Business Machines CORN1TASUHOP User Manual OET Correspond 22603

International Business Machines Corporation OET Correspond 22603

Contents

EMC and RF Exposure Info

FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-01/9IBM Japan Ltd.1623-14, Shimotsuruma, Yamato-shiKanagawa-ken 242-8502, JapanApril 15, 2002To whom this may concernOET Requested InformationFCC ID : ANOCORN1TASUHOPApplicant : International Business Machines CorporationCorrespondence Reference Number : 22603731 Confirmation Number : EA935585Original Requested Date : April 13, 2002Subjects : EMC portionWith regard to your new request to implement method for replacing a broken WLAN card by theuser themselves.Subject 1) Please provide correspondence for the acceptance by FCC on February 2002 about your proposal.Answer 1) Please refer the Attechment-1 of this correspondence.Subject 2) Will this be only for broken WLAN cards and not for upgrade options?Answer 2) We plan to support only broken WLAN cards for the ANOCORN1TASUHOP.Subject 3) Will the (BIOS Lock) be used with other notebook computers?Subject 4) Will the WLAN card be used with other notebook computers?Answer 3/4) Yes, we plan to add other notebook computers with BIOS Lock mechanism, and will have the FCC authorizations for each PC model with different FCC IDs.Subject 5) If the WLAN card will be used with other computers, will a different output power be used? Will different antennas be used? How would you ensure that SAR compliance?Answer 5)- We have no plan to modify the applying WLAN card. i.e. The conducted output power must be the same. - Yes, different antennas will be used for other computers after being certified with different FCC IDs.- Usually the antennas of our products are located at the top of LCD panel, so they may be subjected to MPE. If we will have a different design (like a keyboard antenna), we will have the SAR testing in accordance with the latest FCC rule. note) We need to confirm the treatment for transmitters below 10mW whether it may be allowed MPE or not.Subject 6) Does the (BIOS Lock) check the proper antenna and card combination?Answer 6) The BIOS Lock checks the peculiar information of each authorized card, not checks any antenna info. Because the integrated antenna is (will be) unique for each PC model, so the BIOS does not need to detect the antenna type of its own host unit. Please refer the Attechment-2 adding more details of the BIOS Lock.
FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-02/9Subject 7) Does the (BIOS Lock) check the proper antenna and output power combination?Answer 7) The BIOS Lock dose not check output power, but checks the detail RF chipset info instead. IBM will not modify the power of authorized RF cards, so the function must be equal to the detection of the card manufacturing level. Also please refer the Attechment-2 adding more details of the BIOS Lock.Subject 8) The FCC identifier and label can only be placed on a complete transmitter. How is thisensured when the WLAN card is sold without the antenna? You'll be shipping/marketing incompletetransmitters.Subject 9) How does this proposal comply with 15.204 requirement that a complete system ismarketed together? This replacement does not have an antenna.Answer 8/9) As for the ANOCORN1TASUHOP, the RF WLAN card will be delivered to the customers for replacing broken cards only, not marketed for sales independently. To allow customers to install the repair parts, we implement the BIOS Lock to guarantee the Part 15.203. When we will market the card as the IBM option, we will process the proper certification of LMA (by the card supplier) in line with the new rule of Attachment-1.Subject 10) Please provide any additional information to ensure that the system will comply with EMC and SAR requirements when any changes to antenna or output power is made. Will Class II permissive changes be filed for all notebooks using this system?Answer 10) Usually we have the FCC IDs for each system unit, not for card. So we measure all test items for each model even though a same card was used for several models. If antenna will be changed, we re-measure the Part 15.205/207/209(EMC) and do class II change. ANOCH126H8056 is the case of it. We don't modify the card, so we have no case of power change. As for SAR, we have used MPE, so we could proceed with only the calculation using the conducted power and antenna gain. The Class II change is very rare for us, because we take a system grant approach (not LMA). Almost submissions are done as original filings with different new FCC IDs.Subject : RF Safety portionSubject: FYI - in future filings please do not submit MPE "estimation" analyses for distances less than 20 cm.Answer: Thank you but we still need a confirmation whether the rule will be applied to a low power transmitter below 10mW (e.g. Bluetooth 3mW).Subject: Concerning revised RF exposure statement in users manual: there are typographical errors, and we have the following comments for your consideration only:Answer: Thank you very much. We will fully follow your advice, and would like to attach the update for the sure. Please see the Attachment-3.Sincerely, April 15, 2002Toshiya MurotaStaff Engineer, EMC EngineeringYamato Laboratory, IBM Japan Ltd.
FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-03/9Attachment-1: Response from the FCC on February/2002"Rich Fabina" <RFABINA@fcc.gov>02/06/02 11:12 AMTo: George Kavelak/Raleigh/IBM@IBMUScc:Subject: Re: Awaiting Your ResponseGeorge,Yes, we find the proposal attached acceptable.Sorry for not getting back to you sooner but things just keep gettingbusier and busier.Rich>>> "George Kavelak" <kavelakg@us.ibm.com> 02/04/02 12:40PM >>>Rich, at our meeting Friday, January 25, 2002 you indicated that you wouldtry to get back with your answer by Friday February 1, 2002 on our proposalregarding a label on the bottom of the laptop near the Customer AccessPanel for the Mini-PCI transmitter card (limited modular approval with anFCC ID on the card). The label would indicate that an FCC ID for aninstalled transmitter card is viewable under the cover (i.e. "TXFCC ID forinstalled transmitter card viewable under this customer access cover").Have you reached a decision? Thanks.George KavelakIBM Corp.Corporate Program Manager of Electromagnetic CompatibilityEMC Program Standards Project AuthorityEMC PSPA Home Page -http://dteng.raleigh.ibm.com/~emccoc/kavelak/EMC-PSPA-Home.htmlkavelakg@us.ibm.comKAVELAKG at RALVM8YNYA/306 RTPtele: (919) 254-2311, t/l 444-2311fax: (919) 254-7778, t/l 444-7778ATTACHED FCC MINI-PCI CERTIFICATION MEETING TRIP REPORTMeeting Purpose:We met with the Federal Communications Commission (FCC), Office ofEngineering and Technology, Equipment Authorization Branch regarding FCCCertification requirements of Mini-PCI transmitter cards as separatelysold options for customer installation into wireless-ready ThinkPads.Meeting Attendees:Richard Fabina, FCC, Chief, Equipment Authorization BranchTim Harringon, FCC, Electronics Engineer, Equipment Authorization BranchGeorge Kavelak, IBM, Corporate Program Manager - EMCBarry Pate, IBM RTP EMC CoordinatorDaryl Cromer, IBM, Manager, Communications Option/BldgBlock Development
FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-04/9Meeting Date:January 25, 2002Meeting Location:FCC Laboratory7435 Oakland Mills RoadColumbia, MD 21046 At the onset of the meeting, the FCC restated that Limited ModularApproval radios sold separately were not allowed as described in thePublic Notice of June 26, 2000(http://www.fcc.gov/Bureaus/Engineering_Technology/Public_Notices/2000/da001407.doc). Their major points of concern were the requirement for a uniqueantenna connection and allowing a customer to install FCC ID labels.Limited Modular Approval would allow only an authorized dealer ormanufacturer to install the radio and add an external FCC ID label.Information in the following two files was presented to the FCC: (attachments removed)Meeting Results:The FCC will allow the Mini-PCI card to be certified under a LimitedModular Approval. The application should be for use in a ThinkPad family(chassis and antenna) such as ThinkPad X series. The application caninclude data for multiple ThinkPad families. Class II permissive changescan be made to the original Grant to include additional ThinkPadfamilies. (The IBM Grants that I have seen have notes indicating:"ThinkPad X23 Laptop Personal Computer", "Laptop PC IBM ThinkPad R30","Full size Notebook type PC integrating IEEE 802.11", "IBM ThinkPad T23","IBM Laptop PC, ThinkPad A22", "IBM ThinkPad", "Notebook Type PC IBMThinkPad Series", and no reference.) The Grantee for the Limited ModularApproval could be IBM or our OEM supplier. However, the OEM supplier asthe grantee must make the application for the Permissive Change and maybalk at performing Class II applications for IBM as we introduceadditional ThinkPad series.The FCC will accept unique operability of Mini-PCI cards to only IBMOptions in a ThinkPad via control of BIOS or other software mechanism inmeeting the intent of 15.203's requirement for a "unique coupling" betweenthe antenna and the transmitter.The FCC will allow the Mini-PCI card to be customer installed.The FCC accepts the FCC ID Number on the Limited Modular Approval Mini-PCItransmitter card. The Limited Modular Approval does not allowinstallation of a certification label by the customer on the exterior ofthe product