FCC ID: 2A3HY-RMG3-RCOM-B sepioo S1

sepioo S1 Module Integration Manual Graz, 02.06.2023 This document describes how to integrate sepioo S1 module including all the requirements related to it. 1 CONTENT Mechanical Integration ............................................................................................................................................ 3 Mechanical integration requirements .......................................................................................................................... 3 sepioo S1 module - 3D view: ......................................................................................................................................... 3 Dimension details .......................................................................................................................................................... 4 Hardware/Firmware Integration .............................................................................................................................. 5 Flashing ......................................................................................................................................................................... 5 Operation ...................................................................................................................................................................... 5 UART COMMANDS .................................................................................................................................................. 6 Command "RES\r": ........................................................................................................................................................ 6 Command "SVN\r": ....................................................................................................................................................... 6 Command "FIB\r": ......................................................................................................................................................... 6 Command "RID\r":......................................................................................................................................................... 6 Command "SEV <1-byte event-type><4-byte data>\r": ................................................................................................ 6 Command "EVS\r": ........................................................................................................................................................ 7 Command "RSC <1-byte user-SET-config ID>\r": ........................................................................................................... 7 Command "WGC <1-byte user-GET-config ID><4-byte data>\r": .................................................................................. 7 Command "EHI <32bit host interrupt configs\r": .......................................................................................................... 8 Command "GHI\r": ........................................................................................................................................................ 8 Command "CHI\r":......................................................................................................................................................... 8 Command " ERF\r": ....................................................................................................................................................... 8 Command "RUD\r": ....................................................................................................................................................... 8 Error responses "ERR <2-byte error-code\r": ................................................................................................................ 9 EXAMPLE USAGE CHARTS ........................................................................................................................................... 10 Canada/ISED PRODUCT LABELING .......................................................................................................................... 12 RF EXPOSURE ........................................................................................................................................................ 13 USA / FCC VERIFICATION TEST REQUIREMENTS ...................................................................................................... 14 USA / FCC COMPLIANCE ........................................................................................................................................ 16 2 Mechanical Integration Max. Dimensions of the module: 13,75 x 23,985 x 16,9 mm The module needs to be attached to a host PCB by soldering using the castellated holes on the sides of the PCB of the module (see red marking in the picture below). Pin assignment is described in the HW/FW chapter. 3D data of the module can be requested from the module provider on demand. Mechanical integration requirements The position of the module in the host system has to be verified and approved by the module provider. Every change in the host system (PCB dimensions or mechanical changes) needs to be logged and communicated to the module provider. The PCB ground must not be connected directly to the casing material The module has to have a minimum distance of 10 mm to the metal casing. Furthermore, the module has to have at least 25 mm distance to batteries. The module antenna needs to be reachable by electromagnetic waves, meaning it is not allowed to be mounted behind metal or liquids. Instead, the host system cover must be some kind of plastic to cover the opening in the metal in front of the antenna. A typical plastic with a permittivity of ~2.5 should be used. sepioo S1 module - 3D view:

3 Dimension details Figure 1: Top view sepioo S1 module Figure 2: Front and side view of sepioo S1 module 4 Hardware/Firmware Integration Figure 1RFCOMM001A pinout Flashing To flash the Module with the SEGGER Flasher (ARM) connect the module via the SWD pins shown in blue in Figure 1RFCOMM001A pinout. An external power supply (3.3V) is also needed as the SEGGER flasher does not provide power. Start ARMFirmwareFlasher.exe and select a firmware hex file via the drop-down menu:

File Open firmware file Enter a Label ID (must match a Label ID in the pool-file.csv) and press START. After a successful flash operation, the notification windows should turn green and PASS appears. After successfully flashing the module be sure to reboot it, i.e. reconnect power supply or trigger reset via the reset pin

(pull LOW). Operation For communicating one must first pull PIN 15 (WAKEUP/GPIO2) low and wait for the RDY\r response from the module. After this the module is ready to receive commands for approximately two seconds. A timeout will occur if this time is exceeded. All available commands a listed below including a short example and the expected result. 5 UART COMMANDS Command "RES\r":

Function: resets the module Returns: "ACK\r"

Command "SVN\r":

Function: returns the SVN-revision of the firmware (like FW version) Returns: "ACK 9403\r"

9403 => 0x0394 in decimal = 916 => SVN revision 916. Command "FIB\r":

Function: returns very detailed firmware information. Returns: "ACK 0000000003200203100094038524A74A0020000000D001000000C002FFFF0BF1\r"

Command "RID\r":

Function: returns the unique ID (=address) of the module. Returns: "ACK 0012FFA5\r"

0012FFA5 => 0xA5FF1200 => the unique ID of the module is A5FF1200. Command "SEV <1-byte event-type><4-byte data>\r":

Function: sends a high-priority event to the access-point backend.

<1-byte event-type>:

specifies the "type" of the event (see PKT_EVENT_TYPES).

= 0x00, // no event PKT_EVENT_TYPE_NONE PKT_EVENT_TYPE_BUTTON_1_PRESSED PKT_EVENT_TYPE_BUTTON_2_PRESSED PKT_EVENT_TYPE_BUTTON_1_AND_2_PRESSED = 0x03, // event "button 1+2 was pressed"

PKT_EVENT_TYPE_SIMPLE_NFC_EVENT

= 0x04

// ... add more event types here (up to 0xFF)

= 0x01, // event "button 1 was pressed"

= 0x02, // event "button 2 was pressed"

<4-byte data>: 4-byte payload. Example: "SEV 04AABBCCDD\r"

Format: 04

=> event type 0x04 AABBCCDD => 0xAA,0xBB,0xCC,0xDD payload that will be sent to the access-point. Returns: "ACK\r"

