FCC ID: 2AUVU-OES3 5G mmWave Repeater

www.pivotalcommware.com Pivotal Commware, Inc.

(425) 365-0408 HOW TO SET UP YOUR PIVOTAL ECHO 5G Installed on your Window Outdoors Window Indoors Parts List Also Included:

(1) Outdoor unit

(ODU)

(1) Rail-mounting tool (with pre-

attached rails)

(1) Indoor Unit IDU alignment cling

(1) Indoor unit

(IDU) With pre-attached spacer ring

(1) 10 power adapter & cable

(1) Window-

prepping wipes

(1) Allen wrench

(2) Extra rails with adhesive

(if needed)

(1) Removal tool Troubleshooting Help (Back side) 1 Start by locating the best window for installation and cleaning the glass 2 Mount the ODU Press adhesive for good seal 3 a) Remove the protective film from the adhesive on the rails pre-attached to the back of the rail-mounting tool and position the rails on the outside window glass keeping them at least 4 inches from any edge. b) Press so that the rails adhere to the window. Run your fingers up and down the rails while applying force for 30 seconds. Inspect the rails from the inside of the window to ensure that there are minimal air gaps in the adhesive bond. Remove the rail-mounting tool by using the tabs to pop the tool off the rails. Wait 60 minutes for the rails to set, then slide the ODU on & tighten the set screws. The rails and adhesive MUST remain dry while setting. The Echo 5G is mounted on a window (not a sliding window) for optimum reception. Identify the window with the best 5G reception by turning off your phones wifi, downloading the SpeedTest app from your phones App store, opening the app, and selecting Go. You will mount your Echo 5G:

At least 4 inches from any window edge Within 10 feet of an outlet inside

(to plug in the IDU) Do not plug the IDU into the wall outlet until Step 5. Clean both sides of the window glass with the provided wipes. See back of wipes packet for detailed cleaning instructions. Verizon Wireless authorizes the use of this device on Verizon Wireless network only. Attach alignment cling and IDU 4 5 Plug in IDU & confirm connection to ODU 6 Commission your Echo 5G device Scan to read the Pivotal Echo 5G Installation Manual To contact Support:

Phone: 1-855-956-2016 Email: support@pivotalcommware.com Web: pivotalcommware.freshdesk.com/support/home WARNING. This is not a CONSUMER device. This device may not be sold at retail. You MUST have an FCC LICENSE or express consent of an FCC Licensee (or express consent of your service provider) to operate this device. Antennas must be installed at least 20 cm (8 inches) from any person. Unauthorized use may result in significant forfeiture penalties, including penalties in excess of $100,000 for each continuing violation. Attach the IDU alignment cling to the inside of the glass, aligning it with the ODU. LED lights Remove the adhesive from the Velcro on the pre-attached spacer ring on the IDU and press to the glass in the circle of the alignment cling. Apply force and hold for 30 seconds. Plug the Echo 5G IDU into your wall outlet. Blue and green LED lights on the IDU will appear and blink before going solid. If the green light blinks for more than 30 seconds, consult the Troubleshooting Help on the back of this page. Wait 60 minutes a) Stay within 10 feet of your Echo 5G while commissioning. Turn wireless off and select the Echo device in your smartphones Bluetooth settings. You may need to activate Bluetooth tethering in your Bluetooth settings. b) Navigate to web address 10.0.0.1 and type the last six digits of your devices serial number

(located on the packaging box and the bottom of the ODU) into the designated box. c) Press Enter. d) Then press Go on the next page. e) When the LED on the inside of the ODU (facing indoors) turns a solid green, your Echo 5G commissioning is complete!

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Pivotal Echo 5G Installation Manual Version 1.0 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 1 of 32 Table of Contents Safety and Regulatory Information ..................................................... 4 FCC Signal Booster User Information .......................................................................................4 FCC Part 15 Information for User .............................................................................................4 FCC Radiation Exposure Statement ..........................................................................................4 Intellectual Property ........................................................................... 5 Disclaimer of Warranties; Exclusion of Liability ................................... 5 Contact Information ........................................................................... 5 Overview of Echo 5G ........................................................................... 6 Installation & Setup ............................................................................ 7 System Components ................................................................................................... 7 General Configuration ................................................................................................ 8 Choosing a Device Location ........................................................................................ 9 Finding the Best Window for Reception ...................................................................................9 Pre-Installation Cleaning ............................................................................................. 9 Installing Outdoor (ODU) and Indoor (IDU, alignment cling) Components .............. 10 Installing the ODU on the outside of your window ................................................................10 Installing the IDU on the Inside of your Window ...................................................................11 Connecting to Echo 5G ...................................................................... 13 Add the Echo 5G as a Recognized Device via Laptop ............................................... 13 Establish Network Connection to the Echo 5G via Laptop ....................................... 15 Add the Echo 5G as a Recognized Device via Smartphone ....................................... 17 Echo 5G Web Interface ..................................................................... 19 Connecting to Echo via Web Browser ....................................................................................19 Device Settings (Details) .........................................................................................................20 Setting Azimuth or Elevation Manually ..................................................................................20 Appendix A Technical Specifications .............................................. 22 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 2 of 32 Appendix B Troubleshooting & Support ......................................... 23 Indicator Lights Overview ......................................................................................... 23 What the IDU Indicator Light Displays Mean ............................................................ 23 What the ODU Indicator Light Means ...................................................................... 24 Troubleshooting Issues ............................................................................................. 24 Getting Technical Assistance .................................................................................... 25 Appendix C Warranty Information ................................................. 26 Standard Limited Warranty ...................................................................................... 26 User License Agreement for Software ...................................................................... 27 Appendix D Glossary ...................................................................... 30 Appendix E Removal Instructions ................................................... 32 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 3 of 32 Safety and Regulatory Information This manual should be read and used as a guideline for properly installing and operating the Pivotal Echo 5G device. This manual may be changed for system improvement, standardization, and other technical reasons without prior notice. Updated manuals are available at: https://pivotalcommware.com/UserManual.pdf. For questions on the manual or their content, contact support@pivotalcommware.com. FCC Signal Booster User Information WARNING. This is not a CONSUMER device. This device may not be sold at retail. You MUST have an FCC LICENSE or express consent of an FCC Licensee (or express consent of your service provider) to operate this device. Antennas must be installed at least 20 cm (8 inches) from any person. Unauthorized use may result in significant forfeiture penalties, including penalties in excess of $100,000 for each continuing violation. FCC Part 15 Information for User Outdoor Unit (ODU) FCC ID: 2AUVU-OES3. This device contains FCC IDs: 2AUVU-UBR410M and Z64-WL18SBMOD Indoor Unit (IDU) FCC ID: 2AUVU-IES3 Pursuant to part 15.21 of CFR Title 47, you are cautioned that changes or modifications not expressly approved by the party responsible for compliance could void the users authority to operate this equipment. 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. Note: This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to part 15 of the FCC Rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates, uses, and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications. However, there is no guarantee that interference will not occur in a particular installation. If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one or more of the following measures Reorient or relocate the receiving antenna Increase the separation between the equipment and receiver Connect the equipment to an outlet on a circuit different from that which the receiver is connected Consult the dealer or an experienced radio/TV technician for help FCC Radiation Exposure Statement To ensure the safety of users, the FCC has established criteria for the amount of radio frequency energy various products may produce depending on their intended usage. This product has been evaluated to comply with the FCCs exposure criteria. This transmitter must not be co-located or operating in conjunction with any other antenna or transmitter. The installation of the Echo unit should allow at least 20 centimeters between the device and persons to be in compliance with FCC RF exposure guidelines. Use only Pivotal Commware approved power supplies and accessories that are specifically designed for your Echo device. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 4 of 32 Intellectual Property All Intellectual Property, as defined below, owned by or which is otherwise the property of Pivotal Commware, Inc. (Pivotal) or its respective suppliers relating to the Pivotal device, i.e., Pivotal Echo 5G, including but not limited to, accessories, parts, or software relating thereto (the Echo 5G), is proprietary to Pivotal and protected under federal laws, state laws, and international treaty provisions. Intellectual Property means any Pivotal (or where applicable, Pivotals suppliers) intellectual property including, but not limited to, inventions (patentable or unpatentable), patents, trade secrets, copyrights, software, computer programs, and related documentation and other works of authorship. You may not infringe or otherwise violate the rights secured by the Intellectual Property. Moreover, you agree that you will not (and will not attempt to) modify, prepare derivative works of, reverse engineer, decompile, disassemble, or otherwise attempt to create source code from the software. No title to or ownership in the Intellectual Property is transferred to you. All applicable rights of the Intellectual Property shall remain with Pivotal and its suppliers. Disclaimer of Warranties; Exclusion of Liability This document provides an introduction to features, functions, setup, and operation of Pivotal Commwares Echo 5G. For more information, refer to the Warranty Information. Contact Information Headquarters:

10801 120th Ave NE #200 Kirkland, WA 98033 USA www.pivotalcommware.com Do you have questions about your Echo 5G device?

