• Steve Liu commented on 2012-06-30 17:48:29.196:
  Thank you for updating the KDBs on this publication. Please see attached our comments that we believe would help clarify the procedures indicated. View attachment associated with this comment

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• Brian Scarpelli commented on 2012-06-29 16:33:24.226:
  The Telecommunications Industry Association (“TIA”) hereby submits input to the Federal Communications Commission’s (“FCC”) Office of Engineering and Technology (“OET”) on draft Laboratory Division Knowledge Database (“KDB”) publication 616217 (“KDB 616217”). Specifically, TIA submits the following input for OET’s consideration: • Additional clarification is required on antenna testing/selection (specific absorption rate [“SAR”]) for modules designed for integration into laptops. The language in section III (e.g. page 3) does not clearly define the antenna parameters of interest to the FCC. The section discusses requirements for the retesting of antennas based on conductive/non-conductive surrounding materials but does not define allowable deviations in the antenna parameters. These restrictions on antenna selection drive the number of Class II permissive change requirements. For example, is a PIFA antenna limited to physical dimensions, efficiency characteristics, return loss, etc.? In the absence of definition, it is unclear if the FCC is allowing the manufacturer to determine what characteristic are of importance (e.g. increasing or limiting Class II changes at engineering discretion) or if the FCC would like feedback from industry on what, if any, antenna characteristics should be restricted with respect to “modular” or host SAR. Given the potential impact of the proposed KDBs on test time, lab capacity, and even product design, we request that OET determine and announce a reasonable transition period for implementation of the KDBs once finalized. TIA members recommend that a transition period of at least ninety days in order to mitigate the impact that such extensive changes to testing protocols will have. TIA has previously requested an extension of the due date for comments on draft KDBs as critical to industry’s ability to provide thoughtful comments. In order to facilitate review of industry’s concerns, TIA may submit comments to selected KDBs, subject to supplementation, after June 30, 2012. We therefore respectfully submit this comment to draft KDB 616217, and urge the Commission to act consistent with the above. View attachment associated with this comment

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• Kai Niskala commented on 2012-06-25 06:23:49.956:
  616217 D04 SAR for Laptop and Tablets v01 III. Host platforms A. Laptop host platform test requirements This section seems to define test requirements only when modular approach is applied. It should be clarified what are the laptop test requirements when dedicated host approach is applied.

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• Mark Briggs commented on 2012-06-14 14:04:55.576:
  Please refer to attached document for comments. View attachment associated with this comment

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• Thanh Nguyen commented on 2012-06-13 17:20:25.82:
  In section V.C. Modular transmitter manufacturer and host manufacturer responsibilities, the draft KDB stating: The preferred equipment approval approach is to have all transmitters authorized under a single FCC ID for the host tablet… There are up to 3 different modular transmitters can be installed in the tablet, and there are multiple suppliers for each of modular transmitter. Therefore, it is impractical for the host tablet manufacturer to apply for a single FCC ID for the host tablet to cover all possible combination of transmitters installed (different configurations). So, it makes sense that the preferred approval approach is a change of ID of the modular transmitter and the alternative approval approach is single FCC ID for the host tablet.

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• alexander ho commented on 2012-05-10 11:39:50.143:
  In page 4, host manufacturer should check SAR of USB dongles. While the host is pure difital device, there is no requirement of certification; how do they address the SAR compliance? If the radio module integration is through C2PC, the applicant of the certification is module company; is the responsibility belonged to the module company to check USB dongle simultaneous SAR compliance? The USB dongle is to be tested at separation of 5mm, while the laptop/tablet is getting very thin; if volume scan is necessary to address compliance, and the USB dongle cannot maintain 5mm when plugged in (ex: USB dongle would touch the phantom), and SAR failed. Is the host manufacturer's responsibility to make the device thin?

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• Alexander Ho commented on 2012-05-08 06:37:04.033:
  In KDB616217 D03, and the draft KDB 616217 D04, if module SAR is < 0.4W/kg, the module can be integrated into any host platform if module SAR is tested more conservative antenna-user distance than that in host platform. There is no clear definition or limitation of the "antenna", for part 15 devices and licensed devices, regarding the antenna type and the antenna gain. Is it required the antenna for integration into host must be the same as that in module SAR testing? In practical cases, esspecially for licensed devices, the antenna integrated into host will be fine-tuned for best OTA performance in different host. If the rule does require some limitation, is it possible to have a footnote to indicate?

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Note: It is important to understand that the staff guidance provided in the KDB is intended to assist the public in following Commission requirements and does not constitute rules. Accordingly, the guidance is not binding on the Commission and will not prevent the Commission from making a different decision in any matter that comes to its attention for resolution.