Notes: Events are reserved for critical messages and should be used seldomly. Sending too many events will cause congestion of the network, therefore the use should be limited to high-priority or critical messages. Only a single event can be active at a given time. To monitor the status and successfull/failed delivery, use the

"Get Event Status" command (EVS). 6 Command "EVS\r":

Function: returns the status of the event-transmission. Returns: "ACK 000A0104AABBCCDD\r"

Format:

offset 0: flag indicating if event is active offset 1: number or retries left offset 2: result of previous event (see SYNC_EVENT_RESULT) SYNC_EVENT_RESULT_NOT_AVAILABLE SYNC_EVENT_RESULT_EVENT_CONFIRMED SYNC_EVENT_RESULT_EVENT_TIMEOUT

= 0 // result is not available

= 1 // event was confirmed

= 2 // event has timed out offset 3: event type (see PKT_EVENT_TYPES) PKT_EVENT_TYPE_NONE PKT_EVENT_TYPE_BUTTON_1_PRESSED PKT_EVENT_TYPE_BUTTON_2_PRESSED PKT_EVENT_TYPE_BUTTON_1_AND_2_PRESSED = 0x03 // event "button 1+2 was pressed"

PKT_EVENT_TYPE_SIMPLE_NFC_EVENT

// ... add more event types here (up to 0xFF)

// offset 4-7: event data payload (4 bytes)

= 0x00 // no event

= 0x01 // event "button 1 was pressed"

= 0x02 // event "button 2 was pressed"

= 0x04 Command "RSC <1-byte user-SET-config ID>\r":

Function:

reads a user-SET-config register and returns the 12-bits data. This config was SET by the access-point backend system.

<1-byte user-SET-config ID>: specifies the config-register to read. Example: "RSC 00\r"

00 => 0x02 => use user-SET-config #0 Returns: "ACK BC0A\r"

BC0A => 0x0ABC => 12 bits of config data => 0xABC Notes: Config-registers can be set/read the access-point backend system. ATTENTION! Only 12 bits can be SET by the access-point!

However, 4 bytes can be READ by the access-point!

So, the RSC and WGC commands differ in their function!

Command "WGC <1-byte user-GET-config ID><4-byte data>\r":

Function: writes a 4-byte value to a user-GET-config register.

<1-byte config-ID>: specifies the config-register to write.

<4-byte data>: 4 byte payload. This config can be READ by the access-point backend system. Note that the value will not be transferred to the access-point, it's the access-point backend system's task to regularly read all configs of interest. This method does not cause a congestion of the network and is the preferred way of providing data to the access-point backend. Example: "WGC 02AABBCCDD\r"

02 => 0x02 = use user-GET-config #1. AABBCCDD => 0xAA,0xBB,0xCC,0xDD payload that will be written. Returns: "ACK\r"

Notes: Config-registers can be set/read the the access-point backend system. ATTENTION! 4 bytes can be READ by the access-point!

However only 12 bits can be SET by the access-point!

So, the RSC and WGC commands differ in their function!

7 Command "EHI <32bit host interrupt configs\r":

Function: Enables interrupts to signal host about certain events. Check interrupt_commands.py for details about what interrupts to active and the according command string. Example: "EHI 00010000\r"

"Host enables IRQ when [user-SET-config #0] will be written."

NOTE: this could to be configured after startup once. Returns: "ACK\r"

Command "GHI\r":

Function: Prints currently active IRQ flags. Example: GHI\r Returns: ACK 00010000\r IRQ flag [user-SET-config #0 was written] is set. Command "CHI\r":

Function: Host wants to clear IRQ flag. Example: EHI 00010000\r host wants to clear IRQ flag, user-SET-config #0 was written."

Returns: ACK\r Notes: After an interrupt was caught and handled, PIN 1 (GPIO0) is still low, one must manually clear the active interrupt in order to reset PIN 1 to a HIGH state again. To clear all active interrupts, use the CHI FFFFFFFF\r command which will clear everything. Command " ERF\r":

Function: Enables output of modulated or unmodulated carrier Example: ERF 0107\r Enabled output of unmodulated carrier on channel 7 Returns: ACK\r Notes: The first bytes describe the mode :

(00 = disable radio; 01 = output unmodulated carrier; 02 = output modulated carrier) The second bytes describes the channel to use (0x00 0x0B) This command is only used for certification/testing purposes. Command "RUD\r":

Function: Reads USERDATA previously received via AUX page Example: RUD 00003100\r Reads 0x100 (256) bytes of USERDATA from address 0x00003 Returns: 2 bytes length + requested data + 2 bytes checksum Notes:

Every packet is transmitted with a two byte length information in the beginning and a checksum at the end for validating the requested data. This command allows to read a maximum of 4095 bytes per request in address range of 0x00000 to 0xFFFFF (1048575), although an error will be thrown if the address is out of range. 8 Error responses "ERR <2-byte error-code\r":

Function: any function may respond with a 2-byte error code. Example: "ERR 0200\r"

0200 => 0x0002 => ERR_COMMAND_TIMEOUT.

= 0 // no error - all OK!