For 24-hour information and assistance, please contact Verizons Automated Response System at:

www.verizonwireless.com/support/

2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 5 of 32 Overview of Echo 5G The Echo 5G is a self-installable, on-the-window, precision beamforming repeater designed to counteract mmWave penetration, reflection, and structural shadowing losses so it can gently flood an interior with native mmWave signal. Essentially, the Echo 5G acts as a portal between indoor and outdoor worlds. For fixed wireless access (FWA) providers serving homes and enterprises, the Echo 5G facilitates Gigabit speeds and introduces a superior broadband choice and experience to cable and DSL end users. For 5G-

connected devices, the Echo 5G enables outdoor-to-indoor signal transitions so users can ubiquitously enjoy the immersive 5G experiences that only mmWave capacity can deliver. The Echo 5G product line accomplishes this using Pivotals patented Holographic Beam Forming

(HBF) technology whose cost, size, weight, and power consumption (C-SWaP) profile is significantly lower than phased array beamformers; specifically, an order of magnitude less cost, less than half the weight, and less than one-third the power consumption. With HBF, Echo 5G overcomes a major obstacle to cost-effectively delivering 5G broadband access to homes and businesses with mmWave-in-building penetration. Figure 1: Millimeter wave signals bounce off windows Figure 2: The Echo 5G boosts the signals through the glass 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 6 of 32 Installation & Setup The Echo 5G is designed to be easily installed. The following material provides guidance to perform a typical installation. Subsequent sections offer additional assistance if needed. System Components Echo 5G (1) Outdoor unit (ODU) with HBF antenna and RF front-end functions:

Conveys wireless data between user devices and nearby base station Rail-mounting tool (1) Comes with pre-attached mounting rails Wireless Power IDU (1) Indoor Unit (IDU): transmits power through the glass to ODU equipment Power Adapter (1) Provides power from wall outlet to IDU Alignment cling (1) Mounts on indoor glass side of Echo 5G, helps with positioning IDU Extra Rails (2) To replace rails pre-attached to ODU, if necessary Spacer Ring (1, pre-attached to IDU) Mounts on the indoor glass side to ensure the proper spacing between the ODU and IDU if window is single-pane glass 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 7 of 32 Cleaning Wipes (1) To clean both sides of the window before mounting to ensure a good bond Allen Wrench (1) To loosen the set screws on each side of the device so the device can be slid off the rails. Removal Tool (1) To remove the rails and rail adhesive if necessary. General Configuration Heres an example of the Echo 5G system configuration along with a diagram of the components that are installed on your window. Figure 3: Window-mounted system: Echo Outdoor Unit (ODU) attaches to outside of window and smaller Indoor Unit (IDU) attaches to inside. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 8 of 32 Choosing a Device Location The window you choose for your Echo 5G must:

Receive quality 5G reception Be large enough to place the Echo 5G at least 4 inches from any window edge (or the ground) Have an outlet within 10 feet of the mounting location for plugging in the IDU Finding the Best Window for Reception Identify the window with the best 5G reception by turning off your phones wi-fi, downloading the SpeedTest App from your phones App store, opening the app, and selecting Go. Pre-Installation Cleaning Clean the inside and outside of the window glass according to the instructions on the back of the packet of wipes included with your Echo 5G.

[1] Wipe glass vertically and then horizontally to ensure complete coverage. Be sure pad is wetting the glass surface.

[2] While glass surface is still wet, wipe dry with a clean dry cloth or paper towel. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 9 of 32

[3] Apply the item(s) to be bonded within thirty minutes. Installing Outdoor (ODU) and Indoor (IDU, alignment cling) Components Make sure you have carefully selected a good window and performed the required glass cleaning before installing your Echo 5G. Installing the ODU on the outside of your window

[1] Remove the strips to expose the adhesive on the rails that are pre-attached to the rail mounting tool.

[2] Make sure the rails are level and you are mounting the unit at least four inches from any window edge. Press it against the outside of your window apply force and hold for 30 seconds.

[3] Run your thumbs up and down the rails, pressing hard for 30 seconds.

[4] Let the rails cure for one hour before sliding the device on. Wait 60 minutes

[5] Slide the ODU onto the rails. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 10 of 32

[6] Use the included Allen wrench to tighten the set screws on the ODU so the unit is tightly secured to the rails. Installing the IDU on the Inside of your Window

[7] Remove the alignment cling from its backing and attach it to the indoor side of the glass, lining up the cling inside with the ODU mounted on the outside.

[8] Remove the backing from the adhesive on the ring pre-attached to the IDU. Line the IDU up in the corresponding viewport in the cling.

[9] Press the IDU firmly to the window and hold for 30 seconds. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 11 of 32 Note that the adhesive-backed portion adheres to the ring and IDU with Velcro so you can remove the IDU and adjust as necessary once the adhesive-backed Velcro is secured to the window as outlined above. Disassembled IDU (velcro, one side), spacer ring (Velcro, both sides), and Velcro-to-

window adhesive Assembled IDU, spacer ring, and Velcro-to-window adhesive

[10] Once the IDU has been applied to the window, insert the power adapter and plug the IDU in to a standard 110V outlet. The IDU lights will blink before going solid. If the green IDU light continues blinking for more than 30 seconds, remove the spacer ring and re-attach the IDU. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 12 of 32 Connecting to Echo 5G You will commission the Echo 5G using the Echo 5G Manager web interface. In order to do this, you must first establish a wireless Bluetooth connection to the Echo device from your laptop or smartphone. Your laptop/smartphone and the Echo will communicate via Bluetooth. (Specifically, they communicate via IP over a Bluetooth connection). Once connected, you will need to keep your laptop or smartphone within 10 feet of the Echo unit until you are finished commissioning the device. Add the Echo 5G as a Recognized Device via Laptop

[1] Power on the Echo 5G so the laptop can discover it as a nearby Bluetooth device.

[2] On your laptop toolbar, right-click the Bluetooth icon:

[3] In the pop-up list, select Add a Bluetooth Device. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 13 of 32

[4] A Settings screen will appear with a list of options (left side). Select Bluetooth & other devices if it doesnt show by default, then select Add Bluetooth or other device.

[5] Select Bluetooth as the intended device type. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 14 of 32

[6] Select the Echo from the displayed list of nearby Bluetooth devices. It will show as echo.

[7] This adds your Echo unit to the list of devices available for interaction with the laptop. You will see a confirmation message when the Echo and your laptop are finished pairing.

[8] Then select Done. Establish Network Connection to the Echo 5G via Laptop

[1] Right click the Bluetooth icon in your laptop toolbar. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 15 of 32

[2] In the pop-up list, select Join a Personal Area Network.

[3] The system displays the Devices and Printers panel. Select your Echo device. Then, from the Connect using button, select Access point.

[4] Confirm that the Connect button is now replaced with a Disconnect from device network button. This is evidence that the Echo device is currently connected. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 16 of 32

[5] You will now be able to commission the Echo 5G device from this laptop using the Echo 5G Manager web interface. Add the Echo 5G as a Recognized Device via Smartphone

[1] Turn on your phones Bluetooth if it is not already on.

[2] You may also need to turn on Bluetooth tethering in your phones Bluetooth settings.

[3] Select the Echo 5G from your list of available Bluetooth devices and wait for it to connect. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 17 of 32 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 18 of 32 Echo 5G Web Interface The Echo 5G Web Interface is the same whether it is on a Smartphone browser or laptop browser. Connecting to Echo via Web Browser

[1] Navigate to web address 10.0.0.1 on your phones web browser.

[2] Enter the last six digits of your Echo 5Gs serial number as your password. The serial number can be found on the bottom of the ODU, the back of the IDU, or on the packaging box. Serial number shown on bottom of ODU

[3] Once you have entered your password, select Submit.

[4] After submitting your password, the Echo setup will begin. Select Go for the Echo to scan and align with the strongest 5G beam source. Once scanning is complete, you will see the Setup Complete screen and can reset and rescan or view the details of the scan.

