FCC ID: 2AGZ3S01711 Comet37 2.0 Radio

FCC Label Artwork and Location Comet37 2.0 (S01711) Version 1.2.0 Nov 21, 2023 Ryan Lagoy Hardware and Systems Brian Wanek Mechanical Engineering, Hardware and Systems Engineering 2023 Starry, Inc. All rights reserved. Starry Proprietary and Condential Table of Contents Table of Contents Label Artwork SRD-12-00100, Coax Label Label Location 1 2 2 3 2023 Starry, Inc. All rights reserved. Starry Proprietary and Condential Label Artwork The label stock and printing are UV / weather resistant materials, 70 x 25mm. The minimum label font size is Type 4. Prior to UL Listing, the label will contain no UL LISTED logo. SRD-12-00100, Coax Label 2023 Starry, Inc. All rights reserved. Starry Proprietary and Condential Label Location The product weather-protected and visible during installation. is placed on the bottom of label the system so it is 2023 Starry, Inc. All rights reserved. Starry Proprietary and Condential

Date: September 6, 2023 UL LLC 12 Laboratory Dr. Research Triangle Park, NC 27709 USA To whom it may concern:

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

a) fulfill the requirements for the scope of certification requested, including implementing any appropriate changes requested by UL Verification Services Telecommunications Certification Body (TCB) and / or the FCC;

b) supply any and all information needed for the evaluation of the products for which certification is sought;

c) make claims regarding certification only in respect of the scope for which certification has been granted;

d) not use our product certification in such a manner as to bring the TCB or FCC into disrepute and to not make any statement regarding product certification which the TCB or FCC may consider misleading or unauthorized;

e) discontinue use of all advertising matter that contains any reference thereto and complies with any and all actions required by the FCC upon suspension or cancellation of certification;

f) use certification only to indicate that products are certified in conformity with specified standards;

g) endeavor to ensure that no certificate or report or any part thereof is used in a misleading manner, and any copies of the grants/certificates shall be reproduced in their entirety;

v1.0.1 i) h) comply with the requirements of the TCB and FCC, including the use of marks and label information prescribed for the scope of certification, when making reference to product certification in communication media such as documents, brochure or advertisements;

comply with the requirements for certification, supply any information needed for evaluation of products to be certified and, where applicable, make provision for the participation of observers;

ensure that products marketed under the scope of the requested certification continue to comply with the certification requirements;

j) k) provide a sample of a production unit for testing within 30 days of the request should this product be selected as part of either the TCBs or the FCCs market surveillance requirements;

l) keep a record of all complaints relating to products compliance with requirements of relevant standard; make records available to UL or FCC when requested; take appropriate action with respect to such complaints and any deficiencies found in the product that affect compliance with requirements for certification; document the actions taken with respect to complaints and/or deficiencies;

m) inform the TCB immediately of any changes that may affect its ability to comply with the certification requirements. This authorization is valid until September 6, 2025, unless sooner terminated or extended by written notice to UL LLC and the Federal Communications Commission. Sincerely Yours, Ryan Lagoy Director, Hardware and Systems Engineering Starry, Inc. 38 Chauncy Street, Suite 200 Boston, MA 02111 v1.0.1

Date: September 11, 2023 Attn: FCC Office of Engineering and Technology / UL Verification Services TCB Subject:

Request for Confidentiality FCC ID:

2AGZ3S01711 To Whom It May Concern:

Pursuant to the provisions of Sections 0.457 and 0.459 of the Commissions rules (47 CFR 0.457, 0.459), we are requesting the Commission to withhold the following attachments as confidential document from public disclosure indefinitely. Schematics Detailed Block Diagrams Detailed Operational/Functional Description Calibration Documentation Parts list/BOM Internal photos User Manual Above mentioned document contains detailed system and equipment description are considered as proprietary information in operation of the equipment. The public disclosure of above documents might be harmful to our company and would give competitor an unfair advantage in the market. In additional to above mentioned documents, pursuant to Public Notice DA 04-1705 of the Commissions policy, in order to comply with the marketing regulations in 47 CFR 2.803 and the importation rules in 47 CFR 2.1204, while ensuring that business sensitive information remains confidential until the actual marketing of newly authorized devices. We are requesting the commission to grant short-term confidentiality request on the following attachments for a period of 45 days from the date of Authorization:

External Photos Test Setup Photos It is our understanding that all measurement test reports, FCC ID label format and correspondent during certification review process cannot be granted as confidential documents and those information will be available for public review once the grant of equipment authorization is issued. v1.1.0 Rationale for request for confidentiality:

The exhibits for which Starry requests long-term confidential treatment all contain confidential, proprietary technical information that the Commission protects from disclosure as a type of record that is not routinely available for public inspection.1 Disclosure of the exhibits for which Starry seeks short-term confidential importation and/or distribution would reveal key aspects of proprietary technology to competitors and significantly diminish the value of our investment in research and development. treatment during the period of Starry has invested considerable time and materials in research and development to produce the referenced product. To protect its investment, Starry does not release this information in the ordinary course of its business because doing so would result in substantial competitive harm to Starry. Disclosure of these confidential exhibits to competitors would not only give them significant competitive advantages in developing similar products, but would also disclose successful implementation of unpublished, leading edge technology developed by Starry and could even reveal information about Starrys unique economic model. Among the exhibits for which Starry seeks long-term confidential treatment are internal photos. It is appropriate to accord such treatment to the internal photos submitted for two reasons. First, some of these photos are scanning receiving internal photos, which, by rule, the Commission inspection.2 Second, long-term confidential treatment for all other does not make available for internal photos is also warranted because the referenced product is a non-consumer device that is not sold to end users, nor is it accessible to the general public. These devices are mounted on the top of buildings, such as a rooftop, and are only serviceable by professional, designated Starry technicians and partners under a Non-Disclosure Agreement (NDA). An example of the NDA between Starry and its technicians and partners is provided herein. Starry also seeks long-term confidential treatment for the user manual of the referenced product. The manual for this product contains confidential proprietary technical information and is only shared outside the company with professional, designated Starry technicians and partners under an NDA. The manual is not provided to end users because this is a non-consumer device that is not available for sale and end users of the device do not have access to it and cannot service it. Therefore, long-term confidential treatment of the user manual is also warranted. Best Regards, Ryan Lagoy Director, Hardware and Systems Engineering Starry, Inc. 38 Chauncy Street, Suite 200 Boston, MA 02111 1 47 C.F.R. 0.457(d) 2 See 47 C.F.R. 0.457(d)(1)(ii) (Portions of applications for equipment certification of scanning receivers and related materials will not be made available for inspection.).

Date: September 6, 2023 Federal Communications Commissions Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 RE: CFR 47 2.911 (d)(5) Attestation FCC ID: 2AGZ3S01711 1. Starry, Inc. (the applicant) certifies that the equipment for which authorization is sought is not covered equipment prohibited from receiving an equipment authorization pursuant to section 2.903 of the FCC rules. 2. Starry, Inc. (the applicant) certifies that, as of the date of the filing of the application, the applicant is not identified on the Covered List as an entity producing covered equipment and is not an affiliate or subsidiary of an entity identified on the Covered List. Sincerely yours, Name:

Job Title:

Ryan Lagoy Director, Hardware and Systems Engineering Company Name: Starry, Inc. v1.0.1

Date: September 6, 2023 Federal Communications Commissions Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 RE: CFR 47 2.911 (d)(7) Agent Designation Attestation FCC ID: 2AGZ3S01711 Applicant (Grantee) FRN: 0025148065 To whom it may concern:

Starry, Inc. (the applicant) as required by section 2.911(d)(7), will also serve as the agent for service of process for the above referenced FCC ID. The applicant acknowledges that they will maintain an agent for no less than one year after the grantee has terminated all marketing and importation or the conclusion of any Commission-related proceeding involving the equipment. The applicant further acknowledges their responsibility under CFR 47 2.929(c) to inform the FCC whenever the agent information changes. U.S. Agent Information:

Ryan Lagoy Starry, Inc. FCC FRN: 0025148065 38 Chauncy Street, Suite 200 Boston, MA 02111 rlagoy@starry.com Sincerely yours, Ryan Lagoy Starry, Inc. 38 Chauncy Street, Suite 200 Boston, MA 02111 v1.0.1

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Attn:

2023-09-11 FCC Office of Engineering and Technology FCC ID:

Applicant:

2AGZ3S01711 Starry Inc. Ref:

47 CFR Part 30 Far-Field Measurements Background The mmWave radio incorporated within the EUT submitted as part of this certification operates between 37-40 GHz and is available with 3 different antenna variants as described below:

- Base radio with integral 8 x 8 patch antenna array. Maximum antenna dimension is 58mm.

- Base radio with integral 8 x 8 patch antenna array plus small reflector plate. Maximum reflector plate dimension is 320mm.