= 1 // a generic error (not a specific one) occurred

= 2 // host-MCU didnt send a command on time (=timeout)

= 3 // buffer for receiving commands was full List of error-codes:

ERR_NONE ERR_UNSPECIFIC ERR_COMMAND_TIMEOUT ERR_COMMAND_BUFFER_FULL ERR_COMMAND_RECEIVE_ABORTED = 4 // host-MCU command reception was aborted ERR_COMMAND_LENGTH_INVALID ERR_COMMAND_UNKNOWN ERR_PARAMETER_LENGTH_INVALID = 7 // parameter had invalid length ERR_PARAMETER_FORMAT_INVALID = 8 // parameter had invalid format ERR_COMMAND_NOT_IMPLEMENTED = 9 // command is not implemented ERR_EVENT_IS_ACTIVE ERR_USER_CONFIG_ID_INVALID ERR_RFOUT ERR_READ_USERDATA

= 10 // an EVENT is still active

= 11 // user-config ID is invalid

= 12, // rf output config is invalid

= 13 // error while transmitting payload

= 5 // host-MCU command had invalid length

= 6 // command is unknown 9 EXAMPLE USAGE CHARTS In order to talk with the module, pull the /CS_MODULE pin LOW and wait for the module to respond with RDY\r. After that one can issue a command terminated with '\r' <CARRIAGE RETURN> char. The module will just answer with a simple ACK\r, depending on the command followed with desired information

(e.g. SVN). See Figure 2 example of simple commands. If a command is not recognized (command not known, typo, wrong parameters, timeout, etc.) the label will respond with an Error followed by the Error code

(e.g. ERR 0200 = ERR_COMMAND_TIMEOUT.) see Figure 3 error responses Figure 2 example of simple commands Figure 3 error responses 10 In order to enable host interrupts, use the command EHI followed by the desired interrupts to enable. A tool to provide help on how to select interrupts and the corresponding command is provided (see interrupt_command.py). see Figure 4 enable host interrupts. There is no need to enable an interrupt again once it was activated. To disable the interrupt again, issue an EHI 00000000\r command to disable ALL interrupts or select a specific interrupt to disable (again see interrupt_command.py for help) Figure 4 enable host interrupts After an interrupt was enabled (e.g. set_config #0 was written) the module will pull the /HOST_IRQ pin LOW. After that the host can communicate with the module (read set_config, ). It is important to clear the active interrupt flag again to allow the /HOST_IRQ to go HIGH again. To do this one can simply clear ALL active interrupts (CHI FFFFFFFF\r) or ask for the currently active interrupts

(GHI\r) and just clear those. see Figure 5 handle host interrupts and clear active flags. Figure 5 handle host interrupts and clear active flags 11 Canada/ISED PRODUCT LABELING The Host Marketing Name (HMN) shall be indicated on the exterior of the host product or on the product packaging, or in the product literature, which shall be supplied with the host product or readily available online. The host product shall be properly labelled to identify the modules within the host product. The ISED certification label of a module shall be clearly visible at all times when installed in the host product; otherwise, the host product must be labelled to display the ISED certification number for the module, preceded by the word "contains" or similar wording expressing the same meaning, as follows:

Contains IC: 27854-RMG3RCOMB In addition to containing other required statements specified elsewhere in this standard or in the applicable RSS, user manuals for licence-exempt radio apparatus shall contain the following text, or an equivalent notice, that shall be displayed in a conspicuous location, either in the user manual or on the device, or both in both English and Frensh:

This device contains licence-exempt transmitter(s)/receiver(s) that comply with Innovation, Science and Economic Development Canadas licence-exempt RSS(s). Operation is subject to the following two conditions:

(1) This device may not cause interference.

(2) This device must accept any interference, including interference that may cause undesired operation of the device. Lmetteur/rcepteur exempt de licence contenu dans le prsent appareil est conforme aux CNR dInnovation, Sciences et Dveloppement conomique Canada applicables aux appareils radio exempts de licence. Lexploitation est autorise aux deux conditions suivantes :

(2) Lappareil ne doit pas produire de brouillage;

(3) Lappareil doit accepter tout brouillage radiolectrique subi, mme si le brouillage est susceptible den compromettre le fonctionnement. RF EXPOSURE The module is an exempt RF device. It can be used in hosts for portable and mobile applications and for fixed installation. This module can not be used for medical implants. The module comes with a permanent antenna assembled. The host integrator is not allowed to change the antenna or any RF impacting parameters. RF integration specifications:

Usable band: 2404,053 MHz 2479,285 MHz 0-10 Channels available Transmission power of 10 dBm The host integrator must comply with the following requirements:

The position of the module in the host system has to be verified and approved by the module provider. Every change in the host system (PCB dimensions or mechanical changes) needs to be logged and communicated to the module provider. The PCB ground must not be connected directly to the casing material The module has to have a minimum distance of 10 mm to the metal casing. Furthermore, the module has to have at least 25 mm distance to batteries. The module antenna needs to be reachable by electromagnetic waves, meaning it is not allowed to be mounted behind metal or liquids. Instead, the host system cover must be some kind of plastic to cover the opening in the metal in front of the antenna. A typical plastic with a permittivity of ~2.5 should be used. The usage of the module is permitted only in case the host integrator complies with all RF exposure requirements. USA / FCC VERIFICATION TEST REQUIREMENTS The sepioo S1 module is certified as a limited module due to not fulfilling the FCC requirements regarding shielding based on 15.212 (FCC Part 15, Subpart C). That is why the host integrator needs to follow the approach that is defined in this manual on how to integrate and test the host product. The results of the host product verification need to be communicated to and approved by the module provider. The module complies with the requirements based on 15.212 (FCC Part 15, Subpart C) for modular transmitters for:

Buffered modulation/data inputs Voltage regulation Antenna LMA for Professional Host Installation Possibility that the module is tested in a Stand-Alone Configuration Due to not fulfilling the FCC requirements regarding shielding based on 15.212 (FCC Part 15, Subpart C) the host design shall consider the requirements described in this document regarding mechanical, HW and FW design. Each host device has to be tested according to Part 15 Unintentional Radiator requirements in addition to that it needs to be ensured by spot checks that the missing shield is not causing problems. The testing needs to be done by an FCC recognized laboratory and the test reports for each host device need to be provided to PDi Digital. All host devices must be added to the limited module Grant by PDi Digital by a Class 2 Permissive Change (C2PC) before use. All changes in the host device need to be reported to PDi Digital. For all changes in the host devices, technical details need to be provided to PDi Digital by the host integrator, so PDi Digital together with a TCB can check/decide what needs to be verified/tested in order to fulfill the FCC requirements. To ensure that no out-of-complaint emissions as a composite result from any stray host signals being reradiated out of compliance to 15B under SDoC or Certification it needs to be confirmed by a Spurious Emission Test. The host device needs to comply with the conducted limits for unintentional radiators according to https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-B/section-15.107 as well as the host needs to comply with the radiated limits for unintentional radiators according to https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-B/section-15.109. Due to the lack of shielding on the module, signals from the host device could possibly be coupled into the module, or vice versa, signals from the module could couple into the rest of the device and possibly be radiated (or conducted). It has to be ensured that radiated & conducted emissions are not coupled into the module and then emitted by the module. This shall be done by the test lab through spot checking by comparing measurement results from the host system with the measurement results from the module certification. Spurious Emission Test For spurious emission tests, the host integrator can use the standard FW (the FW that the module is delivered with). As described in detail in the FW integration chapter of this document there is a dedicated UART command implemented for spurious emission testing command ERF\r". With this command modulated or unmodulated carriers can be emitted within the 2.4GHz spectrum by the module on the configured channels accordingly. USA / FCC COMPLIANCE The following rules are applicable to this modular transmitter:

1.1307 Actions that may have a significant environmental effect, for which Environmental Assessments (EAs) must be prepared. 2.1033 Application for certification. 15.209 Radiated emission limits; general requirements. 15.249 Operation within the bands 902-928 MHz, 2400-2483.5 MHz, 5725-5875 MHZ, and 24.0-24.25 GHz. This limited modular transmitter is only FCC authorized for the Part 15 FCC transmitter rules listed in the grant. The host product manufacturer is responsible for compliance to any other FCC rules that apply to the host not covered by the limited modular transmitter grant of certification. The host product still requires Part 15 Subpart B compliance testing with the modular transmitter installed. A host product shall use a physical label stating Contains Transmitter Module FCC ID: 2A3HY-RMG3-

RCOM-B, or Contains FCC IDs: 2A3HY-RMG3-RCOM-B, XYZMODEL, or shall use e-labeling."

The antenna(s) used for this transmitter must not transmit simultaneously with any other antenna or transmitter, except in accordance with FCC multi-transmitter product procedures. The device shall bear the following statement in a conspicuous location on the device:

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. When the device is so small or for such use that it is impracticable to label it with the statement specified in a font that is four-point or larger, and the device does not have a display that can show electronic labeling, then the information required by this paragraph shall be placed in the user manual and must also either be placed on the device packaging or on a removable label attached to the device. The users manual or instruction manual for an intentional or unintentional radiator shall caution the user that changes or modifications not expressly approved by the party responsible for compliance could void the user's authority to operate the equipment. In cases where the manual is provided only in a form other than paper, such as on a computer disk or over the Internet, the information required by this section may be included in the manual in that alternative form, provided the user can reasonably be expected to have the capability to access information in that form. A compliance information statement that includes the following items (Section 2.1077(a)) must be supplied with the product at the time of marketing or importation Identification of the product, e.g., trade name, model, etc. A statement that the product complies with the rules, as applicable; and The name and address, and telephone number, or internet contact information of the responsible partys (as defined in Section 2.909(b)) contact located in the United States. Further to Section 2.1077(c), the compliance information must be provided in a form that an end-user can reasonably be expected to have the capability to access, such as the instruction manual, a separate product insert, computer disk, web page, or the devices own electronic screen. Compliance information may be provided electronically as permitted in Section 2.935. "

Devices authorized under the SDoC procedure have the option to use the FCC logo to indicate compliance with the FCC rules,12 and the logo may be included in the instruction materials or as part of an e-label. The FCC logo shall only be used on a product that has been tested, evaluated, and found to be compliant in accordance with the SDoC procedures. The use of the FCC logo on the device does not mitigate the requirement to provide a means to uniquely identify the product or to provide the required compliance information statement. The FCC logo cannot be used on products that are exempt from an authorization by rule (e.g., Section 15.103 exempt devices, or Section 15.3 incidental radiators) unless the SDoC procedure has been fully applied for the product. In addition, this limited module is not permitted for any application where end users can insert a module into any open host platform.

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DIGITAL FCC Applicant Authorization Federal Communication Commission Equipment Authorization Division, Application Processing Branch 7435 Oakland Mills Road Columbia, MD 21048 11.04.2023 To whom it may concern, We, PDi Digital GmbH, FRN: 0031553837, hereby authorize TUV AUSTRIA Services GmbH to act Fait L-wbkalt : i = il as = EE u=minm ek? eee en ae ee a! _ Bae oe fl. ue ce ie ee eee a. og FO lt a a ee |

FCC Applicant Authorization Federal Communication Commission Equipment Authorization Division, Application Processing Branch 7435 Oakland Mills Road Columbia, MD 21048 11.04.2023 To whom it may concern, We, PDi Digital GmbH, FRN: 0031553837, hereby authorize TUV AUSTRIA Services GmbH to act Feit L-bL.Iift : i ail as = EE u=mim ed? eee een a en a! _ Bm oe ft. ue ce me ee ee a og FL lt a ee |

