FCC ID: YESTX91513 Powercaster Transmitter

Illuminated product packaging Illuminated product packaging Illuminated product labeling Illuminated product labeling is provided to the User Manual Transmitter TX91513 915 MHz Transmitter PRODUCT DESCRIPTION transmitter has The Powercast TX91513 transmitter power to product been designed to provide power in a store The in a store. labels and packaging labels and packaging durable plastic case TX91513 is housed in a durable with several mounting options. Operational with several mounting options. Operational DC power power connector. The TX91513 includes a status includes a status LED to provide feedback on functional LED to provide feedback on functional state. The TX91513 has a factory set, fixed has a factory set, fixed power output of 3W EIRP. Once properly Once properly initiated by mounted, initiated mounted, applying power to the TX91513. FEATURES FCC approved Flexible mounting options Fully integrated system Transmits power Wide temperature range PRODUCT CONTENTS The following items are included:

transmission transmission is is Qty Description 1 915 MHz transmitter 1 Power supply Power supply cable 1 Quick Start instruction card 1 Quick Start instruction card APPLICATIONS are registered trademarks of Powercast Corporation. Powercast, Lifetime Power, Powerharvester, and Powercaster are registered trademarks of Powercast Corporation. Powercast, Lifetime Power, Powerharvester, and Powercaster All other trademarks are the property of their respective owners. All other trademarks are Powercast products and technology are covered by one or more of the following patents and other patents pending:

Powercast products and technology are covered by one or more of the following patents and other patents pending:

Powercast products and technology are covered by one or more of the following patents and other patents pending:

6,289,237 | 6,615,074 | 6,856,291 | 7,027,311 | 7,057,514 | 7,639,994 | 7,643,312 | 7,812,771 | 7,844,306 | 7,868,482 | 7,898,105 7,844,306 | 7,868,482 | 7,898,105 6,289,237 | 6,615,074 | 6,856,291 | 7,027,311 | 7,057,514 | 7,639,994 | 7,643,312 | 7,812,771 |

| 9,107,579 | 9,251,699 | 9,706,924 7,925,308 | 8,159,090 | 8,350,255 | 8,432,062 | 8,461,817 | 8,621,245 | 9,000,616 | 9,021,277 | 9,107,579 | 9,251,699 | 9,706,924 7,925,308 | 8,159,090 | 8,350,255 | 8,432,062 | 8,461,817 | 8,621,245 | 9,000,616 | 9,021,277 Rev 1 2019/8 Users Manual - TX91513 Transmitter User www.powercastco.com Page 1 User Manual TX91513 915 MHz Transmitter SET-UP AND OPERATION 1. Mount the TX91513 in the desired location under or behind the store shelf with the Powercast logo and status LED facing the direction of the package and labels. 2. Plug the DC connector of the power supply into the connector on the TX91513. Plug the power supply into a 120V outlet. 3. When the green LED illuminates, the TX91513 is active and transmitting radio frequency

(RF) energy. 4. Note: The TX91513 must be installed at least 20cm back from the edge of the store shelf. The labels and packaging must be located less than or equal to 1m from the TX91513. The status LED indicates the following operating conditions:

LED Off Green Red Blinking Red Status Off Active Idle Fault Description 5VDC is not applied Transmitting normally TX91513 is powered but not actively transmitting TX91513 is in a fault condition such as overheating SPECIFICATIONS Item Frequency Power output Beam pattern Approvals Operating Temperature Environment Mounting Power Color Dimensions Description 915 MHz Center Frequency 3 watts EIRP 70 width, 130 height Horizontal Polarization United States - FCC ID: YESTX91513

-20C to 40C Indoor use only Mount in the desired location to create a power area. 2 keyholes (See mechanical drawing for dimensions) for wall mounting 5VDC/1A through included Power Supply Black/Blue 7.3 2.1 1.4 (185.4 x 53.3 x 35.6 mm) Rev 1 2019/8 Users Manual - TX91513 Transmitter www.powercastco.com Page 2 User Manual Transmitter TX91513 915 MHz Transmitter MECHANICAL (REAR VIEW) Dimensions in inches

*Dimensions in inches Rev 1 2019/8 Users Manual - TX91513 Transmitter User www.powercastco.com Page 3 User Manual TX91513 915 MHz Transmitter SUPPORT Technical support for Powercast products can be initiated through the following methods:

Website contact form:

Telephone:

http://www.powercastco.com/contact/

+1 412-455-5800 COMPLIANCE STATEMENTS This device is intended to be located under or behind a store shelf to illuminate product labels and packaging on the shelf. Changes or modifications not expressly approved by Powercast could void the users authority to operate the equipment. Use and maintain device only as specified in this manual. This equipment has been tested and found to comply with Part 18 of the FCC Rules. These limits are designed to provide reasonable protection against harmful interference in an 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 of the following measures:

Reorient or relocate the receiving antenna. Connect the equipment into an outlet on a circuit different from that to which the Increase the separation between the equipment and receiver. receiver is connected. Consult the dealer or an experienced radio/TV technician for help. WARNING!

FCC Radiation Exposure Statement:

This equipment complies with FCCs RF radiation exposure limits set forth for an uncontrolled environment under the following conditions:

1. This equipment should be installed and operated such that a minimum separation distance of 20cm is maintained between the radiator (antenna) & users/nearby persons body at all times. 2. This transmitter must not be co-located or operating in conjunction with any other antenna or transmitter. Rev 1 2019/8 Users Manual - TX91513 Transmitter www.powercastco.com Page 4 User Manual TX91513 915 MHz Transmitter IMPORTANT NOTICE Information furnished by Powercast Corporation (Powercast) is believed to be accurate and reliable. No license, express or implied, to any intellectual property rights is granted by this document. No responsibility is assumed by Powercast for its use, nor for any infringements of patents or other rights of third parties that may result from its use. Powercast assumes no liability for misuse of this product. Specifications are subject to change without notice. No license is granted by implication or otherwise under any patent or patent rights of Powercast. Trademarks and registered trademarks are the property of their respective owners. POWERCAST PRODUCTS (INCLUDING HARDWARE AND/OR SOFTWARE) ARE NOT DESIGNED OR INTENDED TO BE FAIL-SAFE, FAULT TOLERANT OR FOR USE IN ANY APPLICATION THAT COULD LEAD TO DEATH, PERSONAL INJURY OR SEVERE PROPERTY OR ENVIRONMENTAL DAMAGE

(INDIVIDUALLY AND COLLECTIVELY, CRITICAL APPLICATIONS), SUCH AS LIFE-SUPPORT OR SAFETY DEVICES OR SYSTEMS, CLASS III MEDICAL DEVICES, NUCLEAR FACILITIES, APPLICATIONS THAT AFFECT CONTROL OF A VEHICLE OR AIRCRAFT, APPLICATIONS RELATED TO THE DEPLOYMENT OF AIRBAGS, OR ANY OTHER CRITICAL APPLICATIONS. CUSTOMER AGREES, PRIOR TO USING OR DISTRIBUTING ANY SYSTEMS THAT INCORPORATE POWERCAST PRODUCTS, TO THOROUGHLY TEST THE SAME FOR SAFETY PURPOSES. CUSTOMER ASSUMES THE SOLE RISK AND LIABILITY OF ANY USE OF POWERCAST PRODUCTS IN CRITICAL APPLICATIONS, SUBJECT ONLY TO APPLICABLE LAWS AND REGULATIONS GOVERNING LIMITATIONS ON PRODUCT LIABILITY. Rev 1 2019/8 Users Manual - TX91513 Transmitter www.powercastco.com Page 5 User Manual TX91513 915 MHz Transmitter WARRANTY THIS LIMITED WARRANTY applies solely to standard transmitters manufactured by or on behalf of Powercast. Subject to the limitations herein, Powercast warrants that transmitters, when delivered by Powercast or its authorized distributor, for one (1) year following the delivery date, will be free from defects in material and workmanship and will substantially conform to Powercast publicly available specifications for such products in effect at the time of delivery. This limited warranty excludes: (i) engineering samples (which are provided AS-IS without warranty); (ii) bare circuit boards (iii) development products (such as boards and cables); (iv) design defects or errors known as errata; (v) transmitters procured through unauthorized third parties; and (vi) transmitters that have been subject to misuse, mishandling, accident, alteration, neglect, unauthorized repair or installation. Furthermore, this limited warranty shall not apply to the use of covered products in an application or environment that is not within Powercast specifications or in the event of any act, error, neglect or default of Customer. If such Powercast products fail to conform to the warranty above, the exclusive remedy of Customer and the sole liability of Powercast shall be, at the option of Powercast, to replace or repair the affected products, or to refund to Customer the price of the affected products. The availability of replacement products is subject to product discontinuance policies at Powercast. Customer may not return products without first obtaining a customer return material authorization

