FCC ID: C3K2066 Portable Computing Device

Label Content for Model Number: 2067 EUT Back FCC ID: C3K2067, Contains FCC ID C3K2066 as Change of ID to PD9AX201D2, IC 3048A-

2067, Contains IC 3048A-2066 CAN ICES-3 (B)/NMB-3(B). 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, and (2) this device must accept any interference received, including interference that may cause undesired operation.

Label Content for Model Number: 2066 EUT Back Model 2067, CAN ICES-3 (B)/NMB-3(B), FCC ID: C3K2067, Contains FCC ID C3K2066 as Change of ID to PD9AX201D2, IC 3048A-2067, Contains IC 3048A-

2066. 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, and (2) this device must accept any interference received, including interference that may cause undesired operation. Notes:

Please note that the module will not be relabeled but, with FCC OET approval via KDB inquiry

(#744487) submitted with this application, the host product will be physically labeled as shown above.

[07/18/2023]

Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, Maryland 21046 Subject: Class II Permissive change for FCC ID: [C3K2066] (Original Grant date:

[08/21/2023]) TO WHOM IT MAY CONCERN:

This is to request a Class II permissive change for FCC ID: [C3K2066], originally granted on [08/21/2023]. This module will be integrated into host C3K2067. The changes filed under this application are:

Change 1: SAR testing was performed to consider the portable exposure conditions. We understand that the power control mechanism needs to be implemented by the applicable KDB. The module will be operated at the maximum rated powers detailed in the SAR report. These maximum power levels will be different from those of the module certified power levels, but these new powers are the maximum possible for this specific module + host combination. Change 2: Radiated emissions and conducted power spot checks were performed as per the latest modular requirement guidance. Change 3: The maximum power setting level for all channels is either equal to or lower than the modular grant power levels. The antenna gain is lower than the gains used in the modular grant. The radiated emissions and conducted power measurements are compliant with the modular grant approval. Microsoft Corporation is an equal opportunity employer. Sincerely, Nisha Nandakumar Compliance Engineer, Microsoft Corporation. Microsoft Corporation is an equal opportunity employer.

WARNING:pdfminer.pdfpage:The PDF <_io.BufferedReader name='/Volumes/Scratch/Incoming/eg-scratch/6768342.pdf'> contains a metadata field indicating that it should not allow text extraction. Ignoring this field and proceeding. Use the check_extractable if you want to raise an error in this case Date: 7/24/2023 Federal Communications Commissions Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 RE: CFR 47 2.911 (d)(5) Attestation FCC ID: C3K2066 1. Microsoft Corporation (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. 2. Microsoft Corporation (the applicant) certifies that, as of the date of the filing of the application, the applicant is not identified on the Covered List as an entity producing covered equipment and is not an affiliate or subsidiary of an entity identified on the Covered List. Sincerely, Name: Nisha Nandakumar Title/Company: Compliance Engineer, Microsoft Corporation

07/16/2023 Federal Communications Commission 7435 Oakland Mills Road Columbia MD 21046 Subject: Request for Confidentiality for FCC ID: [C3K2067]

To Whom It May Concern:

Pursuant to the provisions of the Commissions rules 47 CFR sections 0.457(d) and 0.459, we are requesting the Commission to withhold the following attachments as confidential document from public disclosure indefinitely. Block Diagram Schematics Operational Description (Covers SW Security Document) The above-mentioned documents contain detailed system and equipment descriptions that are considered as proprietary information in the operation of the equipment. Public disclosure of the above documents might be harmful to our company and would give competitors an unfair advantage in the market. In addition to above mentioned documents, pursuant to Public Notice DA 04-1705 of the Commissions policy, to comply with the marketing regulations in 47 CFR 2.803 and the importation rules in 47 CFR 2.1204, while ensuring that business sensitive information remains confidential until the actual marketing of newly authorized devices, we are requesting the commission to grant short-term confidentiality on the following attachments until March 4th, 2024. Microsoft Corporation is an equal opportunity employer. External Photos Internal Photos Test Setup Photos Users Manual It is our understanding that all measurement test reports, FCC ID label format and correspondence during certification review process cannot be granted as confidential documents and the information will be available for public review once the grant of equipment authorization is issued. Sincerely, Nisha Nandakumar RF Compliance Engineer, Microsoft Corporation. Microsoft Corporation is an equal opportunity employer.