MEE MME MSTIGIE TTT GUE TIGRE Ss PCIGUIIB LY GV MIILGUUEIS TUE CUUIVITICIIL QULITOLIZALION Ol SO MIOO oO FCC ID: 2A3HY-RMG3-RCOM-B, including the signing of all documents relating to these matters Any and all acts carried out by TUV AUSTRIA Services GmbH on our behalf shall have the same effect as acts of our own. All statements we make in our request for equipment authorization are true and correct to the best of our knowledge and belief. We also hereby certify that no party to this application is subject to a denial of benefits, includ-

ing FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 862. Sincerely, Michael Moosburger, CEO Signature (can be electronically inserted) PDi Digital GmbH MEE MME MRTIGIN TTT GUE TIGR PCIGUIIB LY GV MIILGUULIS (UE CUUIVITICIIL QULITOLIZALION OF SO MIOO oO FCC ID: 2A3HY-RMG3-RCOM-B, including the signing of all documents relating to these matters Any and all acts carried out by TUV AUSTRIA Services GmbH on our behalf shall have the same effect as acts of our own. All statements we make in our request for equipment authorization are true and correct to the best of our knowledge and belief. We also hereby certify that no party to this application is subject to a denial of benefits, includ-

ing FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 862. Sincerely, Michael Moosburger, CEO Signature (can be electronically inserted) PDi Digital GmbH Kalsdorfer Strasse 6 8072 Fernitz-Mellach, Austria Mobil: +43 (0) 664 88 28 35 23 office@pdi-digital.com www.pdi-digital.com PDi Digital GmbH FN497733k UID-No Austria: ATU75023617 BNP Paribas Austria Kalsdorfer Strafse 6 office@pdi-digital com Germany: DE331624217 IBAN: AT46 1810 0101 3583 0100 A-8072 Fernitz-Mellach, AUSTRIA www pdi-digital com BIC: GEBAATWW Kalsdorfer Strasse 6 8072 Fernitz-Mellach, Austria Mobil: +43 (0) 664 88 28 35 23 office@pdi-digital.com www.pdi-digital.com PDi Digital GmbH FN497733k UID-No Austria: ATU75023617 BNP Paribas Austria Kalsdorfer Strafse 6 office@pdi-digital com Germany: DE331624217 IBAN: AT46 1810 0101 3583 0100 A-8072 Fernitz-Mellach, AUSTRIA www pdi-digital com BIC: GEBAATWW PDI Digital GmbH Kalsdorer Strake 6 A-8072 Fernitz-Mellach AUSTRIA PDI Digital GmbH Kalsdorer Strake 6 A-8072 Fernitz-Mellach AUSTRIA

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DIGITAL PDi Digital GmbH Kalsdorfer StraRe 6 A-8072 Fernitz-Mellach AUSTRIA PDi Digital GmbH Kalsdorfer StraRe 6 A-8072 Fernitz-Mellach AUSTRIA CONF D N JALI YREQ EST Federal Communication Commission Equipment Authorization Division, Application Processing Branch 7435 Oakland Mills Road Columbia, MD 21048 Februrary 2, 2023 TO WHOM IT MAY CONCERN Pursuant to Paragraphs 0.457 and 0.459 of the Commissions Rules (47 C.F.R.) and Section 552(b)(4) of the Freedom of Information Act, PDi Digital GmbH (FRN: 0031553837) requests confidentiality for the following products:

FCC ID Number Product: Title/Model e Product Code:

Oo RMG3-RCOM-B FCC: 2A3HY- RMG3-RCOM-B CONF D N IALI YREQ EST Federal Communication Commission Equipment Authorization Division, Application Processing Branch 7435 Oakland Mills Road Columbia, MD 21048 Februrary 2, 2023 TO WHOM IT MAY CONCERN Pursuant to Paragraphs 0.457 and 0.459 of the Commissions Rules (47 C.F.R.) and Section 552(b)(4) of the Freedom of Information Act, PDi Digital GmbH (FRN: 0031553837) requests confidentiality for the following products:

FCC ID Number Product: Title/Model e Product Code:

Oo RMG3-RCOM-B FCC: 2A3HY- RMG3-RCOM-B For the product stated above, we request that the following information be held confidential:

1. Circuit diagrams, BOM, and PCBs submitted as Equipment Authorization Electronic Filing attachment: folder: Hardware 2. Block diagram, Operational description submitted as Equipment Authorization Electronic Filing attachment:

e sepioo_certification_manual_EN The above exhibits contain PDi Digital GmbH trade secrets and proprietary information that could be of benefit to our competitors regarding the design of our Smart Tagging System. This material is not customarily available to the general public and we request that it be withheld from public inspection. If you have any questions, please feel free to contact me at the address shown below. Sincerely, For the product stated above, we request that the following information be held confidential:

1. Circuit diagrams, BOM, and PCBs submitted as Equipment Authorization Electronic Filing attachment: folder: Hardware 2. Block diagram, Operational description submitted as Equipment Authorization Electronic Filing attachment:

e sepioo_certification_manual_EN The above exhibits contain PDi Digital GmbH trade secrets and proprietary information that could be of benefit to our competitors regarding the design of our Smart Tagging System. This material is not customarily available to the general public and we request that it be withheld from public inspection. If you have any questions, please feel free to contact me at the address shown below. Sincerely, Michael Moosburger, CEO PDi Digital GmbH bH Kalsdorfer Strasse 6 rnitz-Mellach 8072 Fernitz-Mellach, Austria igital.com |

Mobil: +43 (0) 664 88 28 35 23 office @pdi-digital.com www.pdi-digital.com PDi Digital GmbH FN497733k UID-No Austria: ATU7S023617 BNP Paribas Austria Kalsdorfer StraBe 6 office@pdi-digital com Germany: DE331624217 IBAN: AT46 1810 0101 3583 0100 A-8072 Fernitz-Mellach, AUSTRIA WWW pdi-digital.com BIC: GEBAATWW Michael Moosburger, CEO PDi Digital GmbH bH Kalsdorfer Strasse 6 rnitz-Mellach 8072 Fernitz-Mellach, Austria igital.com |

Mobil: +43 (0) 664 88 28 35 23 office @pdi-digital.com www.pdi-digital.com PDi Digital GmbH FN497733k UID-No Austria: ATU7S023617 BNP Paribas Austria Kalsdorfer StraGe 6 office@pdi-digital com Germany: DE331624217 IBAN: AT46 1810 0101 3583 0100 A-8072 Fernitz-Mellach, AUSTRIA WWW pdi-digital.com BIC: GEBAATWW