[5] Should you wish to change your settings at any future time, simply go through this process again. The setup will skip the second and third screens in the image above and take you right to the Setup Complete page (as the Echo retains the details of your previous scan). You should select Reset for the device to re-scan and re-align. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 19 of 32 Device Settings (Details)

[6] If you select Details, you can view the Azimuth (Az) and Elevation (El) along with other details of the Echo 5Gs alignment in either dB or raw format. You can also manually set the Azimuth and Elevation if your connection is weak. Setting Azimuth or Elevation Manually The Manual Setup tab provides access to beam pointing (Az, El) control in degrees. Azimuth can be adjusted in 2-degree increments and decrements, and the Elevation in 5-degree increments. The inputs are bounded from -35 degrees to +35 degrees in Elevation and -76 degrees to

+76 degrees in Azimuth. You can begin with initial setting of 0 for both Az and El. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 20 of 32 Figure 4: Top-down view of azimuth settings range Side view of elevation settings range Side view of elevation settings range Figure 5: Top-down view of azimuth settings range 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 21 of 32 Appendix A Technical Specifications Pivotal Echo 5G Specifications 7" x 7" x 1.5" for RF ODU, and 3.7" circle, 1.1" depth for IDU AC adapter for IDU and wireless power magnetically induced for ODU 36 Watts (from outlet) Adhesive, VHB

-30 to 45 C IP54 for ODU; IP32 for IDU Bluetooth and LTE CAT M1 Standard: single and double pane Automated scan with setup via web-interface 27.5 to 28.35 GHz 29.5 dBm 29.5 dBm 6 dB at 76 2.4 lbs. 0.4 lbs. 3000 ft 30 ft FCC, UL 15 dB 15 dB 16 dB

+/-76

+/-35 6 dB 5 20 100 100 55 dB 55 dB 5 dB 5 dB 2 dB Dimensions Weight RF ODU Weight IDU Power Method Max. Power Consumption Operating Temperature Mounting IP Rating Configuration Management Interface Maximum Donor Range (to gNB) Maximum Indoor Range (to CPE/UE) Support Glass Type Certifications Commissioning Frequency of operation Max EIRP - DL Max EIRP - UL Gain tunable range - DL Gain tunable range - UL HBF antenna gain (donor side) HBF scan loss HBF az scan envelope HBF el scan envelope Static antenna (service side) HPBW towards gNB - azimuth HPBW towards gNB - elevation HPBW towards CPE/UE - azimuth HPBW towards CPE/UE - elevation Max electronic gain - DL Max electronic gain - UL Min noise figure - DL Min noise figure - UL In-band ripple (per 100 MHz channel) 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 22 of 32 Appendix B Troubleshooting &

Support Indicator Lights Overview What the IDU Indicator Light Displays Mean 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 23 of 32 What the ODU Indicator Light Means Troubleshooting Issues Issues Actions IDU continues to probe for the ODU (green light on IDU blinks for more than 30 seconds) Make sure the alignment cling and IDU are properly aligned with the ODU. If window glass is double-paned, remove the spacer ring from the IDU and re-attach the IDU. Echo 5G transmitting signal is weak Adjust Azimuth (Az) and Elevation (El) settings for better alignment with the gNB. Echo 5G is not transmitting at all Power off, then power on the Echo 5G. Echo 5G loses connectivity during commissioning Bluetooth connection may have dropped if laptop/smartphone was moved too far away from the Echo 5G during commissioning. Try getting closer to Echo with the device you are using to commission Echo 5G via Bluetooth. You may need to re-do the network connection portion of the Laptop-to-Echo connection process. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 24 of 32 Echo 5G signal strength diminishes over time Possible gradual obstruction in signal path to gNB, such as leaves growing on trees that were not there during initial Echo 5G setup. Re-commission the Echo 5G and select Reset and then Go to re-scan and re-align or perform manual adjustment of Gain and Az-El. Notes:

The Echo does not lose any settings when GUI/Bluetooth connection has been dropped and subsequently restored. If the above listed solutions do not appear to resolve your concern, please contact Pivotal Commware for additional assistance. Getting Technical Assistance Pivotal Commware is dedicated to the success of your Echo 5G installation and operation. Feel free to contact us with any questions or concerns. Before calling, gather the following details about your Echo 5G:

Serial Number (located on the bottom of the ODU, back of the IDU, and on the packaging box) Device settings Pivotal Echo 5G Technical Support:

Phone 1-855-956-2016 Email support@pivotalcommware.com Website https://pivotalcommware.freshdesk.com/support/home 10801 120th Ave NE, #200 Kirkland, WA 98033 USA

(425) 365-0408 pivotalcommware.com 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 25 of 32 Appendix C Warranty Information Your Pivotal Commware, Inc. ("Pivotal") Echo 5G has been designed to provide reliable, worry-free service. If for any reason you have a problem with your equipment, please refer to the manufacturers warranty in this section. For information regarding the terms and conditions of service for your Echo 5G, please visit www.verizonwireless.com/support/ or call Verizon Wireless Customer Service at (800) 922-0204 or *611 from your Verizon Wireless mobile phone. Standard Limited Warranty What is Covered and For How Long?

Pivotal warrants to the original purchaser (Purchaser or You) that the Pivotal Echo 5G and accessories (Products) included in this package are free from defects in material and workmanship under normal use and service for the period commencing upon the date of purchase and continuing for the following specified period of time after that date: All components carry a one-year warranty. What is Not Covered?

This Limited Warranty is conditioned upon proper use of Product by Purchaser. This Limited Warranty does not cover: (a) defects or damage resulting from accident, misuse, abuse, neglect, unusual physical, electrical or electromechanical stress, or modification of any part of Product, including antenna, or cosmetic damage; (b) equipment that has the serial number removed or made illegible; (c) any plastic surfaces or other externally exposed parts that are scratched or damaged due to normal use;

(d) malfunctions resulting from the use of Product in conjunction with accessories, products, or ancillary/peripheral equipment not furnished or approved by Pivotal; (e) defects or damage from improper testing, operation, maintenance, installation, or adjustment; (f) installation, maintenance, and service of Product, or (g) Product used or purchased outside the United States. What are Pivotals Obligations?

During the applicable warranty period, Pivotal will repair or replace, at Pivotals sole option, without charge to Purchaser, any defective component part of Product. To obtain service under this Limited Warranty, Purchaser must return Product to an authorized service facility in an adequate container for shipping, accompanied by Purchasers sales receipt or comparable substitute proof of sale showing the date of purchase, the serial number of Product and the sellers name and address. To obtain assistance on where to deliver the Product, call Verizon Customer Care at (800) 922-0204. Upon receipt, Pivotal will promptly repair or replace the defective Product. Pivotal may, at Pivotals sole option, use rebuilt, reconditioned, or new parts or components when repairing any Product or replace Product with a rebuilt, reconditioned or new Product. All other repaired/replaced Product will be warranted for a period equal to the remainder of the original Limited Warranty on the original Product or for 90 days, whichever is longer. All replaced parts, components, boards and equipment shall become the property of Pivotal. If Pivotal determines that any Product is not covered by this Limited Warranty, Purchaser must pay all parts, shipping, and labor charges for the repair or return of such Product. WHAT ARE THE LIMITS ON PIVOTALS WARRANTY/LIABILITY?

