FCC ID: PD9BE201D2 Intel BE201

Model: BE201D2W Label information The device is considered to be too small for the label since it is impracticable to label with a font side that is four-points or larger. The FCC ID and IC ID is instead placed in the users manual as allowed by KDB 784748. External host labeling is still required once integrated into host. FCC ID: PD9BE201D2 IC: 1000M-BE201D2 Wireless Solutions Group Intel Confidential

Certification Application Attestation Statements Date: July 24, 2023 American Certification Body, Inc. 313 Park Avenue Suite 300 Falls Church, VA 22046 To Whom It May Concern:

Statement for 47 CFR section 2.911(d)(5)(i) Intel Corporation certifies that as of the date of the application the equipment for which authorization is sought is not covered equipment1 prohibited from receiving an equipment authorization pursuant to section 2.903 of the FCC rules. If the equipment for which the applicant seeks authorization is produced by any of the entities identified on the current Covered List, including affiliates or subsidiaries of the named companies, the applicant must include an explanation on why the equipment is not covered equipment. Additional Explanation: <N/A>

Statement for 47 CFR section 2.911(d)(5)(ii) Intel Corporation (the applicant) certifies that, as of the date of the filing of this application, the applicant - is / - is not identified on the Covered List as an entity producing covered equipment. Thank you, By:

(Signature2) Title:

Company:

Regulatory Engineer Intel Corporation Benjamin Lavenant

(Print name) Telephone: 0493001400 1 - The Commissions Covered List is published by the Public Safety and Homeland Security Bureau and posted on the Commissions website. This Covered List, which is periodically updated, identifies particular equipment, produced by particular entities, that constitutes covered equipment. https://www.fcc.gov/supplychain/coveredlist . 2 - Letters should be placed on appropriate letterhead. 021423-17 rev 4

January 5, 2024 Federal Communications Commission 7435 Oakland Mills Road Columbia, Maryland 21046 USA Subject: Model BE201NGW Wireless LAN Adapter Card FCC ID: PD9BE201D2 IC: 1000M-BE201D2 Gentlemen:

Please be advised that the Model BE201D2W 802.11a/b/g/n/ac/be + BT Wireless LAN mini-PCIe card is manufactured for the global market but when marketed in the U.S. under FCC ID:

PD9BE201D2 and in Canada under IC: 1000M-BE201D2. The non-volatile memory (NVM) will be programmed at the factory to only actively scan and operate on these specific channels during normal WLAN operation. During Wi-Fi Direct mode the device may act as a group owner (GO) to establish a peer-to-peer (P2P) network including conditions when no master device is present on these specific channels. Channels 1-13,2412-2472MHz 802.11b mode Channels 1-13, 2412-2472MHz 802.11g mode Channels 1-13, 2412-2472MHz 802.11n mode (20MHz channel) Channels 3-11, 2422-2462MHz 802.11n mode (40MHz channel) The device operates as a client without radar detection capability and will be programmed at the factory to passively scan on the following dynamic frequency selection (DFS) channels and will only listen for a master device and cannot send a probe request to initiate communication on these DFS channels. Accordingly passive scanning provides protection for TDWR operations and preventing transmission in the 5600MHz 5650MHz frequency band. Client software and drivers will never enable the device to act as a master or GO for operation in DFS frequency bands and therefore ad-