Coverletter:

PDi Digital GmbH wants to get FCC-Certification for the following product:

limited module sepioo S1, RMG3-RCOM-B. The unit will get the following FCC-ID: 2A3HY-RMG3-RCOM-B The module is limited because it doesnt fulfil the requirement for: RF shielding All host devices must be tested by an FCC recognized lab and added to the limited module grant through a C2PC. The procedure is reviewed under MODLIM PAG according to KDB 388624 D02 Pre-Approval Guidance List v18r03. List of documents:

Exhibit Exhibit 01 Exhibit 02 Thema File Label and placement Permanent_adhesive_label_with_FCC_ID.jpg Authorization Letter PDi Digital GmbH_FCC Applicant Authorization_RGCOM.pdf Covered List CoveredList_FCC_RMG-RCOM-B Exhibit 03 US Agent for Service of Process External Photos FCC ID on Module USAgent_FCC_RMG-RCOM-B with FRN.pdf external and internal photos.pdf

* Exhibit 04 Block Diagrams

* Exhibit 05 Schematic Diagrams RFComM001D00B_Schematics_v1.0.pdf Exhibit 06 Testreport Permanent_adhesive_label_with_FCC_ID.jpg RFComM001D00B_BlockDiagram_v1.0.pdf 2023-IN-AT-TICL-E-EX-000013-FG-

002_signed_2x.pdf Part 15 Antenna Information Test Set-up Photos User Manual Internal Photos RF exposure Exhibit 07 Exhibit 08 Exhibit 09 Exhibit 11

* Exhibit 12 Operational Description Part_15_Antenna_Information_RMG3RCOMB_13062 023.pdf photos_setup.pdf sepioo S1_IntegrationManual_v2_01022023.pdf external and internal photos.pdf see test report FCC Protocol Timing Specification.pdf sepioo_operational description_EN.pdf Exhibit 13 Antenna dimensions Cover letter AntennaInformation_RMG3RCOMB_13062023.pdf This file Request for confidentiality ConfidentiallyRequest_RMG-RCOM-B_FCC.pdf Cover letter for module certification 2023-06-02 FCC Modular Approval Letter_02062023.pdf For the Exhibits marked with * PDi Digital GmbH requested Confidentiality according to 47 CFR 0.457 and 0.459 of the FCC rules because these are sensitive parts owned by this company and include much of Know-How or sensitive data, it will not be provided to the public. Part 15 antenna information: The limited module uses an on-board inverted-F antenna made from sheet metal. Measured gain values are given in the test report, antenna photos are given in the internal and external photos exhibits. A summary is given in the test report exhibit. Drawings with detailed dimensions are given in the Operational Description. The labelling on some photos may be not the actual status. Label and placement are shown in Exhibit 01.

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DIGITAL https://www. fcc.gov/supplychain/coveredlist oreo a4 PDt Digital GmbH Kalsdorfer StraRe 6 A-8072 Fernitz-Mellach AUSTRIA PDt Digital GmbH Kalsdorfer StraRe 6 A-8072 Fernitz-Mellach AUSTRIA Covered List, 2.911(d)(5) Federal Communication Commission Equipment Authorization Division, Application Processing Branch 7435 Oakland Mills Road Columbia, MD 21048 31.01.2022 To whom it may concern, regarding the FCC 22-84 Report and Order and the Commissions Covered List 1 Covered List, 2.911(d)(5) Federal Communication Commission Equipment Authorization Division, Application Processing Branch 7435 Oakland Mills Road Columbia, MD 21048 31.01.2022 To whom it may concern, regarding the FCC 22-84 Report and Order and the Commissions Covered List 1 PDi Digital GmbH, (the applicant) certifies that the equipment for which authorization is sought is not covered equipment prohibited from receiving an equipment authorization pur-

suant to section 2.903 of the FCC rules. PDi Digital GmbH, (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. Sincerely, i Michael Moosburger (D CEO DIGITAL GmbH Kalsdorfer PDi Digital GmbH Kalsdorfer Strasse 6 8072 Fernitz-Mellach Signature PDi Digital GmbH, (the applicant) certifies that the equipment for which authorization is sought is not covered equipment prohibited from receiving an equipment authorization pur-

suant to section 2.903 of the FCC rules. PDi Digital GmbH, (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. Sincerely,

Michael Moosburger (D CEO DIGITAL GmbH Kalsdorfer PDi Digital GmbH Kalsdorfer Strasse 6 8072 Fernitz-Mellach Signature

' The inclusion of producers or providers of equipment or services identified on this list should be read to include the subsidiaries and affiliates of such entities PDi Digital GmbH FN497733k UID-No Austria: ATU75023617 BNP Paribas Austria Kalsdorfer StraBe 6 office@pdi-digital com Germany: DE331624217 IBAN: AT46 1810 0101 3583 0100 A-8072 Fernitz-Mellach, AUSTRIA www pdi-digital com Bic: GEBAATWW

' The inclusion of producers or providers of equipment or services identified on this list should be read to include the subsidiaries and affiliates of such entities PDi Digital GmbH FN497733k UID-No Austria: ATU75023617 BNP Paribas Austria Kalsdorfer StraBe 6 office@pdi-digital com Germany: DE331624217 IBAN: AT46 1810 0101 3583 0100 A-8072 Fernitz-Mellach, AUSTRIA www pdi-digital com BIC: GEBAATWW

Cover Letter Request for Module Certification for Sepioo S1 - RMG3-RCOM-B FCC ID Company: PDi Digital GmbH Date: 02.06.2023 Application for:

Modular Approval Split Modular Approval Limited Modular Approval Limited Split Modular Approval Single-modular transmitter: A complete RF transmission sub-assembly, designed to be incorporated into another device, that must demonstrate compliance with FCC rules and policies independent of any host;

Limited single-modular transmitter: A single-modular transmitter that complies with the 15.212(a)(1) modular rules, only when constrained to specific operating host(s) and/or associated grants condition(s);

Split-modular transmitter: An RF transmission system that complies with the requirements for a single-modular transmitter, that is separated into a radio front-end section and a control-

element section, and can demonstrate compliance for a range of similar type hosts;

Limited split-modular transmitter: A split-modular transmitter that complies with the definition and technical rules for split modules only when constrained to specific operating host(s), and/or associated grant condition(s).