EXCEPT AS SET FORTH IN THE LIMITED WARRANTY CONTAINED HEREIN, PURCHASER TAKES THE PRODUCT "AS IS," AND PIVOTAL MAKES NO WARRANTY OR REPRESENTATION AND THERE ARE NO CONDITIONS, EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, OF ANY KIND WHATSOEVER WITH RESPECT TO THE PRODUCT, INCLUDING BUT NOT LIMITED TO:

THE MERCHANTABILITY OF THE PRODUCT OR ITS FITNESS FOR ANY PARTICULAR PURPOSE OR USE;

WARRANTIES OF TITLE OR NON-INFRINGEMENT;

DESIGN, CONDITION, QUALITY, OR PERFORMANCE OF THE PRODUCT;

THE WORKMANSHIP OF THE PRODUCT OR THE COMPONENTS CONTAINED THEREIN; OR COMPLIANCE OF THE PRODUCT WITH THE REQUIREMENTS OF ANY LAW, RULE, SPECIFICATION OR CONTRACT PERTAINING THERETO. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 26 of 32 ALL IMPLIED WARRANTIES AND CONDITIONS THAT MAY ARISE BY OPERATION OF LAW, INCLUDING IF APPLICABLE THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, ARE HEREBY LIMITED TO THE SAME DURATION OF TIME AS THE LIMITED WARRANTY STATED HEREIN. SOME STATES/PROVINCES DO NOT ALLOW LIMITATIONS ON HOW LONG AN IMPLIED WARRANTY LASTS, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU. IN ADDITION, PIVOTAL SHALL NOT BE LIABLE FOR ANY DAMAGES OF ANY KIND RESULTING FROM THE PURCHASE, USE, OR MISUSE OF, OR INABILITY TO USE THE PRODUCT OR ARISING DIRECTLY OR INDIRECTLY FROM THE USE OR LOSS OF USE OF THE PRODUCT OR FROM THE BREACH OF THE LIMITED WARRANTY, INCLUDING INCIDENTAL, SPECIAL, CONSEQUENTIAL OR SIMILAR DAMAGES, OR LOSS OF ANTICIPATED PROFITS OR BENEFITS, OR FOR DAMAGES ARISING FROM ANY TORT (INCLUDING NEGLIGENCE OR GROSS NEGLIGENCE) OR FAULT COMMITTED BY PIVOTAL, ITS AGENTS OR EMPLOYEES, OR FOR ANY BREACH OF CONTRACT OR FOR ANY CLAIM BROUGHT AGAINST PURCHASER BY ANY OTHER PARTY. SOME STATES/PROVINCES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU. THIS WARRANTY GIVES YOU SPECIFIC LEGAL RIGHTS, AND YOU MAY ALSO HAVE OTHER RIGHTS, WHICH VARY FROM STATE TO STATE/PROVINCE TO PROVINCE. THIS LIMITED WARRANTY SHALL NOT EXTEND TO ANYONE OTHER THAN THE ORIGINAL PURCHASER OF THIS PRODUCT AND STATES PURCHASER'S EXCLUSIVE REMEDY. IF ANY PORTION OF THIS LIMITED WARRANTY IS HELD ILLEGAL OR UNENFORCEABLE BY REASON OF ANY LAW, SUCH PARTIAL ILLEGALITY OR UNENFORCEABILITY SHALL NOT AFFECT THE ENFORCEABILITY FOR THE REMAINDER OF THIS LIMITED WARRANTY WHICH PURCHASER ACKNOWLEDGES IS AND WILL ALWAYS BE CONSTRUED TO BE LIMITED BY ITS TERMS OR AS LIMITED AS THE LAW PERMITS. THE PARTIES UNDERSTAND THAT THE PURCHASER MAY USE THIRD-PARTY SOFTWARE OR EQUIPMENT IN CONJUNCTION WITH THE PRODUCT. PIVOTAL MAKES NO WARRANTIES OR REPRESENTATIONS AND THERE ARE NO CONDITIONS, EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, AS TO THE QUALITY, CAPABILITIES, OPERATIONS, PERFORMANCE OR SUITABILITY OF ANY THIRD-

PARTY SOFTWARE OR EQUIPMENT, WHETHER SUCH THIRD-PARTY SOFTWARE OR EQUIPMENT IS INCLUDED WITH THE PRODUCT DISTRIBUTED BY PIVOTAL OR OTHERWISE, INCLUDING THE ABILITY TO INTEGRATE ANY SUCH SOFTWARE OR EQUIPMENT WITH THE PRODUCT. THE QUALITY, CAPABILITIES, OPERATIONS, PERFORMANCE AND SUITABILITY OF ANY SUCH THIRD-PARTY SOFTWARE OR EQUIPMENT LIE SOLELY WITH THE PURCHASER AND THE DIRECT VENDOR, OWNER OR SUPPLIER OF SUCH THIRD-PARTY SOFTWARE OR EQUIPMENT, AS THE CASE MAY BE. This Limited Warranty allocates risk of Product failure between Purchaser and Pivotal, and Pivotals Product pricing reflects this allocation of risk and the limitations of liability contained in this Limited Warranty. The agents, employees, distributors, and dealers of Pivotal are not authorized to make modifications to this Limited Warranty, or make additional warranties binding on Pivotal. Accordingly, additional statements such as dealer advertising or presentation, whether oral or written, do not constitute warranties by Pivotal and should not be relied upon. User License Agreement for Software IMPORTANT. READ CAREFULLY: This End User License Agreement ("EULA") is a legal agreement between you (either an individual or a single entity) and Pivotal Commware, Inc. (Pivotal) for software owned by Pivotal and its affiliated companies and its third party suppliers and licensors that accompanies this EULA, which includes computer software and may include associated media, printed materials, "online" or electronic documentation ("Software"). BY INSTALLING, COPYING, DOWNLOADING, ACCESSING, OR OTHERWISE USING THE SOFTWARE AND/OR BY USING ANY MOBILE DEVICE ON WHICH THE SOFTWARE IS EMBEDDED (INCLUSIVE OF THE SOFTWARE, THE PRODUCT), YOU AGREE TO BE BOUND BY THE TERMS OF THIS EULA. 1. GRANT OF LICENSE. Pivotal grants you the following rights provided that you comply with all terms and conditions of this EULA: You may use any Products purchased by you for your personal, non-commercial use. Your license to the Software embedded on such Products is non-exclusive, non-transferable (except as permitted under Section 6) and non-sublicensable. 2. RESERVATION OF RIGHTS AND OWNERSHIP. Pivotal reserves all rights not expressly granted to you in this EULA. The Software is protected by copyright and other intellectual property laws and treaties. Pivotal or its suppliers own the title, copyright and other intellectual property rights in the Software. The Software is licensed, not sold. 3. LIMITATIONS ON END USER RIGHTS. You may not reverse engineer, decompile, disassemble, or otherwise attempt to discover the source code or algorithms of, the Software (except and only to the extent that such activity is expressly permitted by applicable law notwithstanding this limitation), or modify, or disable any features of, the Software, or create derivative 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 27 of 32 works based on the Software. You may not rent, lease, lend, sublicense or provide commercial hosting services with the Software. 4. CONSENT TO USE OF DATA. You agree that Pivotal and its affiliates may collect and use technical information gathered as part of the product support services related to the Products provided to you, if any. Pivotal may use this information solely to improve its products and services, to provide benchmark reporting to its existing and prospective customers, and/or to provide customized services or technologies to you and will not disclose this information in a form that personally identifies you. 5. UPGRADES. This EULA applies to updates, supplements and add-on components (if any) of the Software that Pivotal may provide to you or make available to you after the date you obtain your initial copy of the Software, unless we provide other terms along with such upgrade. To use Software identified as an upgrade, you must first be licensed for the Software identified by Pivotal as eligible for the upgrade. After upgrading, you may no longer use the Software that formed the basis for your upgrade eligibility. 6. SOFTWARE TRANSFER. You may not transfer this EULA or the rights to the Software granted herein to any third party unless it is in connection with the sale of the Product. In such event, the transfer must include all of the Software (including all component parts, the media and printed materials, any upgrades, this EULA) and you may not retain any copies of the Software. The transfer may not be an indirect transfer, such as a consignment. Prior to the transfer, the end user receiving the Product must agree to all the EULA terms. 7. EXPORT RESTRICTIONS. You acknowledge that the Product is subject to export restrictions of various countries. You agree to comply with all applicable international and national laws that apply to the Product, including the U.S. Export Administration Regulations, as well as end user, end use, and destination restrictions issued by U.S. and other governments. 8. TERMINATION. This EULA is effective until terminated. Your rights under this EULA will terminate automatically without notice from Pivotal if you fail to comply with any of the terms and conditions of this EULA. Upon termination of this EULA, you shall cease all use of any Products. 9. DISCLAIMER OF WARRANTIES. You expressly acknowledge and agree that use of the Products is at your sole risk and that the entire risk as to satisfactory quality, performance, accuracy and effort is with you. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE PRODUCT IS PROVIDED "AS IS" AND WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND, AND PIVOTAL AND ITS LICENSORS (COLLECTIVELY REFERRED TO AS "PIVOTAL" FOR THE PURPOSES OF SECTIONS 9, 10 and 11) HEREBY DISCLAIM ALL WARRANTIES AND CONDITIONS WITH RESPECT TO THE PRODUCT, EITHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES AND/OR CONDITIONS OF MERCHANTABILITY, OF SATISFACTORY QUALITY OR WORKMANLIKE EFFORT, OF FITNESS FOR A PARTICULAR PURPOSE, OF RELIABILITY OR AVAILABILITY, OF ACCURACY, OF LACK OF VIRUSES, OF QUIET ENJOYMENT, AND NON-INFRINGEMENT OF THIRD PARTY RIGHTS. PIVOTAL DOES NOT WARRANT AGAINST INTERFERENCE WITH YOUR ENJOYMENT OF THE PRODUCT, THAT THE FUNCTIONS CONTAINED IN THE PRODUCT WILL MEET YOUR REQUIREMENTS, THAT THE OPERATION OF THE PRODUCT WILL BE UNINTERRUPTED OR ERROR-FREE, OR THAT DEFECTS IN THE PRODUCT WILL BE CORRECTED. NO ORAL OR WRITTEN INFORMATION OR ADVICE GIVEN BY PIVOTAL OR A PIVOTAL AUTHORIZED REPRESENTATIVE SHALL CREATE A WARRANTY. EXCEPT AS EXPRESSLY PROVIDED IN PIVOTALS LIMITED WARRANTY, SHOULD THE PRODUCT PROVE DEFECTIVE, YOU ASSUME THE ENTIRE COST OF ALL NECESSARY SERVICING, REPAIR OR CORRECTION. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES OR LIMITATIONS ON APPLICABLE STATUTORY RIGHTS OF A CONSUMER, SO THESE EXCLUSIONS AND LIMITATIONS MAY NOT APPLY TO YOU. 10. EXCLUSION OF INCIDENTAL, CONSEQUENTIAL AND CERTAIN OTHER DAMAGES. TO THE EXTENT NOT PROHIBITED BY LAW, IN NO EVENT SHALL PIVOTAL BE LIABLE FOR PERSONAL INJURY, OR ANY INCIDENTAL, SPECIAL, INDIRECT OR CONSEQUENTIAL DAMAGES WHATSOEVER, OR FOR LOSS OF PROFITS, LOSS OF DATA, BUSINESS INTERRUPTION, OR FOR ANY PECUNIARY DAMAGES OR LOSSES, ARISING OUT OF OR RELATED TO YOUR USE OR INABILITY TO USE THE PRODUCT, THE PROVISION OF OR FAILURE TO PROVIDE SUPPORT OR OTHER SERVICES, INFORMATION, SOFTWARE, AND RELATED CONTENT THROUGH THE PRODUCT OR OTHERWISE ARISING OUT OF THE USE OF THE PRODUCT, OR OTHERWISE UNDER OR IN CONNECTION WITH ANY PROVISION OF THIS EULA, HOWEVER CAUSED, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT OR OTHERWISE) AND EVEN IF PIVOTAL HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OF LIABILITY FOR PERSONAL INJURY, OR OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THIS LIMITATION MAY NOT APPLY TO YOU. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 28 of 32 11. LIMITATION OF LIABILITY. Notwithstanding any damages that you might incur for any reason whatsoever (including, without limitation, all damages referenced herein and all direct or general damages in contract or anything else), the entire liability of Pivotal under any provision of this EULA and your exclusive remedy hereunder shall be limited to the greater of (a) the actual damages you incur in reasonable reliance on the Product, up to the amount actually paid by you for the Product; or (b) US$50.00. The foregoing limitations, exclusions and disclaimers (including Sections 9, 10 and 11) shall apply to the maximum extent permitted by applicable law, even if any remedy fails its essential purpose. 12. U.S. GOVERNMENT END USERS. The Software is licensed only with "restricted rights" and as "commercial items" consisting of "commercial software" and "commercial software documentation" with only those rights as are granted to all other end users pursuant to the terms and conditions herein. 13. APPLICABLE LAW. This EULA is governed by the laws of the State of Washington, without regard to conflicts of laws principles. This EULA shall not be governed by the UN Convention on Contracts for the International Sale of Goods, the application of which is expressly excluded. If a dispute, controversy or difference is not amicably settled, it shall be finally resolved by arbitration in Seattle, Washington, USA, in accordance with the Arbitration Rules of the Washington State Commercial Arbitration Board. The award of arbitration shall be final and binding upon the parties. 14. ENTIRE AGREEMENT; SEVERABILITY. This EULA is the entire agreement between you and Pivotal relating to the Product and supersedes all prior or contemporaneous oral or written communications, proposals and representations with respect to the Product or any other subject matter covered by this EULA. If any provision of this EULA is held to be void, invalid, unenforceable or illegal, the other provisions shall continue in full force and effect. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 29 of 32 3GPP LTE LTE protocol per 3rd Generation Partnership Project a mobile telephone standards org. Appendix D Glossary Term Definition 5G-NR 5G NSA 5G SA 5G TF ADC The 5G radio system Non-Stand-Alone flavor of 3GPP 5G-NR