hoc mode is always disabled on these passive scan DFS channels. Channels 52-64, 5260-5320MHz 802.11a mode Channels 52-64, 5260-5320MHz 802.11n mode (20 MHz channel) Channels 52-64, 5260-5320MHz 802.11ac mode (20 MHz channel) Channels 54-62, 5270-5310MHz 802.11n mode (40MHz channel) Channels 54-62, 5270-5310MHz 802.11ac mode (40MHz channel) Channel 58, 5290MHz 802.11ac mode (80MHz channel) Channel 50, 5250MHz 802.11ac mode (160MHz channel) Channels 100-140, 5500-5700MHz 802.11a mode Channels 100-140, 5500-5700MHz 802.11n mode (20 MHz channel) Channels 100-144, 5500-5720MHz 802.11ac mode (20 MHz channel) Channels 102-134, 5510-5670MHz 802.11n mode (40MHz channel) Channels 102-142, 5510-5710MHz 802.11ac mode (40MHz channel) Channels 106 &138, 5540 & 5690MHz 802.11ac mode (80MHz channel) Channel 114, 5570MHz 802.11ac mode (160MHz channel) SAS au capital de 5 208 026,16 Euros RCS Nanterre 302 456 199 Siret 302 456 199 00256 - TVA FR54302456199 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 This device meets the requirements of FCC Part 15.202 and accordingly will be programmed at the factory to active scan on the following non-DFS channels to initiate communication during normal WLAN operation. When operating in Wi-Fi Direct mode on these non-DFS channels, it may operate as a P2P client device or GO to establish a P2P network if, and only if, a master device is present and network communication is maintained between a master device and the GO. Channels 36-48, 5180-5240MHz 802.11a mode Channels 36-48, 5180-5240MHz 802.11n mode (20 MHz channel) Channels 36-48, 5180-5240MHz 802.11ac mode (20 MHz channel) Channels 38-46, 5190-5230MHz 802.11n mode (40MHz channel) Channels 38-46, 5190-5230MHz 802.11ac mode (40MHz channel) Channel 42, 5210MHz 802.11ac mode (80MHz channel) Channels 149-165, 5745-5825MHz 802.11a mode Channels 149-165, 5745-5825MHz 802.11n mode (20 MHz channel) Channels 149-165, 5745-5825MHz 802.11ac mode (20 MHz channel) Channels151-159, 5755-5795MHz 802.11n mode (40MHz channel) Channels151-159, 5755-5795MHz 802.11ac mode (40MHz channel) Channel 155, 5775MHz 802.11ac mode (80MHz channel) This device meets the requirements of FCC Part 15.202 and 15.407 as a 5.9GHz band Indoor client module (UNII) and accordingly will be programmed at the factory to passive scan on the following channels. On these channels, a) the client device will not directly connect to another client device, b) will only associate and connect with an indoor Access Point (AP) or indoor subordinate, and c) the Client device (EUT) will always be under the control of an indoor AP. However. there may exist situations where the client may transmit brief messages, prior to being under the control of an AP, to join an AP network. But these brief messages will only occur if the client has detected a signal confirming that an AP is operating on a particular channel. These brief messages will have a time-out mechanism if it does not receive a response from an AP. Channels 169-177, 5845-5885MHz 802.11a mode Channels 169-177, 5845-5885MHz 802.11n mode (20 MHz channel) Channels 169-177, 5845-5885MHz 802.11ac mode (20 MHz channel) Channels 167-175, 5835-5875MHz 802.11n mode (40MHz channel) Channels 167-175, 5835-5875MHz 802.11ac mode (40MHz channel) Channel 171, 5855MHz 802.11ac mode (80MHz channel) Channel 163, 5815MHz 802.11ac mode (160MHz channel) SAS au capital de 5 208 026,16 Euros RCS Nanterre 302 456 199 Siret 302 456 199 00256 - TVA FR54302456199 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 This device meets the requirements of FCC Part 15.202 and 15.407 as a 6GHz Dual Client (6CD) and accordingly will be programmed at the factory to passive scan (listen before talk) on the following channels. This client may initiate a brief message to associate with a low power indoor access point or subordinate or Standard Power Access Point and establish a connection only after receiving a confirmation signal confirming that an AP is present and operating on a particular channel. After being associated, the device can only initiate transmission with that access point. The Device will never directly link to any other client devices. 5925MHz - 6425MHz, 802.11a/n/ac/ax/be mode (all channel BWs), (LPI AP, Standard power AP) 6425MHz - 6525MHz, 802.11a/n/ac/ax/be mode (all channel BWs), (LPI AP) 6525MHz - 6875MHz, 802.11a/n/ac/ax/be mode (all channel BWs), (LPI AP, Standard power AP) 6875MHz - 7125MHz, 802.11a/n/ac/ax/be mode (all channel BWs), (LPIAP) This information when programmed into the NVM will not be accessible and cannot be changed by the end user. The transmitter is approved as a non-software defined radio and OEMs and third party system integrators do not have the ability through software to allow configuration controls that would permit the device to operate outside the grant conditions per FCC KDB 594280. Sincerely, Benjamin Lavenant Wireless regulatory Engineer Intel Corporation SAS au capital de 5 208 026,16 Euros RCS Nanterre 302 456 199 Siret 302 456 199 00256 - TVA FR54302456199 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

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

January 5, 2024 Attestation Letter for Dual Client (6CD) Module Approval We, Intel Corporation, attest that this device under FCC ID PD9BE201D2 complies with device protocol requirements and operational restrictions for Dual Client 6CD. a) This device only support 6CD category and the maximum power does not exceed authorized values. b) This device will only associate and connect with a Low Power Indoor Access Point, Subordinate Device, or Standard Power Access Point and never directly link to any other client devices. c) This device will always initiate transmission under the control of a Low Power Indoor Access Point, Subordinate Device, or Standard Power Access Point except for brief communications before joining a network. These brief messages will only occur if the client has detected a Low Power Indoor Access Point, Subordinate Device, or Standard Power Access Point operating on a channel. These messages will have a timeout mechanism such that if this device does not receive a response from an AP, it will not continually repeat the request. d) This device, when associated and connected with a Low Power Indoor Access Point, Subordinate Device or Standard Power Access Point device, will operate at or below power levels advertised by the Low Power Indoor Access Point, Subordinate Device, or Standard Power Access Point:

i. Lower than or equal to the power advertised by the Low Power Indoor Access Point or Subordinate Device; and never above the maximum output power allowed by the FCC grant for clients associated with Low Power Indoor Access Points or Subordinate Devices. ii. 6 dB lower than the Standard Power Access Points authorized power level; and never above the maximum output power allowed by the FCC grant for clients associated with Standard Power Access Points. e) 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. f) We acknowledge this device is subject to restrictions listed below. i. Prohibited for control of or communications with unmanned aircraft systems, including drones. This device is prohibited for control of or communications with unmanned aircraft systems, including drones. Best Regards, Benjamin LAVENANT Regulatory Engineer Intel Corporation benjamin.lavenant@intel.com

Request for Modular/Limited Modular Approval January 20, 2024 Subject: Manufacturers Declaration for

- Modular Approval

- Limited Modular Approval

- Split Modular Approval

- Limited Split Modular Approval Confidentiality Request for: ______PD9BE201D2_____ For Items Marked NO(*), the Limited Module Description Must be Filled Out on the Following Pages 8 Basic Requirements FCC Part 15.212(a)(1) 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 X - YES 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) Details: The module was tested in stand-alone mode as described in this filing.

- NO(*) 053019-02a 6. The modular transmitter must be labeled with its own FCC ID number, or use an electron display (see KDB Publication 784748). Modular Approval Requirement 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) Requirement Met

- 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. Software Considerations KDB 594280 / KDB 442812 (One of the following 2 items must be applied) Requirement Requirement Met 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.

- 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 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 Manual

- 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 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. X

- All Items shown to the left are provided in the Modular Integration Guide (or UM) for Full Modular Approval (MA) or LMA. Therefore the Sincerely, By:

__________________________ Benjamin Lavenant, Regulatory Engineer 1 - Must be signed by applicant contact given for applicant on the FCC site, or by the authorized agent if an appropriate 053019-02a

January 5, 2024 Subject: Confidentiality Request for FCC ID: PD9BE201D2 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 Short Term Short Term Short Term Short Term Short Term Short Term Permanent Permanent Permanent Permanent Permanent Permanent Permanent Permanent Permanent Exhibit Block Diagrams External Photos Internal Photos Operation Description Operation Description/HW Theory of Operation Operational Description/BT FHSS Description Schematics Test Setup Photos Users Manual Intel Corporation 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

January 20, 2024 Declaration Letter related to Channel puncturing feature. We, Intel Corporation, attest that this device under FCC ID PD9BE201D2 and IC 1000M BE201D2 has the channel puncturing not activated. The firmware is programmed at the factory and cannot be modified by third parties. Yours Sincerely, Benjamin Lavenant Wireless regulatory Engineer Intel Corporation SAS au capital de 5 208 026,16 Euros RCS Nanterre 302 456 199 Siret 302 456 199 00256 - TVA FR54302456199 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

January 27, 2024 The information provided in this document applies to the following Intel Wireless Adapter Modules FCC ID: PD9BE201D2 IC: 1000M BE201D2 Software Security Description KDB 594280 D02v01r03 Section II RSS 248 (section 11 a, b, & c) General Description 1. Describe how any software/firmware update will be obtained, downloaded, and installed. Software that is accessed through manufacturers website or devices management system, must describe the different levels of security as appropriate. There is no downloadable software provided by the manufacturer that can modify critical radio transmitter parameters. All critical parameters are programmed in OTP memory at the factory and cannot be modified or overridden by third parties. 2. Describe the rf parameters that are modified by any software/firmware without any hardware changes. Are these parameters in some way limited, such that, it will not exceed the authorized RF characteristics?

3. Describe in detail the authentication protocols that are in place to ensure that the source of the RF related software/firmware is legitimate. Describe in detail how the software is protected against modification. 4. Describe in detail any encryption methods used to support the use of legitimate RF relatedsoftware/firmware. 5. For a device that can be configured as a master and client (with active or passive scanning), explain how the device ensures compliance for each mode? In particular if the device acts as master in some band of operation and client in another; how is compliance ensured in each band of operation?