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[02/24/2023]

Federal Communications Commission 7435 Oakland Mills Road Columbia MD 21046 To whom it may concern:

I, the undersigned, hereby authorize UL Verification Services Inc. to act on our behalf in all manners relating to application for equipment authorization, including signing of all documents relating to these matters. Any and all acts carried out by UL Verification Services Inc. on our behalf shall have the same effect as acts of our own. I, the undersigned, hereby certify that we are not subject to a denial of federal benefits, that includes FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 853(a). In authorizing UL Verification Services Inc. as our representative, we still recognize that we are responsible to:

a) Comply with the relevant provisions of the certification program. b) c) d) Make all necessary arrangements for the conduct of the evaluation, including provision for examining documentation and access to all areas, records (including internal audit reports) and personnel for the purposes of evaluation inspection, assessment,

(e.g. testing, surveillance, reassessment) and resolution of complaints;

Make claims regarding certification only in respect of the scope for which certification has been granted;

Not use our product certification in such a manner as to bring the Certification Division into disrepute and not make any statement regarding our product certification which the Certification Division may consider misleading or unauthorized;

Microsoft Corporation is an equal opportunity employer. e) f) g) h) i) j) Upon suspension or cancellation of certification, discontinue use of all advertising matter that contains any reference thereto and return any certification documents as required by the Certification Division;

Use certification only to indicate that products are certified as being in conformity with specified standards;

Endeavor to ensure that no certificate nor report nor any part thereof is used in a misleading manner;

that any Ensure in communication media such as documents, brochures or advertising, complies with the requirements of the Certification Division;

to our product certification reference Keep a record of all complaints made known to us relating to the products compliance with requirements of the relevant standard and to make these records available to the when requested;

Take appropriate action with respect to such complaints and any deficiencies found in products or services that affect compliance with the requirements for certification;

k) Document the actions taken. This authorization is valid until further written notice from the applicant. Sincerely, Nisha Nandakumar Compliance Engineer, Microsoft Corporation. Microsoft Corporation is an equal opportunity employer.

WARNING:pdfminer.pdfpage:The PDF <_io.BufferedReader name='/Volumes/Scratch/Incoming/eg-scratch/6737527.pdf'> contains a metadata field indicating that it should not allow text extraction. Ignoring this field and proceeding. Use the check_extractable if you want to raise an error in this case Date: 3/3/2023 Federal Communications Commissions Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 RE: CFR 47 2.911 (d)(5) Attestation FCC ID: C3K2066 1. Microsoft Corporation (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. 2. Microsoft Corporation (the applicant) certifies that, as of the date of the filing of the application, the applicant is not identified on the Covered List as an entity producing covered equipment and is not an affiliate or subsidiary of an entity identified on the Covered List. Sincerely, Name: Nisha Nandakumar Title/Company: Compliance Engineer, Microsoft Corporation

Federal Communications Commission 7435 Oakland Mills Road Columbia, Maryland 21046 USA Re: Change of Identification Authorization, FCC ID: PD9AX201D2 Date: 02/14/2023 To Whom It May Concern:

This letter grants authorization for representatives of Microsoft Corporation to apply to the FCC for a change in identification as specified under 47CFR2.933 of the FCC rules. This authorization applies to the Intel Corporation, Intel Wireless AX201, 802.11a/b/g/n/ac/ax+

BT form factor, model: AX201D2W, FCC ID: PD9AX201D2. We are aware that Microsoft Corporation intends to market the above referenced product under their FCC ID: C3K2066, part number AX201D2W. Sincerely, Steven C. Hackett Wireless Product Regulatory Engineer Mobile Wireless Group Intel Corporation Date: 2/15/2023 Intel Mobile Communications 100 Center Point Circle, Suite 200 Columbia, South Carolina 29210 USA

