• Ari Fitzgerald, on behalf of GE Healthcare commented on 2015-11-20 20:36:05.503:
  As explained in the attached document, GE Healthcare proposes the following changes to the Draft Report’s guidance on unwanted radiation measurement: (1) change the resolution bandwidth ("RBW") setting to 100 kHz to help detect spurious energy and free additional spectrum for Medical Body Area Network ("MBAN") use; (2) account for RBW filter roll-off in the test equipment specifications to help ensure consistent measurements; and (3) use 2359.5 MHz and 2400.5 MHz as the center frequencies to help avoid measuring in-band MBAN signals. GE Healthcare also notes that we are coordinating with other stakeholders and anticipate addressing in a subsequent filing what the phrase "automatically cease" should mean in the context of Section 95.628 of the FCC's rules. View attachment associated with this comment

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• DS LAW PLLC David Siddall commented on 2015-11-20 19:57:37.296:
  Philips Healthcare (Philips) submits the attached comments on the above-referenced FCC Laboratory Division’s Draft Measurement Procedures for MBAN Devices released on October 15, 2015. View attachment associated with this comment

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• DS LAW PLLC David Siddall commented on 2015-11-20 17:45:45.87:
  Joint Filing by the Aerospace and Flight Test Radio Coordinating Council (AFTRCC), GE Healthcare, and Philips Healthcare MBAN devices may not operate outside the confines of a health care facility in the 2360-2390 MHz band under Section 95.1203 of the FCC’s Rules. AFTRCC, GE Healthcare, and Philips Healthcare wish to inform the Commission staff that jointly they have under discussion the appropriate maximum time period within which to “automatically cease” all transmissions as used in Section 95.628(c) of the FCC’s Rules when an MBAN device moves outside a health care facility. The joint parties intend to file a proposal with the Commission by January 22, 2016, for the Commission staff’s consideration for application in the equipment authorization process. Ken Keane, Esq. Duane Morris?LLP Counsel to AFTRCC KKeane@duanemorris.com Ari Q. Fitzgerald, Esq. Hogan Lovells US LLP Counsel to GE Healthcare ari.fitzgerald@hoganlovells.com David Siddall, Esq. DS LAW PLLC Counsel to Philips Healthcare david@davidsiddall-law.com

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• Ari Fitzgerald, on behalf of GE Healthcare commented on 2016-02-05 20:26:16.826:
  GE Healthcare, Philips Healthcare, and the Aerospace and Flight Test Radio Coordinating Council, Inc. (collectively, the “Joint Parties”) hereby submit these comments in response to the October 15, 2015 Draft Publications Report (“Draft Publications Report”) released by the Commission’s Office of Engineering and Technology Laboratory Division. The Draft Publications Report proposes guidance on the procedures to be used in demonstrating compliance with the Medical Body Area Network (“MBAN”) requirements contained in Part 95 of the Commission’s rules. As explained in the attached document, the Joint Parties propose a number of measures to ensure that MBAN devices operate as expected. View attachment associated with this comment

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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.