Regulatory Engineer __________________________ Benjamin Lavenant _____________________

(Signature/Title1)

(Print name) 1 - Must be signed by applicant contact given for applicant on the FCC site, or by the authorized agent if an appropriate 053019-02a

October 10, 2023 Subject: Confidentiality Request for FCC ID: PD9BE200NG Pursuant to FCC 47 CRF 0.457(d) and 0.459 the applicant requests that a part of the subject FCC application be held confidential. Type of Confidentiality Requested Short Term Short Term Short Term Permanent Permanent Permanent Exhibit Operation Description Test Setup Photos / Internal Photos Users Manual Intel Mobile Communications has spent substantial effort in developing this product and it is one of the first of its kind in industry. Having the subject information easily available to "competition"

would negate the advantage they have achieved by developing this product. Not protecting the details of the design will result in financial hardship. Permanent Confidentiality:

The applicant requests the exhibits listed above as permanently confidential be permanently withheld from public review due to materials that contain trade secrets and proprietary information not customarily released to the public. Short-Term Confidentiality:

The applicant requests the exhibits selected above as short term confidential be withheld from public view for a period of 180 days from the date of the Grant of Equipment Authorization and prior to marketing. This is to avoid premature release of sensitive information prior to marketing or release of the product to the public. Applicant is also aware that they are responsible to notify Sporton International (USA) Inc. in the event information regarding the product or the product is made available to the public. Sporton International (USA) Inc. will then release the documents listed above for public disclosure pursuant to FCC Public Notice DA 04-1705. By:

_________________________ Benjamin LAVENANT Regulatory Engineer Title:

On behalf of: Intel Corporation e-mail:

benjamin.lavenant@intel.com Intel Corporation 425 rue de Goa, Le Cargo 6 Antibes, 06600 France

Date November 8th, 2023 Declaration To whom it may concern By this letter, Intel Corporation (Intel) hereby declare that DPCSA (Dynamic Power Control and SAR/PD Algorithm) is implemented in the following Intel wireless modules family as described in Intel DPCSA Operational Report AX201D2W rev4 provided for KDB Enquiry:

AX200xxx AX201xxx AX210xxx AX211xxx AX411xxx BE200xxx Where xxx may be alphanumerical aa-z, 0-9 which designate different HW form factor. The algorithm that is implemented is identical in all models and doesnt change from model to model. SAR Level input for DPCSA algorithm is specific to each host and assessed in relevant Host SAR report. Regards, _________________________________________________ Signature & Contact info Intel Rep Wilfrid DAngelo Wireless Certification Program Manager Intel CCG Wireless Test and Certification Center (WTCC) Email: Wilfrid.DAngelo@intel.com Date Intel Corporation S.A.S. 425 Rue de Goa Le Cargo B6 06600 Antibes France Tel. +33 (0)4 93 00 14 00 - Fax +33 (0)4 93 00 14 01 SAS au capital de 5 208 026,16 Euros RCS Nanterre 302 456 199 Siret 302 456 199 00256 - TVA FR54302456199