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Inquiry on 06/19/2019:

Inquiry:

Hello OET staff, We are seeking your approval regarding the FCC ID re-labeling strategy associated with the Change of FCC ID process when integrating FCC certified RF modules in our (Microsoft) host devices. Please see the attached documents for more details on the proposed FCCID labeling option. Thank you, Chaitrali Limaye(chlimaye@microsoft.com) Vishwas Narayan(vivarada@microsoft.com) FCC response on 06/21/2019 We would like to determine if the host products could use e-labelling where a described wording could be used. Contains: FCC ID: XYZ-123456 as a change of ID to FCC ID:ABC-123456 This device complies. etc.

---Reply from Customer on 06/25/2019---

Yes, the host products can use e-labeling, as they have integrated displays and we can abide by the FCCs e-labeling requirements per the KDB784748 D02 e-labeling v02 FCC response on 06/26/2019 Great, we find this acceptable. Since a host can use e-labeling for a module to read the correct id of the change in ID and associate the original FCC ID of the physical label inside the host as a change in ID will eliminate confusion and is a reasonable notification.

---Reply from Customer on 06/28/2019---

Thank you for your acceptance. To clarify and finalize our plan in accordance with your guidance:

The module inside the device will continue to have the original FCCID from module vendor. We will not re-label the module physically with the new (changed) FCCID. At a System Level our host device would be e-labeled with:

"Contains: FCC ID: XYZ-123456 as a change of ID to FCC ID:ABC-123456 o o This device complies...etc. Our Change of FCCID and C2PC Grants would say "FCC ID: XYZ-123456 as a change of ID to FCC ID: ABC-123456"

Could you please clarify what you mean by "Since a hostcan use e-labeling for a module to read the correct id of the changein ID..."? Our intent is to retain the originalFCCID on the existing physical label on the module. However, the module will becompletely concealed within our host device. FCC response on 06/28/2019 FCC response on 07/01/2019 Everything you say is correct:

The module inside the device will continue to have the original FCCID from module vendor. We will not re-label the module physically with the new (changed) FCCID. At a System Level our host device would be e-labeled with:

"Contains: FCC ID: XYZ-123456 as a change of ID to FCC ID:ABC-123456 o o This device complies...etc. Statement...15.19 The following would be controlled by the FCC's EAS system though the TCB and when you file as a Change in ID and then file a Class II permissive change. This is not something you need to add or make comments on the Grant. The grant for the change in ID will be issued with all the privileges of the original grant. The public record of the 731 applications will indicate that it is a Change in ID. Our Change of FCCID and C2PC Grants would say "FCC ID: XYZ-123456 as a change of ID to FCC ID: ABC-123456"

Everything you say is correct:

The module inside the device will continue to have the original FCCID from module vendor. We will not re-label the module physically with the new (changed) FCCID. At a System Level our host device would be e-labeled with:

"Contains: FCC ID: XYZ-123456 as a change of ID to FCC ID:ABC-123456 o o This device complies...etc. Statement...15.19 The(Third bullet) would be controlled by the FCC's EAS system though the TCB when you file as a Change in ID and then file a Class II permissive change. This is not something you need to add or make comments on the Grant. The grant for the change in ID will be issued with all the privileges of the original grant. The public record of the 731 applications will indicate that it is a Change in ID. Our Change of FCCID and C2PC Grants would say "FCC ID: XYZ-123456 as a change of ID to FCC ID: ABC-

123456"

---Reply from Customer on 12/09/2019---

Hello FCC, We have a follow-on question to this inquiry. We will create a (new) generic Microsoft FCC ID (e.g., XYZ-789) for the module though the Change of ID process. This module will go inside a host that implements proximity sensor-based power reduction mechanism and therefore will need a unique FCC ID (e.g., XYZ-123456) (again, through Change of ID process). Can we now e-label the host device as "Contains XYZ-123456 as a Change of ID to FCC ID: XYZ-789"? Or does the label need to show the original FCC ID from module vendor (ABC-123456)?