(RMA) number from Powercast. THE WARRANTIES SET FORTH HEREIN ARE EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES, REMEDIES AND CONDITIONS, WHETHER ORAL OR WRITTEN, EXPRESS OR IMPLIED. POWERCAST DISCLAIMS ALL OTHER WARRANTIES, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING, WITHOUT LIMITATION, ANY WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT, AND ANY WARRANTY THAT MAY ARISE FROM COURSE OF DEALING, COURSE OF PERFORMANCE, OR USAGE OF TRADE. IF POWERCAST CANNOT LAWFULLY DISCLAIM IMPLIED WARRANTIES UNDER THIS LIMITED PRODUCT WARRANTY, ALL SUCH IMPLIED WARRANTIES, INCLUDING WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, ARE LIMITED IN DURATION TO THE WARRANTY PERIOD (AS DEFINED ABOVE). YOUR SOLE REMEDY WITH RESPECT TO ANY BREACH OF THE LIMITED PRODUCT WARRANTY SHALL BE THE REPAIR OR REPLACEMENT OF THE DEVICE AS SPECIFIED IN THE LIMITED PRODUCT WARRANTY. POWERCAST IS NOT RESPONSIBLE FOR DIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES RESULTING FROM ANY BREACH OF WARRANTY OR UNDER ANY OTHER LEGAL THEORY INCLUDING, BUT NOT LIMITED TO, LOST PROFITS, DOWNTIME, GOODWILL, DAMAGE TO OR REPLACEMENT OF EQUIPMENT AND PROPERTY, AND ANY COSTS OF RECOVERING, REPROGRAMMING, OR REPRODUCING ANY PROGRAM OR DATA STORED IN OR USED WITH A SYSTEM CONTAINING POWERCAST TRANSMITTERS. Some states do not allow the exclusion or limitation of incidental or consequential damages or exclusions or limitations on the duration of implied warranties or conditions, so the above limitations or exclusions may not apply to you. This limited product warranty gives you specific legal rights, and you may also have other legal rights which vary from state to state. Rev 1 2019/8 Users Manual - TX91513 Transmitter www.powercastco.com Page 6

ey ot pie 620 Alpha Drive Pittsburgh, PA 15238 +1 412-455-5800 POWERCAST p 8 June 17, 2019 To: Federal Communications Commission 7435 Oakland Mills Road Columbia, MD 21046-1609 Bureau Veritas Consumer Products Services Inc. One Distribution Center Circle Suite #1 Littleton, MA 01460 Re: Confidentiality Request Gentlemen:

This letter is to comply with 47 CFR 0.457(d)(2) pertaining to confidential material. Powercast Corporation requests that the following documents regarding this submission for FCC ID YESTX91513 be kept confidential:

1. Schematics 2 Block Diagram 3; Circuit/Technical Description The material above contains technical data, which would customarily be guarded from competitors. Sincerely, Charles Greene CTO Powercast Corporation 620 Alpha Drive Pittsburgh, PA 15238 412-455-5800

Angela Hsiao From:

Sent:

To:

Subject:

oetech@fcc.gov Wednesday, March 11, 2020 6:18 AM TCBMail Response to Inquiry to FCC (Tracking Number 584840) (TCB) Inquiry on 08/12/2019 :

Inquiry:

Submitting PAG for FCC IDs YESTX91513; TC323619 and YESTX91511B; TC640713 We are submitting a PAG in order to determine the RF Exposure evaluation requirements for two Part 18 wireless power transfer devices, as required by KDB 680106 D01 v03 Section 2)d). The device was improperly certified by the TCB without having gone through the required PAG procedure, so the approvals were set aside by the FCC with the following correspondence (reference number 444400):