*) Split modular transmitters require Pre-Approval Guidance (PAG) Checklist for 15.212(a)(1) Single modular transmitters must meet the following requirements to obtain a modular transmitter approval.

(i) The radio elements of the modular transmitter must have their own shielding. The physical crystal and tuning capacitors may be located external to the shielded radio elements. Requirement met?

yes no Details: The module was initially developed for the European market

(where no shield is required) and together with cost optimization in order to stay competitive with this product the development of this product was done without shield. Adding a shield would have significant impact also on the host PCBs adding a shield requires a bigger RCOM PCB which would change the interface to the host. Host integrators must test their devices at an FCC recognized test lab. Host Integrators must submit their host designs together with the test report to PDi Digital for review. PDi Digital will add the host to the limited module grant by C2PC.

(ii) The modular transmitter must have buffered modulation/data inputs (if such inputs are provided) to ensure that the module will comply with part 15 requirements under conditions of excessive data rates or over-modulation. Details: Compliant to FCC part 15

(iii) The modular transmitter must have its own power supply regulation. Details: Power supply regulation is in place.

(iv) The modular transmitter must comply with the antenna and transmission system requirements of 15.203, 15.204(b) and 15.204(c). The antenna must either be permanently attached or employ a unique Requirement met?

yes no Requirement met?

yes no Requirement met?

yes no 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 (b) of this section. Details: Permanent adhesive label attached

(v) The modular transmitter must be tested in a stand-alone configuration, i.e., the module must not be inside another device during testing for compliance with part 15 requirements. Unless the transmitter module will be battery powered, it must comply with the AC line conducted requirements found in 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 15.27(a)). The length of these lines shall be the 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 and commercially available (see 15.31(i)). Requirement met?

yes no Details: Permanently attached

(vi) The modular transmitter must be equipped with either a permanently affixed label or must be capable of electronically displaying its FCC identification number. Requirement met?

yes no

(A) If using a permanently affixed label, the modular transmitter must be labeled with its own FCC identification number, and, if the FCC identification number 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.

(B) 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. Details: FCC ID is shown via permanent adhesive label

(vii) The modular transmitter must comply with any specific rules or operating requirements that ordinarily apply to a complete transmitter and the manufacturer must provide adequate instructions along with the module to explain any such requirements. A copy of these instructions must be included in the application for equipment authorization. Requirement met?

yes no Details: Host integration requirements have been provided to the host integrator.

(viii) Radio frequency devices operating under the provisions of this part are subject to the radio frequency radiation exposure requirements specified in Requirement met?

yes no 1.1307(b), 1.1310, 2.1091, and 2.1093 of this chapter, as appropriate. Applications for equipment authorization of modular transmitters under this section must contain a statement confirming compliance with these requirements. The modular transmitter must comply with any applicable RF exposure requirements in its final configuration. Technical information showing the basis for this statement must be submitted to the Commission upon request. Details: RF exposure evaluation of the limited module is provided in the test report. The module is 1 mW blanket exempt.RF exposure information will be provided to host integrators in the integration manual. A limited modular approval may be granted for single or split modular transmitters that do not comply with all of the above requirements, e.g., shielding, minimum signaling amplitude, buffered modulation/data inputs, or power supply regulation, if the manufacturer can demonstrate by alternative means in the application for equipment authorization that the modular transmitter meets all the applicable part 15 requirements under the operating conditions in which the transmitter will be used. Limited modular approval also may be granted in those instances where compliance with RF exposure rules is demonstrated only for particular product configurations. The applicant for certification must state how control of the end product into which the module will be installed will be maintained such that full compliance of the end product is always ensured. Checklist for KDB 996369 D03 OEM Manual v01 The grantee must provide 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 met?

yes no Is the module intended for sale to third parties?

*) If the modular transmitter is only approved for use by the grantee in its own products and not intended for sale to third parties, the integration instructions may not be detailed but this must be declared in the filing. In that case, it is permitted to place the instructions in the theory-of-operation exhibit folder using long-term confidentiality. The applicant must include a statement in the filing that the module is not for sale and the user manual integration instructions are internal confidential manufacturing documents. The grant of certification for such a modular transmitter must be limited. Details: The host integration manual contains descriptions on how to integrate the limited module into host devices. Host integrators must test their host devices at an FCC recognized lab. Host integrators must submit their host designs together with with the test reports to PDi Digital for review. PDi Digital will add the host to the limited module grant by C2PC. Checklist for required items in the manual (KDB 996369 D03 OEM Manual v01) 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 antenna2 designs could indicate not applicable. If the modular transmitter is only approved for use by the grantee in its own products and not intended for sale to third parties, the integration instructions may not be detailed but this must be declared in the filing. In that case, it is permitted to place the instructions in the theory-of-operation exhibit folder using long-term confidentiality. The applicant must include a statement in the filing that the module is not for sale and the user manual integration instructions are internal confidential manufacturing documents. The grant of certification for such a modular transmitter must be limited. Included in manual?

(i) List of applicable FCC rules (KDB 996469 D03, Section 2.2) List the FCC rules that are applicable to the modular transmitter. These are yes no the rules that specifically establish the bands of operation, the power, spurious emissions, and operating fundamental frequencies. DO NOT list compliance to unintentional-radiator rules (Part 15 Subpart B) since that is not a condition of a module grant that is extended to a host manufacturer. See also Section 2.10 below concerning the need to notify host manufacturers that further testing is required. Details: FCC part 15, it is mentioned in the operational description.