- Base radio with integral 8 x 8 patch antenna array plus large reflector plate. Maximum reflector plate dimension is 515mm. Per KDB 842590 v1r02, fundamental and out-of-band emissions shall be made in the far field, based on the largest far-field boundary distance of the EUT antenna and the measurement antenna, where the far-field boundary for mmWave antennas is equal to 2D2/. As such, the required far-field boundary distance for each variant is:

- Base radio: 0.90m

- Base radio with 320mm reflector: 27.3m

- Base radio with 515mm reflector: 70.7m The integral antenna of the base radio has a nominal gain of 23 dBi; the 320 mm reflector adds an additional 10.5 dB to this gain, and the 515 mm reflector adds an additional 15.5 dB of gain. Testing Strategy EIRP and Bandedge measurements were first performed on the base radio in the far-field within a fully anechoic chamber. These measurements were then repeated using the worst-case reflector plate (515mm) in the far-field at an outdoor site. The substitution measurement method per C63.26 Clause 5.5.3 was used for the outdoor measurements. In lieu of the theoretical calculated free space propagation path loss (see C63.26 Equation C.9), substitution measurements were performed to determine the actual free space path loss of the test site at the measurement distance. This value was used as the correction factor for in-band measurements. Derivation of the Measured Path Loss:

EIRP = PT + GT LC C63.26 Equation (C.3) Where, PT = transmitter output power GT = gain of transmitting antenna LC = signal loss in connecting cable between transmitter and antenna EIRP = PR + LP Where, PR = adjusted received power level LP = basic free-space propagation path loss C63.26 Equation (C.7) PR Pmeas GR + LC + Latten Gamp C63.26 Equation (C.8) Where, Pmeas = measured power level GR = gain of receive antenna LC = signal loss in measurement cable Latten = value of external attenuation (if used)*

Gamp = value of external amplification (if used)*

*-External attenuation or amplification not used for these measurements Combining Equations. C.3, C.7 and C.8 yields:

Pt + Gtx Lctx = Pmeas Grx + Lcrx + Latten Gamp + Lp Re-arranging to express path loss as a function of the other parameters:

Lp = Pt + Gtx Lctx - Pmeas + Grx - Lcrx - Latten + Gamp Calculation for 37 GHz:

LP = 15 + 22.65 5.22 (-48.75) + 23.31 5.26 0 + 0 LPMeasured = 99.23 dB Free Space Path Loss (Theoretical):

LP = 20logF + 20logd 27.5 Where, LP = basic free space propagation path loss, in dB F = center frequency of radiated EUT signal, in MHz d = measurement distance, in m Calculation for 37 GHz:

LP = 20log(37000) + 20log(71) 27.5 LP = 91.36 + 37.03 27.5 LPTheoretical = 100.89 dB Summary of substitution measurements Channel Freq

(GHz) Meas Distance

(m) PT

(dBm) LC

(Tx)

(dB) GT

(Tx)

(dBi) GT

(Rx)

(dBi) LC

(Rx)

(dB) Measured Power, Pmeas

(dBm) Measured Path Loss, LP (dB) Theoretical Path Loss, LP (dB) Path Loss Delta

(dB) Low BE 37.00 71.00 15.00 5.26 22.65 23.31 5.22

-48.75 99.23 100.89

-1.66 Low Channel Mid Channel High Channel 37.10 71.00 15.00 5.26 22.69 23.35 5.26

-49.12 99.64 100.91

-1.27 38.50 71.00 15.00 5.48 22.57 23.19 5.47

-52.60 102.41 101.23 1.18 39.90 71.00 15.00 5.52 22.45 23.36 5.54

-46.91 96.66 101.54

-4.88 High BE 40.00 71.00 15.00 5.69 22.34 23.39 5.59

-46.61 96.05 101.57

-5.51 Validation and Sanity Checks Knowing the values of the base radio along with the expected added gain of the reflector plate, we can predict the EIRP when testing at the outdoor site. Channel Freq (GHz) Base Radio Measured EIRP At 3m (dBm) Low, 160 MHz BW 37.1 51.97 Expected Additional Gain From Reflector

(dB) 15.5 Predicted EIRP With Reflector 67.47 Measured EIRP With Reflector at 71m (dBm) 65.43 Measured vs Predicted EIRP Delta

(dB)

-2.04 Additionally, a spot test of the base unit at 71 meters was made to validate the gain of the reflector. Channel Freq (GHz) Base Radio Measured EIRP At 71m (dBm) Low, 160 MHz BW 37.1 49.93 Expected Addional Gain From Reector

(dB) 15.5 Predicted EIRP With Reector 65.43 Measured EIRP With Reector at 71m (dBm) 65.43 Measured vs Predicted EIRP Delta

(dB) 0.0