Grants for Application TC640713 for FCC ID YESTX91511B and TC 323619 for FCC ID YESTX91513 are set set-aside because the applications are not in accordance with the provisions of the commission rules:1. incorrect extrapolation factor of 40dB/decade, instead of the Part 18 20dB/decade extrapolation factor. 2. Inappropriately using the same RF Exposure reports for part 15 devices not in accordance with commission policy.3. Advertising and Claiming use conditions not approved for the grant conditions. The items indicated above must be submitted before processing can continue on the above referenced application. Failure to provide the requested information within 30 days of the original e-mail date may result in application dismissal pursuant to Section 2.917(c). The lab is working on resolving the first finding, but asking for clarification of the second and third findings produced this further message from the FCC:

At this point the devices cannot be authorized under Part 18 since I does not meet the intent of local usage. Please file a PAG as per our KDB guidance on wireless charging for any other consideration. Please provide guidance for this matter. Thank you. FCC response on 08/14/2019 Hello. As per KDB 680106 D01 v03 Section 2(c):

"For WPT systems designed to provide power over a distance; for example, to facilitate chargingmultiple client devices simultaneously or for loosely coupled systems that permit operation atdistance, the requirement to generate and use RF energy locally as specified in Section 18.107(c) maynot be met. For any system where there is a separation distance between the primary and client; forexample, where the client devices are not inserted or placed directly on the charger, prior approvalfrom the FCC is required for authorization under Part 18. At the present time, FCC considers "local" under Part 18 rules to be less than 1m distance. In order to obtain Part 18 equipment authorization, additional information must be submitted to detail how the WPT devices will not charge client's beyond the 1m local distance. Additionally, it has been further noted in the user's manual, 1 and by recent manufacture's public announcement, that their WPT devices are advertised as being capable of operating with "coverage area similiar to Wi-Fi at distances up to 80 feet (24 meters)". Here is an excerpt of the manufacture's public announcement:

Creating a coverage area similar to Wi-Fi, Powercasts RF wirelesspower transmitters automatically power enabled products that come within rangefor smart, carefreewireless charging. Charging range and rate depend on a devices powerconsumption; power-hungry products charge best at close range, while thetransmitters can power low-power devices such as sensors up to 80 feet (24 meters).The transmitters use the 915-MHz ISM band to send RF energy over the air toPowercasts tiny Powerharvester receiver chip embedded in products,which converts it to usable direct current (DC) to either directly powerbatteryless devices, or recharge devices batteries. The robust technologycomplies with the FCCs current one-watt power limit for Part 15 deployments,but has power capabilities well beyond that to evolve as FCC standards evolve. Last, please provide additional details specific to the WPT load modulation characteristics for the two WPT devices referenced in this inquiry. After review of TC 323619 and TC 640713 Part 18 WPT applications, the provided technical specifications identified both WPT devices designed to use Direct Sequence Spread Spectrum modulation. Please confirm that the WPT devices comply with load modulation requirement in KDB 680106 D01 Section 2(a):

Systems that use loadimpedance changes also called load modulation on the client device at the fundamental transferfrequency with limited communication for the sole purpose of load management may be authorizedunder Part 18. The load modulation must be integral to transfer system power management andcontrol, and must be used only to the extent necessary to enable safe and efficient operation such asrapid shut-down in response to over-voltage conditions, reporting of charging status and identificationof invalid devices. For devices authorized under Part 18 such load modulation may not be used tocommunicate any other information, such as prioritization of devices for charging and the transfer ofany other data, for example extended system data, images or music.

---Reply from Customer on 08/21/2019---

Please see Powercast response below. This illuminated packaging and labeling application necessarily has a small separation distance between the primary (WPT) and the client (multiple lighted packages). However, for these devices, the requirement that the client be 1 meter or less from the WPT is met. The clients do not illuminate with adequate performance beyond 1 meter from the WPT. Powercast will update the manual to specify that the distance between the WPT and client must be less than or equal to 1 meter. Regarding the WiFi coverage announcement, this statement is incorrect for the devices sought to be certified and has been removed from the companys website. Regarding load modulation, the WPT does not use load modulation. Both WPTs use a Direct Sequence Spread Spectrum (DSSS) chip and occupy a bandwidth similar to a Direct Sequence Spread Spectrum device. However, there is no data exchange between the WPT and the clients. Thank you.