... requiring concurrent 4G capability to function (currently typical) Stand-Alone flavor of 3GPP 5G-NR

... able to work without 4G capability (eventually, future) Verizon 5G Task Force (aka pre-5G) Analog-Digital Converter (in electric circuitry) Az, AZ, Azimuth The left-to-right angle direction relative to nearby gNB location BW Bandwidth Commissioning

(Echo 5G) Installation and initial setup, which tunes the system to optimal functionality CPE, Customer Premises Equip. Typically: End-user obtained transceiver that distributes FWA broadband internet to devices within the home via WLAN (Wi-Fi). Effectively replaces cable/DSL internet dB, decibel A relative unit of power, used to express change in value as in increase of 3 dB --

presented on a logarithmic scale A unit of level, indicating a power ratio expressed in decibels (dB) with reference to one milliwatt (mW) DL, Downlink Data/information transmitted in the direction from gNB to CPE/UE Key performance indicators: set of useful parameters that (in this case) CPE would report to Echo 5G, and Echo 5G would display it for user Equivalent Isotropic Radiated Power, a measure of Transmit power El, EL, Elevation The up-to-down angle direction relative to distant gNodeB location E-UTRA NR dual connectivity (a flavor of NR NSA deployment) Error Vector Magnitude, a measure of quality of received signal Fixed Wireless Access. Gigabit speed A term of user-perceived throughput, as in Gbits/second gNodeB, gNB 5G NR base station Pivotal Commwares Holographic Beam Forming technology that enables Gigabit speeds beyond the reach of cable and DSL Indoor unit. The wireless power unit mounted on the interior side of the window. Low-E glass Low-Emissivity windowpanes, on which the coating that reflects sunlight also inhibits RF signals from passing into a building LTE Long-term Evolution, generally referring to technology path toward 4G speeds LTE Cat M1 A flavor of IoT (internet of things) technology under 3GPP LTE umbrella dBm KPI EIRP EN-DC EVM FWA HBF IDU 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 30 of 32 Term Definition Millimeter wave frequencies Wavelength spectrum that correlates to ~24 GHz frequencies and higher M&C Monitoring and Controlling or Monitor and Control OAM, OA&M Operations, Administration & Management/Maintenance the necessary processes for setting up and running a system Outdoor unit. The unit mounted on the outdoor side of the window. ODU RF SNR UE Radio Frequency Signal-to-Noise Ratio User Equipment typically CPE or a mobile device/smartphone UL, Uplink Data/information transmitted in the direction from CPE/UE towards gNB 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 31 of 32 Appendix E Removal Instructions To remove your Echo 5G, take the following steps.

[1] Loosen the set screws and slide the ODU off the rails

[2] Slide the end of the removal tool under the rails, starting at the bottom and carefully lift the rails away from the window.

[3] Work your way up the rails from the bottom or side.

[4] When you have loosened the adhesive enough you can carefully remove it by hand.