In short, which of the following three options can we use?

Contains XYZ-123456 as a Change of ID to FCC ID: XYZ-789 Contains XYZ-123456 as a Change of ID to FCC ID: ABC-123456 Contains XYZ-123456 as a Change of ID to FCC ID: XYZ-789 / ABC-123456 Thank you, Chaitrali Limaye Vishwas Narayan FCC response on 12/09/2019 It is difficult to follow, and some clarification is required. Explain the Host, how many modules are in the host and their relationship and what is the label on the internal modules. I am confused by the examples. HOST A contains module FCC ID XYZ-123456 which is change in ID of FCC ID XYZ-789 which is a change in ID of FCC ID 3. Module FCC ID ABC-123456is labeled with FCC ID ABC-123456. If this is correct, why cant you just use FCC ID XYZ-789. I may be confused.

---Reply from Customer on 12/10/2019---

Apologies for not providing enough clarification. Please see the document attached to this inquiry. It contains a simple flowchart and some details for the question. Thanks, Chaitrali Limaye

---Reply from Customer on 12/10/2019---

Apologies for not providing enough clarification. Please see the attachment for a simple flowchart explaining the different IDs and the details. FCC response on 12/11/2019 What is the reason that FCC ID XYZ -12345 cannot be a change in ID to ABC -12345. Both XYZ -78 and XYZ -123456 are the same device as ABC -12345. The public record would be less confusing, also what did the letter from ABC say, Permission to do a change in ID or specifically to allow a change in ID for XYZ -789.

---Reply from Customer on 12/11/2019---

We are creating XYZ-789 as an intermediate ID as the 'base' to create new IDs like XYZ-123456 that will go inside host devices with different antenna/sensor configurations. The base ID is being created because we want a Microsoft ID as the base and avoid multiple letter requests to ABC. In short, yes, XYZ-789 and XYZ-123456 are the same RF module as ABC-12345. The difference is that XYZ-789 is an exact copy of original module whereas XYZ-123456 will be tied to a specific host device

(after adding SAR backoff details via C2PC). Letter from ABC says permission to allow change in ID for XYZ-789. The plans for future change in IDs are not disclosed to ABC. Thanks, Chaitrali Limaye

---Reply from Customer on 12/11/2019---

Intermediate ID XYZ-789 is being created because we want a Microsoft ID as the 'base' for creating new IDs like XYZ-123456 (to be used in different hosts with different antenna/sensor configs). This is also to avoid multiple letter requests to ABC for multiple new IDs. The letter from ABC says permission to allow change in ID for XYZ-789. The plan for future change in ID is not disclosed to ABC. Can we use the labeling scheme as "Contains FCC ID XYZ-123456 as change in ID to FCC ID XYZ-789"?

Thanks, Chaitrali Limaye

---Reply from Customer on 12/12/2019---

Hello FCC, Can you please advise if we can use the labeling scheme referencing MSFT ID XYZ-789?

Thanks, Chaitrali Limaye FCC response on 12/16/2019 This request can be complicated because of two KDB policies. First is KDN 616217 D04 SAR for laptop and tablets v01r02 requiring a separate FCC ID for each tablet with different sensor and antenna configurations. Second the change in ID policy Publication Number: 249634 requiring a signed permission letter from the original grantee Party B, on Party Bs letterhead, giving permission to file the change in ID(s), and listing all the applicable FCC IDs and the dates of the original grants of equipment authorization. Basically, if you did do a change in ID to XYZ-123456 to a new ID to FCC ID XYZ-789 you still need an original permission letter from the original Grantee granting permission for this specific arrangement. Which would be basically the same as doing an original Change in ID - FCC ID XYZ-789 as a change of ID from FCC ID:ABC-123456 The interpretation in Publication Number: 249634 was not to isolate permission from the original Grantee through a change in ID to yourself. Youi still need permission form the original grantee. Originally, for the previous Host, you did a change in ID XYZ-123456 form Grantees ABC-123456 but could not relabel the actual module, so we said you could label: Contains: FCC ID: XYZ-123456 as a change of ID to FCC ID:ABC-123456 Now you want a new Change in ID because of 616217 D04 as FCC ID XYZ-789 and you can use the same strategy:

Contains: FCC ID: XYZ-789 as a change of ID to FCC ID: XYZ-123456 or if you do the change in ID to FCC ID:ABC-123456 instead. Them Contains: FCC ID: XYZ-789 asa change of ID to FCC ID:ABC-123456 You can call me 301 362 3051 since I still may not be totally clear.

---Reply from Customer on 12/16/2019---

Thank you for the response. To summarize my understanding, in the label for XYZ-789 host, we can reference the previous Microsoft FCC ID (XYZ-123456), after obtaining the specific approval letter from module vendor for this 2nd Change of ID. Thanks, Chaitrali Limaye FCC response on 12/17/2019 FCC response on 12/17/2019 I assume that Yes, the label for XYZ-789 host, can reference the previous Microsoft FCC ID (XYZ-123456), after obtaining the specific approval letter from module vendor for this 2nd Change of ID. To Reiterate FCC ID XYZ-789 as a Module will be certified as a Change in ID which you will point to as a change in ID of XYZ-123456, with permission from original Grantee ABC -123456. We would want, for the filing, a new approval letter for XYZ-789 as a change in ID for XYZ-123456 . Then it would be acceptable to say Contains: FCC ID: XYZ-789 as a change of ID to FCC ID:XYZ-123456 But note that if you wanted to you could also get a new approval letter for XYZ-789 as a change in ID for ABC-123456. This would also be acceptable. Which then the label can be Contains: FCC ID: XYZ-789 as a change ofID to FCC ID: ABC-123456 If I do not have it correctly give me a call.

---Reply from Customer on 02/24/2023---

Hello FCC, We have a follow-up question to FCC's response on 7/1/2019. Is the same guidance applicable to physical labels also?

At a System Level our host device would be labeled with:

"Contains: FCC ID: XYZ-123456 as a change of ID to FCC ID:ABC-123456 o o This device complies...etc. Statement...15.19 Thanks. FCC response on 03/02/2023 I assume that this is because the module cannot be relabeled. If so, it is acceptable

--Reply from Customer on 03/02/2023---

Yes, the alternate physical labeling proposed above is because the module cannot be relabeled. Thanks for the confirmation. FCC response on 03/02/2023 Thank you for asking.

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This Change of Identification request applies for a new FCC ID as established in 47CFR 2.933(b) for a currently approved device. This application by Microsoft Corporation will establish a new FCC ID: C3K2066 under Microsoft grantee code for purpose of marketing. The original grant to Intel will remain in effect. The purpose of this change in identification is to obtain a new FCC ID for the Intel module and that FCC ID will be used for host specific implementation. This ID will be converted to new FCC IDs and C2PC will be filed on each to identify the host and host-specific implementation details. A new label format on the module is not being submitted, as agreed through FCC KDB inquiry number 744487. Rather a sample of the host e-label is being provided. 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, and (2) this device must accept any interference that may cause undesired operation. CAN-

ICES-3(B)/NMB-3(B) FCC ID C3K2066, Contains FCC ID C3K2066 as Change of ID to PD9AX201D2, IC 3048A-2066, Contains IC 3048A-2066 Per 2.933(b) 1. The original identification is PD9AX201D2. 2. The original grant date is 11/20/2018 and C2PC date is 02/08/2023. 3. The equipment is electrically identical. Only the model name, trade name, and FCC ID number are different. 4. The original test results are applicable and representative of this changed device. Microsoft Corporation is an equal opportunity employer. 5. Exterior photographs are included in this application. The following files are electronically submitted as attachments:

Cover Letter External Photos FCC ID label format and location Nisha Nandakumar, Compliance Engineer Microsoft Corporation Microsoft Corporation is an equal opportunity employer.