---Reply from Customer on 08/26/2019---

Please help to review the applicant response above from 8/21 and please help to respond. Thank you. FCC response on 08/28/2019 Hello. Please note that the issues in KDB inquiry 651454 are now being continued in 584840; that is,... 2

--Reply from Customer on08/26/2019--- Mitchell Lazarus The applicant is addressing these issues in PAG no. 584840submitted by its TCB, Bureau Veritas Consumer Products Services Inc., onWednesday, August 21, 2019, and related documents. More importantly, we are still waiting for a new compliance report to be submitted which uses Part 18 20dB/decade extrapolation factor. Being that the first test report exhibit was submitted using an incorrect extrapolation factor of 40dB/decade, we would require a detailed explanation in the revised test report to indicate how a marginally complaint device using a 40dB/dec extrapolation factor would comply using a 20dB/decade extrapolation factor. In other words, was the device's output level reduced by more than 30dB in order to achieve the limit?

Also, DSSS modulation (as referenced in the device's modulation specifications) is typically authorized and used for Part 15 communications; so, DSSS modulation cannot be permitted under Part 18 rules at this time.

---Reply from Customer on 08/29/2019---

The device was retested and passed withthe correct 20dB/decade extrapolation factor. The test lab provided this explanationfor the earlier, incorrect readings at 40 dB/decade and their assurance thatthe current, 20dB/decade readings are correct:

"The original data below 30MHz improperlymeasured the noise floor, not the device. Those data consisted ofmax-hold peak readings and there was no pre-amp. The 1MHz reading in theoriginal set is noise floor (21dB is typical for the analyzer). Becausethe wrong limit correction factor was used at the time, the fact that themeasured noise floor at 1MHz was over the limit was not noticed. Thismeasurement does not accurately represent theemissions of the product at 1MHz. The loop antenna used for the new, 20 dB/decade data set has a built-inpre-amp. (In the data tables, the pre-amp gain is included in the antennafactor.) This improves the measured signal-noise ratio at the spectrumanalyzer. With this improved test set-up, the measurement at 1MHz is an accuratemeasurement of the product's emissions."

The device does not send data and doesnot use DSSS. Earlier references to DSSS were incorrect. We haveremoved all references to DSSS from the manuals. The updated compliance report andmanuals will be provided next week. Thank you. FCC response on 08/30/2019 Hello. From a policy perspective, we are still not clear how the WPT devices comply with the Part 18 use within 1m

"local" requirement. Please provide evidence how the manufacture intends to limit radiation beyond 1m distance; especially, since the manufacture, as of today, continues to advertise WPT charging over distance on their website. Technically speaking, the labs revised test report appears to contain serious reported errors in the measured results; particularly with the purported -97.3dB/m correction factor at 914.737 MHz on page 7 of 35 of 4370216 test report rev2 document. Please provide correction factors documentation for Sunol JB1, including all associated cable loss factors and preamplifiers in order to clarify how the the aforementioned -97.3 dB/m correction factor is achieved. 3

---Reply from Customer on 09/23/2019---

Hello, The clients do not illuminate with adequate performance beyond 1 meter from the WPTbecause the output power of either WPT is limited (both less than 1W, 446.7mWfor TX91511B, 741.3mW for TX91513). The manual has been updated tospecify a 1 meter maximum distance. The professional installation and thestructure of the store shelves along with instructions in the manual ensure theclients are within 1 meter of the WPT. The WPTs will beprofessionally installed in a commercial setting and there will be no sales toconsumers. Thecurrent marketing material on the website is for the existing Part 15WPTs. This material will not be used for these Part 18 WPTs. ThePart 18 WPT marketing material will clearly represent the use case and thelocal requirement of 1 meter. Thelab is currently editing the report. Theupdated manuals are attached. Thank you. FCC response on 09/24/2019 Hello. Thanks for your response; however, on Aug 30, 2019, we requested evidence how the manufacture intends to limit the products radiation within the 1m local distance. Providing a statement in lieu of evidence will not satisfy our requirement to assess the device's radiative field strength decay plots over distance, in the form of practical data. Furthermore, we have now requested multiple revisions of the EMC test report in order to clarify serious ambiguous measurement and reporting errors. Please attach a lab company signed and written statement which addresses all the EMC concerns raised in this KDB inquiry. Last, we still await the revised EMC report to include all the information, as requested on Aug 30, 2019. Thank you.