[5] Use WD40 and the rough side of a sponge to clean any remaining adhesive off your window. You can use window cleaner to remove any streaks left by the WD40. 2019 Pivotal Commware, Inc. All Rights Reserved. Pivotal Commware is a registered trademark of Pivotal Commware, Inc. Page 32 of 32

10801 120TH AVE NE | SUITE 200 KIRKLAND WA, 98033 | USA www.pivotalcommware.com Product Label and Location FCC ID: 2AUVU-OES3 Located on bottom of Radome plastic P a g e | 1

Federal Communications Commission DA 19-1331 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Pivotal Commware Request for Waiver of Industrial Signal Booster Labelling Requirements

) WT Docket No. 19-272 ORDER Adopted: December 26, 2019 Released: December 26, 2019 By the Chief, Mobility Division, Wireless Telecommunications Bureau:

I. INTRODUCTION 1. In this Order, we address the request for waiver of section 20.21(f) Industrial Signal Booster labeling requirements filed by Pivotal Commware (Pivotal).1 For the reasons discussed below, we grant Pivotal a partial waiver of section 20.21(f) of the Commissions rules to provide for an alternate label on its Echo 5G Subscriber Industrial Signal Booster (Device). We condition this grant, however, on certain features of Pivotals Device. II. Signal Booster Requirements Signal Booster Framework. In 2013, the Commission established a regulatory framework for signal boosters.2 In that Order, the Commission created two classes of signal boosters Consumer and Industrialwith distinct regulatory requirements.3 A Consumer Signal Booster is required to contain a series of built-in technical safeguards and is designed to minimize interference to wireless networks.4 These devices are authorized for use only in certain wireless radio service spectrum bands.5 BACKGROUND A. 2. 1 Pivotal Commware Request for Waiver of Section 20.21(f), WT Docket No. 19-272 (filed Sept. 16, 2019) (Pivotal Waiver Request). 2 See Amendment of Parts 1, 2, 22, 24, 27, 90 and 95 of the Commissions Rules to Improve Wireless Coverage Through the Use of Signal Boosters, Report and Order, 28 FCC Rcd 1663 (2013) (Report and Order). 3 Report and Order, 28 FCC Rcd at 1664-65, para. 3. 4 Id. at 1680, 1685, paras. 44, 57. In particular, [u]nder the Network Protection Standard, all Consumer Signal Boosters must: (1) comply with existing technical parameters for the applicable spectrum band of operation;

(2) automatically self-monitor certain operations and shut down if not in compliance with our new technical rules;

(3) automatically detect and mitigate oscillations in the uplink and downlink bands; (4) power down or shut down automatically when a device is not needed, such as when the device approaches the base station with which it is communicating; (5) be designed so that these features cannot be easily defeated; and (6) incorporate interference avoidance for wireless subsystems. Id. at 1685, para. 57. 5 47 CFR 20.21(e)(3); Report and Order, 28 FCC Rcd at 1677-79, paras. 36-40. Consumer Signal Boosters are authorized for use in the wireless radio service spectrum bands used for the provision of subscriber-based services under Part 22, including: Cellular (824-849 MHz and 869-894 MHz); Broadband PCS (1850-1915 MHz and 1930-

1995 MHz); AWS-1 (1710-1755 MHz and 2110-2155 MHz); 700 MHz Lower A through E (698-746 MHz) and Upper C (746-757 MHz and 776-787 MHz) Blocks; and 800 MHz Enhanced Specialized Mobile Radio (ESMR)

(817-824 MHz and 862-869 MHz). Federal Communications Commission DA 19-1331 3. All other signal boosters are Industrial Signal Boosters.6 Unlike Consumer Signal Boosters, Industrial Signal Boosters are not required to contain specific built-in technical safeguards, but they are required to be installed with explicit licensee consent and close licensee coordination.7 Both Consumer and Industrial Signal Boosters are required to include labels with text applicable to the category of signal booster.8 Signal Booster Labeling Requirements. Section 20.21(f)(1) requires that all signal boosters in the United States include specific advisories concerning the device, regardless of whether the device is classified as a Consumer or Industrial Signal Booster.9 Because Industrial Signal Boosters do not contain built-in, consumer-targeted safeguards, they are required to contain labels to prevent consumers from erroneously purchasing the device and unwittingly causing interference to wireless networks.10 Industrial Signal Boosters are required to contain the following disclosures: WARNING. This is NOT a CONSUMER device. It is designed for installation by FCC LICENSEES and QUALIFIED INSTALLERS. You MUST have an FCC LICENSE or express consent of an FCC Licensee to operate this device. Unauthorized use may result in significant forfeiture penalties, including penalties in excess of $100,000 for each continuing violation.11 4. Background on Pivotals Device. Pivotals Device is a type of Industrial Signal Booster that operates on millimeter wavelength frequencies.12 The Device contains certain features that distinguish it from a typical Industrial Signal Booster. For example, the Device may be obtained exclusively from the FCC licensee that is the users service provider.13 It is not sold at retail.14 The Device operates only on spectrum licensed to the service provider and only if properly authenticated and provisioned by the licensee, which retains the ability to control and disable the Device remotely.15 The Device operates at very low power levels and is designed for self-installation by consumers.16 B. 5. Pivotals Request Pivotal Waiver Request. On September 16, 2019, Pivotal filed a request for waiver of the Industrial Signal Booster labeling requirement under section 20.21(f) of the Commissions rules.17 Pivotal seeks a waiver of the Industrial Signal Booster labeling requirement in its entirety.18 In the alternative, Pivotal requests an alternate label and modified placement of the labeling disclosures.19 6 47 CFR 20.3. Industrial Signal Boosters are defined as [a]ll signal boosters other than Consumer Signal Boosters. 7 Report and Order, 28 FCC Rcd at 1669-70, paras. 15, 20. 8 Id. 9 47 CFR 20.21(f). Section 20.21(f)(1) requires that Consumer and Industrial Signal Booster manufacturers, distributors, and retailers ensure that all signal boosters marketed on or after March 1, 2014, include specific advisories concerning the device. 10 Report and Order, 28 FCC Rcd at 1670, para. 20. 11 47 CFR 20.21(f)(1)(B). 12 Pivotal Waiver Request at 1. 13 Id. at 2. 14 Id. 15 Id. 16 Id. 17 Id. at 1. 18 Id. at 5. 2 Federal Communications Commission DA 19-1331 6. Pursuant to the Commissions waiver standard under section 1.925 of the Commissions rules, Pivotal argues that grant of its requested waiver is warranted because application of the labeling requirements would not serve the underlying purpose of the rule.20 In support of its request for waiver, Pivotal claims that, while the underlying purpose of the labeling requirement is to prevent consumers from erroneously purchasing the Device and unwittingly causing interference to wireless networks, consumers cannot erroneously purchase the Device because it is not sold at retail, and they cannot cause interference to wireless networks because the Device does not operate without authentication by the service provider.21 7. Pivotal also claims a waiver is warranted because the unique features of Pivotals Device render the text of the label inapplicable and thus retention of the labeling requirements will result in confusion and undue concern among consumers.22 Pivotal states that including the text WARNING. This is NOT a CONSUMER device. It is designed for installation by FCC LICENSEES and QUALIFIED INSTALLERS, will cause confusion among consumers because the Device is specifically designed for self-installation by consumers.23 Pivotal also claims that the text of the warning regarding the requirement to hold an FCC license is unnecessary and confusing because consumers can only obtain the Device through their service provider, which always holds the appropriate FCC license.24 Moreover, Pivotal asserts that the text regarding penalties is irrelevant and unduly alarming because consumers cannot violate FCC regulations by using the Device.25 It also claims that the rule was intended for high-power signal boosters used in network and enterprise operations, but that its Device operates at very low radiated power levels.26 Pivotal concludes that application of the requirement would be contrary to the public interest because the labeling requirement is onerous and could create a material barrier to the deployment of the Device into the 5G ecosystem.27 8. Comments and Replies. On September 18, 2019, the Bureau placed the Waiver Request on public notice for comment.28 All commenters oppose the blanket waiver request.29 Pivotal filed in

(Continued from previous page) 19 Id. 20 47 CFR 1.925(b)(3); Pivotal Waiver Request at 3. Pivotal requested a waiver under sections 1.925 and 1.3 of the Commissions rules. We find that Pivotal has satisfied the waiver standard under section 1.925, and a discussion under section 1.3 is not necessary. 21 Pivotal Waiver Request at 4. Service providers also retain the ability to shut down and lock the Device remotely in the event a consumer terminates service or interference occurs. 22 Id. 23 Id. 24 Id. at 5. 25 Id. 26 Id. at 4. 27 Id. at 5. Pivotal claims that its Device would expedite the introduction of 5G millimeter wave broadband into the market and that the labeling requirement could create a barrier to the widespread and rapid deployment of the Device into the 5G ecosystem. 28 Wireless Telecommunications Bureau Seeks Comment on Pivotal Commware Request for Waiver of Industrial Signal Booster Labelling Rules, Public Notice, DA 19-928 (WTB Sept. 18, 2019) (Pivotal Public Notice). 29 See, e.g., Surecall Petition to Deny (filed Sept. 30, 2019) (Surecall Petition to Deny); T-Mobile Comments at 4