There are no rf parameters that can be modified. All rf parameters are programmed in OTP memory at the factory and cannot be modified or overridden by third parties. The firmware is programmed at the factory and cannot be modified by third parties. The firmware is programmed at the factory and cannot be modified by third parties therefore no encryption is necessary. This is a client module only. ThirdParty Access Control 1. Explain if any third parties have the capability to operate a US sold device on any other regulatory domain, frequencies, or in violation of the devices authorization if activated in the U.S.. 2.Describe, if the device permits thirdparty software or firmware installation, what mechanisms are provided by the manufacturer to permit integration of such functions while violation of the devices authorization if ensuring that the RF parameters of the device activated in the U.S..violation of the devices cannot be operated outside its authorization for authorization if activated in the U.S..violation of operation in the U.S. In the description include the devices authorization if activated in the what controls and/or agreements are in place U.S.. violation of the devices authorization if with providers of thirdparty functionality to activated in the U.S..any manner that is in ensure the devices underlying RF parameters are unchanged and how the manufacturer verifies the functionality. 3. For Certified Transmitter modular devices, describe how the module grantee ensures that hosts manufactures fully comply with these software security requirements for UNII devices. If the module is controlled through driver software loaded in the host, describe how the drivers are controlled and managed such that the modular transmitter parameters are not modified outside the grant of authorization. Third parties do not the capability to operate in any manner that is violation of the certification in the U.S. factory and cannot be reprogrammed or re-flashed by third parties. There are no rf parameters that can be modified. All rf parameters are programmed in OTP memory at the factory and cannot be modified or overridden by third parties. The module is not controlled by driver software on the host and cannot override critical rf parameters stored in module OTP memory. SOFTWARE CONFIGURATION DESCRIPTION KDB 594280 D02v01r02 Section III USER CONFIGURATION GUIDE 1. Describe the user configurations permitted through the UI. If different levels of access are permitted for professional installers, system integrators or endusers, describe the differences. No UI provided. a) What parameters are viewable and None configurable by different parties?

b) What parameters are accessible or None modifiable to the professional installer or system integrator?

i) Are the parameters in some way limited, so The module micro-code reads the parameters from the that the installers will not enter parameters that exceed those authorized?

module OTP memory. These parameters cannot be modified or overridden by sw drivers. ii) What controls exist that the user cannot Default mode is always FCC compliant. Other country operate the device outside its authorization in the U.S.?

modes cannot be activated without receiving three independent country codes from different APs, otherwise remains in FCC default mode (always FCC compliant) c) What parameters are accessible or None modifiable by the enduser?

i) Are the parameters in some way limited, so that The module micro-code reads the parameters from the the installers will not enter parameters that exceed those authorized?

module OTP memory. These parameters cannot be modified or overridden by sw drivers. ii) What controls exist that the user cannot Default mode is always FCC compliant. Other country operate the device outside its authorization in the U.S.?

modes cannot be activated without receiving three independent country codes from different APs, otherwise remains in FCC default mode (always FCC compliant) d) Is the country code factory set? Can it be Default country code is set in the factory and no UI is changed in the UI?

provided for modification. i) If it can be changed, what controls exist to ensure that the device can only operate within its authorization in the U.S.?

Programmed for default mode which is always FCC compliant. Always set for default for all start-ups, resets, timeouts or other host or network events. e) What are the default parameters when the Always FCC compliant device is restarted?

No This is a client device. This device is not an access point. 2. Can the radio be configured in bridge or mesh mode? If yes, an attestation may be required. Further information is available in KDB Publication 905462 D02. 3. For a device that can be configured as a master and client (with active or passive scanning),if this is user configurable, describe what controls exist, within the UI, to ensure compliance for each mode. If the device acts as a master in some bands and client in others, how is this configured to ensure compliance?

4. For a device that can be configured as different types of access points, such as pointtopoint or pointto multipoint, and use different types of antennas, describe what controls exist to ensure compliance with applicable limits and the proper antenna is used for each mode of operation. (See Section 15.407(a)) Sincerely, Benjamin LAVENANT Regulatory Engineer Intel Corporation benjamin.lavenant@intel.com

March 6, 2024 Declaration Regarding for 5.9 GHz Client device. We, Intel Corporation, attest that this device under FCC ID PD9BE201D2 complies with device protocol requirements and operat ional restrictions required for 5.9 GHz as follows:

This device operates in the 5.9 GHz band as an indoor Client only device. 1) As a client device (EUT) this will not directly connect to another client device. 2) As client device (EUT) this will only associate and connect with an indoor Access Point

(AP) or indoor Subordinate. 3) As a client device (EUT) this will always be under the control of an indoor AP. However, there may exist situations where the client may transmit brief messages, prior to being under the control of an AP, to join an AP network. But these brief messages will only occur if the client has detected a signal confirming that an AP is operating on a particular channel. These brief messages will have a time-out mechanism if the client does not receive a response from an AP. Best Regards, Benjamin LAVENANT Regulatory Engineer Intel Corporation benjamin.lavenant@intel.com