---Reply from Customer on 02/24/2020---

Powercast has requested the TCB to provide the attached updated test reports based on the results of the call between Powercast and FCC. These reports include updated EMC test reports and a new additional report for field strength measurements and performance data from Keystone Compliance. Please review. Thank you. FCC response on 03/11/2020 Thanks for submitting an updated EMC test report, and the Keystone Compliance field strength measurement report. In general, we accept the test chamber results; however, we request Part 18 test site equivalency examination data in the form of practical data to be submitted, as specified in Section 2.1 of MP-5: 1986. We also request removing all ANSI C63.4/CISPR 22 test method information starting on page 21 of 43 of the EMC test report, as Part 18 of the rules require test setups according to MP-5 not ANSI C63.4 or CISPR. Attachment Details:

4 User manual - TX91511B User manual - TX91511B User manual - TX91513 ES1365-1 FCC Part 18 Final report revised ES2174-2 Final report rev Keystone compliance 1911-140E powercast report - Rev A Do not reply to this message. Please select the Reply to an Inquiry Response link from the OET Inquiry System to add any additional information pertaining to this inquiry. 5

oetech@fcc.gov Wednesday, November 17, 2021 3:03 PM Certifications North America OET KnowledgeBase Inquiry Confirmation, Tracking Number 864718 Your inquiry has been received by the FCC and it's been assigned tracking number is 864718. Inquiry Details on 12/04/2020:

Angela Hsiao From:

Sent:

To:

Subject:

Inquiry:

Hello, This is for response to PAG with tracking Number 584840 - it was closed by OET without resolution. Attached, please find original inquiry and response, revised reports, and Chamber NSA reports. Please help to review.

---Reply from Customer on 12/14/2020---

Dear FCC, Just following up to our previous message. This is for response to PAG with tracking Number 584840 - it was closed by OET without resolution. Attached, please find original inquiry and response, revised reports, and Chamber NSA reports. Please help to review. Thank you.

---Reply from Customer on 12/23/2020---

Hello, Please review and advise.

---Reply from Customer on 01/15/2021---

1 Dear FCC, We are following-up in regards to our previous message as the applicant is pushing for resolution. This is for response to PAG with tracking Number 584840 - it was closed by OET without resolution. Attached, please find original inquiry and response, revised reports, and Chamber NSA reports. Please help to review. Thank you.

---Reply from Customer on 02/08/2021---

Dear FCC, In case our previous message was missed, we are following-up in again regards to our previous message as the applicant is pushing for resolution. This is for response to PAG with tracking Number 584840 - it was closed by OET without resolution. Attached to this KDB, please find original inquiry and response, revised reports, and Chamber NSA reports. Please help to review. Thank you. FCC response on 03/01/2021 Hello. We have reviewed the information in this KDB inquiry, and the information in the reference KDB inquiry 584840, and continue to have serious ongoing concerns that our requested information is not being provided. Although you have provided other information and exhibits worthy of review, there are serious concerns still open that have not been addressed; specifically, our request for practical test site equivalency data for the Open Field Site (OFS) to Open Area Test Site for below 30 MHz, and also the (OATS) to (SAC) test site equivalency data comparison for above 30 MHz. KDB 584840 documents multiple requests for this information which still has not been provided. In the most revised test report submission in this KDB inquiry, we note that emission tests was examined atop an OATS for below 30 MHz, in a SAC between 30 MHz to 1 GHz, then back onto the OATS for 1-10 GHz. Per MP-5 Section 2.1, results provided from an "equivalent" test site can only be excepted when practical examination to compare both test site has been submitted for review. 2 Since measurements for below 30 MHz and above 1 GHz was recorded on the OATS, please provide your OATS test site layout dimensions and expand on the test setup illustrations in the test report that illustrate moisture absorbing electromagnetic barriers between OATS EUT turntable and the OATS Test Antenna Mast. Please expand on the OATS "obstruction free from metallic object and how the OATS test site is compliant to CISPR 16. Based on the submitted test report, it is apparent from the submitted 3m radiated emission test data that the EUT radiates fundamental/harmonic RF Energy beyond the Part 18 1m "Local" distance requirement. Radiation beyond the 1m distance is not compliant to Part 18 policy that the device not radiate beyond the 1m distance. In KDB 584840, we have indicated multiple times that this must be demonstrated to show that the EUT complies with the 1m "local" requirement in form of plotting E/H field roll-off from 1m and beyond, to showing that clients do not charge beyond the 1m boundary.