(filed Sept. 30, 2019) (T-Mobile Comments); Richs Contracting & Custom Audio/Video Comments (filed Oct. 3, 2019) (Richs Contracting Comments). AT&T would require conditions if the Commission grants the request. See AT&T Comments at 4-5 (filed Oct. 7, 2019) (AT&T Comments) (arguing that the Commission should condition the 3 DISCUSSION 10. Federal Communications Commission DA 19-1331 reply to the opposition.30 9. Surecall and Simple Foundry assert that the labeling requirement for Industrial Signal Boosters should continue to be enforced for all Industrial Signal Boosters.31 Surecall, Richs Contracting, and Simple Foundry claim that a grant of the requested relief would frustrate the underlying purpose of the rule to prevent interference.32 AT&T, T-Mobile, and Surecall argue that Pivotal should be required to comply with Consumer Signal Booster labeling and technical requirements because the device is akin to a Consumer Signal Booster.33 Some commenters claim that a grant of the requested relief would be contrary to the public interest because it would unfairly distort competition in the signal booster industry.34 While opposing the request, AT&T notes that, if the request is granted, it would support conditions involving certain features of the device.35 III. Standard of Review. The Commission may grant a request for a waiver under section 1.925 when: (i) the underlying purpose of the rule(s) would not be served or would be frustrated by application to the instant case, and that a grant of the requested waiver would be in the public interest, or

(ii) in view of the unique or unusual factual circumstances of the instant case, application of the rule(s) would be inequitable, unduly burdensome or contrary to the public interest, or the applicant has no reasonable alternative.36 11. Discussion. After review of the record and for the reasons discussed below, we grant the request to the extent described herein but otherwise deny the request. We find that a limited waiver permitting the following alternate label is warranted:

WARNING. This is not a CONSUMER device. This device may not be sold at retail. You MUST have an FCC LICENSE or express consent of an FCC Licensee (or express consent of your service provider) to operate this device. Antennas must be installed at least 20 cm (8 inches) from any person. Unauthorized use may result in

(Continued from previous page) request, if granted, on two key facts: (1) that the device will only be available via carriers, and (2) that licensed carriers may disable the device remotely). 30 See Reply Comments of Pivotal Commware (filed Oct. 7, 2019) (Pivotal Reply). 31 Surecall Petition to Deny at 1 (arguing that the labeling requirement for Industrial Signal Boosters serves a critically important purpose in protecting the integrity of wireless networks and should not be waived for any party); Simple Foundry Comments at 2 (filed Oct. 7, 2019) (Simple Foundry Comments) ([T]he best route forward is to hold all manufacturers to the same standard requiring that every signal booster meet the Part 20 rules or contain the full industrial booster warning label.). 32 Surecall Petition to Deny at 4; Richs Contracting Comments at 1 (We oppose this request because it would effectively permit wireless carriers to market Pivotals signal boosters directly to consumers even though the boosters do not meet the technical requirements for Consumer Signal Boosters, including the critically important Network Protection Standard (NPS).); Simple Foundry Comments at 1 (The problem with this is that multiple carriers will be operating on the frequency bands that the non-compliant Pivotal booster will be boosting, and without proper NPS in place, there is a high likelihood of negatively impacting other carriers who did not approve the booster for use on their network, and as such, have no recourse.). 33 See Surecall Petition to Deny at 2; AT&T Comments at 2; T-Mobile Comments at 3-4. 34 See Surecall Petition to Deny at 6-7 (arguing that the Commission should immediately initiate a rulemaking on expanding its rules for Consumer Signal Boosters to include the recently auctioned [millimeter wavelength]

frequencies); Richs Contracting Comments at 1. 35 See AT&T Comments at 4. 36 47 CFR 1.925. 4 Federal Communications Commission DA 19-1331 significant forfeiture penalties, including penalties in excess of $100,000 for each continuing violation. 12. In addition, we grant this waiver so that it applies only so long as Pivotals Device satisfies the following conditions: (1) the Device may be obtained exclusively from the FCC licensee that is the users service provider; (2) the Device is not distributed at retail; (3) the Device only operates with FCC licensee-provided end user equipment and is provisioned by the licensee; and (4) as with all Industrial Signal Boosters, the FCC licensee must retain control of the Device and avoid unauthorized operation and interference in the installation process.37 We anticipate Pivotal and the licensee will provide appropriate instructions for proper installation and operation. 13. As discussed above, Pivotal argues that application of the Industrial Signal Booster labeling requirements would not serve the underlying purpose of the rule and would be inequitable, unduly burdensome, and contrary to the public interest.38 In light of the Report & Order and the underlying purpose of the labeling requirement, we find that Pivotal has met the waiver standard under section 1.925 and that: (1) the underlying purpose of the rule would not be served by application in the instant case, and a grant would be in the public interest, and (2) there are unique factual circumstances of the instant case such that application of the labeling requirement would be inequitable, unduly burdensome, or contrary to the public interest. 14. We find that the underlying purposes of section 20.21(f) would not be served by application of the requirement because the rule, as originally written, contains text that is inapplicable to the particular characteristics of this device and that may confuse users and decrease compliance with Commission rules. An alternate label that eliminates the inapplicable text should reduce the likelihood of consumer confusion. The language, It is designed for installation by FCC LICENSEES and QUALIFIED INSTALLERS, is inapplicable to Pivotals Device and likely to cause confusion among consumers because the Device is specifically intended for self-installation by consumers. In the Report &

Order, the Commission stated that it consistently has adopted labeling requirements to avoid consumer confusion and provide consumers with needed information.39 By eliminating this text, this grant provides consumers with accurate information about the Devices proper use and avoids consumer confusion. We therefore waive this portion of the labeling requirement. 15. When the Commission adopted section 20.21(f), it stated that the labeling requirement was the best method to inform consumers about which devices are appropriate for their use and how to comply with our rules, as well as to decrease interference to wireless networks.40 The Commission stated that appropriately crafted labels will lead to increased compliance with Commission rules and decreased interference to wireless networks.41 Here, the underlying purposes of the labeling requirement would not be served by strict application of the rule because the label, as originally written, would not appropriately account for the unique features of Pivotals Device. Pivotals Device contains certain features that render portions of the warning inapplicable and likely to mislead consumers about the Devices proper use. A label with inapplicable text may lead to confusion and not serve to inform consumers about which devices are appropriate and how to comply. 37 We agree with AT&T that conditions should be imposed. See AT&T Comments at 4 (arguing that any grant by the Commission of the Petition should be conditioned on Pivotal only selling the device through carriers and providing a mechanism for remote carrier shutoff.). 38 Pivotal Waiver Request at 3. 39 Report and Order, 28 FCC Rcd at 1705, para. 120. 40 Id. at 1704, para. 119. We believe that appropriately crafted labeling and marketing requirements will lead to increased compliance with our rules and decreased interference to wireless networks. 41 Id. 5 Federal Communications Commission DA 19-1331 16. An alternate label with additional text that accounts for the unique features of Pivotals Device is in the public interest because it furthers the rules purpose of ensuring that consumers do not erroneously purchase the Device. Pivotal claims that consumers will not erroneously purchase the Device because it only may be obtained from the FCC licensee that is the service provider.42 It also claims that the Device will not be sold at retail.43 We agree that consumers are unlikely to purchase the Device erroneously because it is not sold at retail and can only be obtained through the consumers service provider. Nevertheless, we find that label warnings are necessary to ensure that information about the Devices proper use and sale is conveyed to consumers who potentially may purchase the Device through distribution channels not anticipated by Pivotal (i.e., through secondary markets). We therefore require that the Device contain the warning, WARNING. This is not a CONSUMER device. This device may not be sold at retail. You MUST have an FCC LICENSE or express consent of an FCC Licensee (or express consent of your service provider) to operate this device. Antennas must be installed at least 20 cm (8 inches) from any person. Unauthorized use may result in significant forfeiture penalties, including penalties in excess of $100,000 for each continuing violation. 17. An alternate label that informs consumers about the Devices proper use promotes safe operation of the Device, reduces the risk of interference, and facilitates the resolution of interference events should they occur.44 We require Pivotals Device to include the warning, This is not a CONSUMER Device, which informs consumers that the Device is an Industrial Signal Booster that requires an FCC license or the express consent of an FCC licensee and not a Consumer Signal Booster, which is otherwise suitable for their use. We also require the language, You MUST have an FCC LICENSE or express consent of an FCC Licensee (or express consent of your service provider) to operate this device, which also facilitates the resolution of interference events by informing consumers about use requirements.45 The additional language, or express consent of your service provider, avoids consumer confusion by making clear that operation of the Device is authorized when consumers obtain the Device through their service providers. We also require language involving penalties to further enforce proper sale and operation of the Device. 18. We note that Pivotal supports including the information regarding separation distance requirements that applies to Consumer Signal Boosters, and we conclude that providing such RF safety-