(ii) Summarize the specific operational use conditions (KDB 996469 D03, Section 2.3) Describe use conditions that are applicable to the modular transmitter, including for example any limits on antennas, etc. For example, if point-to-

point antennas are used that require reduction in power or compensation for cable loss, then this information must be in the instructions. If the use condition limitations extend to professional users, then instructions must state that this information also extends to the host manufacturers instruction manual. In addition, certain information may also be needed, such as peak gain per frequency band and minimum gain, specifically for master devices in 5 GHz DFS bands. Details: Use conditions are listed in the integration manual. Portable, mobile and fixed installation are allowed.The module has an integrated antenna that can't be exchanged.

(iii) Limited module procedures (KDB 996469 D03, Section 2.4) Describe alternative means that the grantee uses to verify that the host meets the necessary limiting conditions Included in manual?

yes no Included in manual?

yes no RF exposure evaluation is necessary, state how control will be maintained such that compliance is ensured, for example by requiring a Class II Permissive Change for new hosts. For details see KDB 996469 D03, Section 2.4 Details: Host integrator is responsible for RF exposure compliance of the final product. RF Exposure information of the module is provided.The host integrator must ensure that the end product into which the module is installed will maintain full compliance with the FCC and ISED rules. The host integrator must test simultaneous transmission and ensure compliance with the FCC/ISED multi-

transmitter rules, if the module is combined with other transmitters.Every change in the host system (PCB dimensions, significant part changes or depopulation of functional groups or mechanical changes) needs to be tested documented and communicated to the module provider and to the FCC/ISED in accordance with authorization procedures.

(iv) Trace antenna designs (KDB 996469 D03, Section 2.5) If applicable, describe allowed trace layouts, parts lists, antenna, connectors, isolation requirements, specifications, test procedures for design validation, production test procedures For details see KDB 996469 D03, Section 2.5 Details: Customized 3D antenna design - antenna changes are not allowed.

(v) RF exposure considerations (KDB 996469 D03, Section 2.6) It is essential for module grantees to clearly and explicitly state the RF exposure conditions that permit a host product manufacturer to use the module. Two types of instructions are required for RF exposure information:

(1) to the host product manufacturer, to define the application conditions

(mobile, portable xx cm from a persons body); and (2) additional text needed for the host product manufacturer to provide to end users in their end-product manuals. If RF exposure statements and use conditions are not provided, then the host product manufacturer is required to take responsibility of the module through a change in FCC ID (new application). Details: RF Exposure information and evaluation are included in the manual. The module is 1 mW Blanket exempt under CFR Title 47 1.1307(b)(3)(i)(A).

(vi) Antennas (KDB 996469 D03, Section 2.7) A list of antennas included in the application for certification must be provided in the instructions. For modular transmitters approved as limited modules, all applicable professional installer instructions must be included as part of the information to the host product manufacturer. The antenna list shall also identify the antenna types (monopole, PIFA, dipole, etc. (note that for example an omni-directional antenna is not considered to be a specific antenna type)). For situations where the host product manufacturer is responsible for an external connector, for example with an RF pin and antenna trace design, the integration instructions shall inform the installer that unique antenna connector must be used on the Part 15 authorized transmitters used in the host product. The module manufacturers shall provide a list of acceptable unique connectors Details: Antenna information is provided in the integration manual. The module comes with an integrated antennas. Technical specifications such as separation distances between antenna and metal parts are provided. Use of other antennas is not permitted.

(vii) Label and compliance information (KDB 996469 D03, Section 2.8) Grantees are responsible for the continued compliance of their modules to the FCC rules. This includes advising host product manufacturers that they Included in manual?

yes no Included in manual?

yes no Included in manual?

yes no Included in manual?

yes no need to provide a physical or e-label stating Contains FCC ID with their finished product. See Guidelines for Labeling and User Information for RF Devices KDB Publication 784748. Details: Host integrator is informed

(viii) Information on test modes and additional testing requirements

(KDB 996469 D03, Section 2.9) Additional guidance for testing host products is given in KDB Publication 996369 D04 Module Integration Guide. Test modes should take into consideration different operational conditions for a stand-alone modular transmitter in a host, as well as for multiple simultaneously transmitting modules or other transmitters in a host product. The grantee should provide information on how to configure test modes for host product evaluation for different operational conditions for a stand-alone modular transmitter in a host, versus with multiple, simultaneously transmitting modules or other transmitters in a host. Grantees can increase the utility of their modular transmitters by providing special means, modes, or instructions that simulates or characterizes a connection by enabling a transmitter. This can greatly simplify a host manufacturers determination that a module as installed in a host complies with FCC requirements. Details: Direct support to host integrator is guaranteed, host integrator is informed in integration manual

(ix) Additional testing, Part 15 Subpart B disclaimer (KDB 996469 D03, Section 2.10) The grantee should include a statement that the modular transmitter is only FCC authorized for the specific rule parts (i.e., FCC transmitter rules) listed on the grant, and that the host product manufacturer is responsible for compliance to any other FCC rules that apply to the host not covered by the modular transmitter grant of certification. If the grantee markets their product as being Part 15 Subpart B compliant (when it also contains unintentional-radiator digital circuity), then the grantee shall provide a notice stating that the final host product still requires Part 15 Subpart B compliance testing with the modular transmitter installed. Details: Included in integration manual Included in manual?

yes no Included in manual?

yes no Sincerely, Markus Rumpf CTO PDi Digital GmbH

DocuSign Envelope ID: 7C5CBB24-6163-4CF5-B51F-C73001C5EA7B The FCC Registration Number (FRN) of SES-imagotag Inc. is 0033456773