---Reply from Customer on 08/04/2021---

---- Inquiry reopened by the FCC ---

FCC response on 08/04/2021 Dear Inquirer, following on recent clarifications, we are requesting to provide an additional exhibit in the operational description section of your application stating the following (or any equivalent edited version):

By design, the WPT ceases to operate before reaching 1 m distance. This is because the load of the WPT receiver consists of an LED, and when the WPT received voltage goes below the (LED) diode characteristic threshold the system, for all intents and purposes, shuts off. In this case, the design parameters ensure that the received voltage falls below the LED threshold when the distance between the WPT transmitter and receiver is less than one meter. Without holding the grant, the PAG item for these applications is approved for further TCB grant processing. Please reply to this KDB with the notification of that the requested exhibit has been uploaded. Best regards, OET Staff

---Reply from Customer on 09/07/2021---

Dear FCC, As requested attached are updated operational descriptions for the TX91511B and TX91513 Part 18 devices. The descriptions were updated with the guidance from the FCC and are ready for FCC review. If acceptable, the applicant (Powercast) can then 3 repeat the Part 18 emissions testing and provide updated test reports to the FCC for the 2 devices. Thank you. FCC response on 09/25/2021 Dear Inquirer, the proposed text in the documents dated Sept. 7 is acceptable. Please upload the new exhibit in the operational description section of you filing. You may the proceed with further grant processing. Best regards, OET Staff

---Reply from Customer on 11/17/2021---

Dear FCC, The 731 applicationunder FCC ID: YESTX91513, TC323619 cannot be accessed. TC323619 has been setaside and is therefore not available for this operation. Same issue isalso presented for the 2nd FCC application, FCC ID: YESTX91511B,TC640713. Additionally, due to the age of the applications, we are not able to access the incomplete applications to processGrant. The original applications under TC323619 and TC640713 weresubmitted under a now inactive TCB account, Curtis Straus TCB(US0106). In 2019, Bureau Veritas Consumer Products Services, Inc (US0160)and Curtis Straus TCB code (US0106) merged and The Curtis Straus TCB (US0106)account was deactivated and is inaccessible. Due to the issuepresented above, we will resubmit the applications entirely as new. Following the PAG procedure, a new PAG KDB will be submitted for each application with reference to this existing KDB tracking number 864718 indicating all non-

compliance items has been resolved. Regards, Angela H. TCB - BureauVeritas Consumer Products Services, Inc. Attachment Details:

With following attachments

- 154455 bytes, Inquiry Tracking Number 584840, on 12/04/2020

- 1292634 bytes, S2174-ES2174-3 FCC 18 Final Report, on 12/04/2020

- 3645905 bytes, TR-1867-NSA Bureau Veritas Chamber 1, on 12/04/2020

- 3639344 bytes, TR-1867-NSA Bureau Veritas Chamber 2, on 12/04/2020

- 1256159 bytes, S1365-ES1365-3 FCC 18 Final Report, on 12/04/2020 4

- 77835 bytes, TX91513 Operational Description, on 09/07/2021

- 59425 bytes, TX91511B Operational Description, on 09/07/2021 Do not reply to this email using the reply button. Please submit your reply to this correspondence at https://www.fcc.gov/labhelp. 5

620 Alpha Drive Pittsburgh, PA 15238 +1 412-455-5800 June 17, 2019 I, an officer of Powercast Corporation, do hereby authorize, until further notice, Bureau Veritas Consumer Products Services Inc., One Distribution Center Circle, #1, Littleton, MA 01460, to act on our behalf in dealings before the Federal Communications Commission with respect to all matters relating to equipment authorizations under 47 CFR. This authorization includes, but is not limited to, the signing of Form 731. I certify that no party (as defined in 47 CFR 1.2002) to this application, including myself, is subject to a denial of federal benefits, that include FCC benefits, pursuant to section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C., 853A. Certified By:

__________________________________ Charles Greene CTO Powercast Corporation 620 Alpha Drive Pittsburgh, PA 15238 412-455-5800