related information is in the public interest, as it promotes safe operation and use of the Device.46 We therefore require that the Device contain the warning, Antennas must be installed at least 20 cm (8 inches) from any person. 19. We agree with commenters that a blanket waiver of the labeling requirements should not be granted because labels concerning the Devices use requirements are still necessary to satisfy the purposes of the rule.47 Moreover, some form of labeling is required for all signal boosters in the United States, regardless of whether the device is a Consumer Signal Booster or an Industrial Signal Booster.48 We do not find that Pivotal has presented such an unusual or unique factual circumstance that the labeling requirement should be waived in its entirety. The Commissions rules provide for exemptions to certain labeling requirements only when the device is so small or for such use that it would be impracticable to 42 Pivotal Waiver Request at 4. 43 Id. 44 Report and Order, 28 FCC Rcd at 1707, para. 124. 45 Id. 46 See Letter from Robert S. Koppel, Counsel to Pivotal Commware, to Marlene H. Dortch, Secretary, FCC, WT Docket No. 19-272, at 2 (filed Oct. 30, 2019) (Pivotal Ex Parte). 47 See, e.g., Surecall Petition to Deny at 1; T-Mobile Comments at 4; Richs Contracting Comments at 1. 48 47 CFR 20.21(f). 6 Federal Communications Commission DA 19-1331 label it with the required language.49 We therefore agree with commenters that Pivotal should be required to place a label on its device. 20. To the extent that commenters express concerns about the risk of interference due to the technical operation of the Device, and not due to improper use by consumers, we find these arguments misplaced.50 Technical operation of the Device is evaluated during the equipment authorization process.51 If the Device is deemed out of compliance with the Commissions technical rules, it will not be authorized. Thus, concerns about the Devices safe and effective operation are beyond the scope of this proceeding, which only addresses the Devices compliance with labeling requirements.52 21. Some commenters argue that the Device is akin to a Consumer Signal Booster and that both Consumer Signal Booster labelling and technical requirements should apply to prevent interference.53 Because the Device does not meet the technical specifications for Consumer Signal Boosters, it is considered an Industrial Signal Booster by rule.54 Consumer Signal Booster requirements are therefore inappropriate. Nevertheless, the warning, You MUST have an FCC LICENSE or express consent of an FCC Licensee (or express consent of your service provider) to operate this device, facilitates coordination with providers and assists in interference prevention and proper installation and operation.55 Moreover, Pivotal claims that the Device operates only with authentication and provisioning by a consumers service provider and that service providers retain remote control over the Device, which we agree will reduce the risk of interference and facilitate the resolution of these issues should they occur.56 22. In conclusion, for the reasons discussed above, we find that Pivotal has met the standard for section 1.925 of the Commissions rules and grant a limited waiver of the Industrial Signal Booster labeling requirements. On our own motion, we find that, to the extent Pivotals Device is manufactured, distributed, and sold in compliance with this waiver, the relevant manufacturers, distributors, and retailers are in compliance with the section 20.21(f)(1). IV. Accordingly, IT IS ORDERED that, pursuant to section 1.925(b)(3) of the Commissions rules, 47 CFR 1.925(b)(3), the request of Pivotal Commware for a partial waiver of section 20.21(f) of the Commissions rules, 47 CFR 20.21(f), IS GRANTED to the extent specified herein. ORDERING CLAUSES 23. 49 See id. 15.19(a)(5); 2.925(f). 50 See, e.g., Surecall Petition to Deny at 2. 51 We require Pivotal include this waiver in its authorization application. 52 See, e.g., Surecall Petition to Deny at 1. 53 See id. at 2; AT&T Comments at 2; T-Mobile Comments at 3-4; Richs Contracting Comments at 1 (arguing that grant of the request would effectively permit wireless carriers to market Pivotals signal boosters directly to consumers even though the boosters do not meet the technical requirements for Consumer Signal Boosters . ). 54 47 CFR 20.3. 55 Report and Order, 28 FCC Rcd at 1704, para. 118. 56 Pivotal Waiver Request at 2. 7 Federal Communications Commission DA 19-1331 24. These actions are taken under delegated authority pursuant to sections 0.331 and 0.131 of the Commissions rules, 47 CFR 0.331, 0.131. FEDERAL COMMUNICATIONS COMMISSION Roger S. Noel Chief, Mobility Division Wireless Telecommunications Bureau 8

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| L KIRKLAND WA, 98033 | USA COMMWARE www.pivotalcommware.com December 26", 2019 To:

PCTEST Certification Body 7185 Oakland Mills Road Columbia, MD 21046 Subject: Attestation Letter for Signal Booster Warning Label Product: Echo 5g Signal Booster (Model Number: OES3) FCC ID: 2AUVU-OES3 To Whom It May Concern, Pursuant to 47 CFR 20.21(f)(1)(i-iv), this letter is to confirm that Pivotal Commware hereby attests that the warning label message will be shown in the following locations:

In online, point-of-sale marketing materials In the Quick Start Guide (printed) and Users Manual (ontine) On the outside packaging of the device Ona label affixed to the device The warning label message has been revised per waiver request DA-19-1331, adopted December 26", 2019 and will read:

WARNING. This is nota CONSUMER device. This device may not be sold at retail. You MUST have an FCC LICENSE or express consent of an FCC Licensee (or express consent of your service provider) to operate this device. Antennas must be installed at least 20 cm (8 inches) from any person. Unauthorized use may result in significant forfeiture penalties, including penalties in excess of $100,000 for each continuing violation. Sincerely, Eric J. Black Chief Technical Officer Pivotal Commware Page |1

PAIVV THN 10801 120 AVE NE | SUITE 200

| | KIRKLAND WA, 98033 | USA COMMWARE www. pivotalcommware.com November 18", 2019 To:

PCTEST Certification Body 7185 Oakland Mills Road Columbia, MD 21046 Subject: Authorization Letter for FCC ID: 2AUVU-OES3 To Whom It May Concern, We, the undersigned, hereby authorize PCTEST Engineering Lab to act on our behalf in all matters relating to applications for equipment authorization, including the signing of all documents relating to these matters. All acts carried out by PCTEST Engineering Lab on our behalf shall have the same effect as acts of our own. We also hereby certify that no party to this application is subject to a denial of benefits, including FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S. C. 862. Chief Operating Officer Pivotal Commware Page |1

I\V/ THN 10801 120 AVE NE | SUITE 200

| J | L KIRKLAND WA, 98033 | USA COMMWARE www.pivotalcommware.com November 18", 2019 To:

Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 Subject: Long Term/Permanent Confidentiality Request for FCC ID: 2AUVU-OES3 To Whom It May Concern, Pursuant to CFR 47 0.457 and 0.459, we respectfully request permanent confidential treatment of the following exhibits accompanying this application (see KDB 726920):

Block Diagram Schematics Operational Description Parts List The above materials contain trade secrets and proprietary information not customarily released to the public. The public disclosure of these materials may be harmful to the applicant and provide unjustified benefits to its competitors. We, the applicant, understand that disclosure of this application and all accompanying documentation will not be made before the date of the Grant for this application. ris Brandon Chief Operating Officer Pivotal Commware, Inc. Page |1

[ | \V TAN 10801 120 AVE NE | SUITE 200 I KIRKLAND WA, 98033 | USA COMMWARE www.pivotalcommware.com November 18", 2019 To:

Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 Subject: Short Term Confidentiality Request for FCC ID: 2AUVU-OES3 To Whom It May Concern, Pursuant to CFR 47 0.457 and 0.459, and to avoid premature release of sensitive information prior to marketing or release of the product to the public, we respectfully request confidential treatment of the following exhibits accompanying this application for a period of 180 days (see KDB 726920):

internal Photographs External Photographs Test Setup Photographs User Manual/Quick Start Guide The above materials contain trade secrets and proprietary information not typically released to the public. The public disclosure of these materials may be harmful to the applicant and provide unjustified benefits to our competitors. We, the applicant, understand that disclosure of this application and all accompanying documentation will not be made before the date of the Grant for this application. Sincerely, /

ft Z Oa Chris Brandon Chief Operating Officer Pivotal Commware, Inc. Page |1