under the current process. The FCC wants indication of thepresence of a radio on the exterior label of the product. The requirementhas been to include the FCC ID on an exterior label of the host product.Remaining FCC issue - In conjunction with having the FCC ID Number on theMini-PCI transmitter card, we suggested a label on the ThinkPad indicatingto the user that a transmitter FCC ID Number is under the customer accesspanel. The FCC seemed favorable towards this but wants to discuss furtherwithin the FCC with a target to respond by February 1, 2002. If the FCCdoes not accept our proposed approach for FCC ID Number labeling, we will
FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-05/9be relegated to having IBM or IBM authorized assemblers install thetransmitter option card and an FCC ID Number label to the ThinkPad.Co-located Unlicensed Radios - Industry is moving to utilize operation ofmultiple radios in the same host system. This has created situations werethe Grant for a specific host required the listing of all supported radioson the Grant. The basic problem is that the FCC requires the radio orradios to demonstrate compliance with FCC Part 2.1091, RF radiationexposure evaluation requirements, as part of the Grant of EquipmentAuthorization. This becomes complex with more and more radio combinationsavailable since the combination must also meet this requirement.Discussion with the Commission on this topic indicated a move to allow lowpower radio's (probably less than 1 milliwatt EIRP) to be exempted fromthis requirement.Other items:Changes to unintentional radiator portions of the ThinkPad such asprocessor and DASD upgrades are processed under the DoC process. Theywould not require a Class II permissive change for the intentionalradiator unless those changes affected the intentional radiatorperformance. (I believe this is "business as usual" conducted by Yamato.The only Class II changes I have seen have been for the addition of a newantenna or inclusion of additional Bluetooth co-transmitters.)The Grant issued by the European FCC Telecommunications Certification Body(TCB) to Agere for the DELL TrueMobile 1150 Series Mini-PCI option card isstill under FCC audit. The FCC will be discussing this Grant with theTCB. The FCC is quite aware that the justification used for "uniqueoperation" within a DELL unit is not valid.The DELL TrueMobile 1150 Mini-PCI option card and pubs we had with us wasborrowed by the FCC.The FCC has a conference call meeting with their TCBs the 2nd Tuesday ofevery month to address authorization issues and procedures.The FCC is working on a Notice of Proposed Rule Making to be issued thisyear that will address the requirements for RF exposure whenco-transmitters of very low power are used. It is expected that therewill be ranges of exemption for various combinations of transmitted powers.The FCC has periodic training sessions for TCBs. For a non-TCB to attend,they need to register with the American Council of IndependentLaboratories (ACIL). (02/13-15/2002, Training Session on SAR; ColumbiaMD; $750.00 for non-TCB; limited to 75 seats, TCB have priority; seehttp://www.acil.org/meetings/FEB2002workshop.pdf)Submitted by,Daryl CromerManager, Communications Option/BldgBlock Development8-441-0115Barry PateRTP EMC Coordinator
FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-06/98-441-6333George KavelakIBM Corp.Corporate Program Manager of Electromagnetic CompatibilityEMC Program Standards Project AuthorityEMC PSPA Home Page -http://dteng.raleigh.ibm.com/~emccoc/kavelak/EMC-PSPA-Home.htmlkavelakg@us.ibm.comKAVELAKG at RALVM8YNYA/306 RTPtele: (919) 254-2311, t/l 444-2311fax: (919) 254-7778, t/l 444-7778
FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-07/9Attachment-2: BIOS Lock FunctionAntenna Coupling Mechanismregarding the FCC Part 15.203 and RSS 210 §5.5 The following is the mechanism regarding the FCC Part 15.203 and RSS 210 Section 5.5 toprevent an unauthorized connection between the applying mini-PCI wireless card and the built_inantenna of the applying host unit (IBM ThinkPad T30 Series).1. If the BIOS of ThinkPad T30 Series finds that the base class code of the applying mini-PCI cardis “02h”, the BIOS regards it as a network mini-PCI card.2. If the BIOS detects a network mini-PCI code (i.e. =“02h”), the BIOS checks the vender ID,device ID, subvendor ID and subsystem ID of it. vender ID : Chipset manufacturer ID device ID : Chipset device ID subvendor ID : WLAN assemble manufacturer ID subsystem ID : Dealer ID à IBM unique code will be assigned by the card supplier.3. If one or more of these IDs was(were) different from supported IBM options which wereauthorized by the FCC and Industry Canada to use for ThinkPad T30 Series, the BIOS willstop the boot and show a POST error with beeps.The following step 4 is backup logic if a wireless card will not be specified with the above IDs.4. The BIOS also checks PCI VPD(Vital Product Data) contents. If a product name of mini-PCIcard written in VPD, which is provided from Flash ROM of the applying mini-PCI wireless card,was different from supported IBM options, which were authorized by the FCC and IndustryCanada to use for ThinkPad T30 Series, the BIOS will stop the boot and show a POST errorwith beeps.
FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-08/9Attachment-3: Revision of the user’s ManualPage 47 :Appendix C. Wireless regulatory noticeThe ThinkPad T30 Series computer must be installed and used in strictaccordance with the instructions as described hereafter. This product complieswith the following radio frequency and safety standards.USA - Federal Communications Commissions (FCC)This device complies with part 15 of the FCC Rules. Operation is subject tothe following two conditions:1. This device may not cause harmful interference, and2. this device must accept any interference received, including interference that may cause undesired operation.The FCC RF Safety RequirementThe radiated output power of Wireless LAN Mini-PCI Adapter is far belowthe FCC radio frequency exposure limits. Nevertheless, the ThinkPad T30shall be used in such a manner that the potential for human contact duringnormal operation is minimized as follows:Multiple Transmitter modelIf you find the FCC ID “ANOCORN1TASUHOP” on the label at the bottom sideof your ThinkPad computer, your computer is approved as a MultipleTransmitters device that is permitted to use the integrated Wireless LANMini-PCI card and Bluetooth card with two or more wireless option PC Cardsin the PC slot simultaneously.The integrated wireless features (Wireless LAN Mini-PCI card and Bluetoothcard) are preinstalled by IBM.l You are not permitted to install nor replace the integrated Bluetooth card byyourself. If you will have any problem on the integrated Bluetooth card, pleasecontact the IBM HelpCenter(s) shown in “Chapter 3. Getting help and servicefrom IBM” of the ThinkPad T30 Series Service and Troubleshooting Guide.l If your integrated Wireless LAN Mini-PCI Card requires replacement via theproper step shown in “Chapter 3. Getting help and service from IBM”, IBM willrequest you to send your computer with the Card to IBM so that IBM will repairit, or IBM will provide the repair parts that you can install. If you will install anunauthorized module, your ThinkPad computer does not start but only displaysan error message and emits beeps.
FCC ID: ANOCORN1TASUHOP Document Number: FCC-19-0182-09/9CAUTION:To comply with FCC RF exposure compliance requirements, a separation distanceof at least 20 cm (8 inches) must be maintained between the antenna for theintegrated Wireless LAN Mini-PCI card built in to the screen section and allpersons.The Bluetooth antenna is located in the left edge portion of keyboard.Transmitted energy from the Bluetooth device is very low compared to other RFdevices. Therefore a 20 cm separation from the Bluetooth antenna is not required.Use of Wireless optionsPlease make sure of the following when you use a Bluetooth option orwireless option PC Card in your ThinkPad computer.1. Visit the IBM® site at www.ibm.com/pc/qtechinfo/MIGR-39377.html and confirm the updated list of RF option devices that have been approved to cooperate with the integrated wireless feature.2. When you use any other RF option device that is not listed on the IBM site, all other wireless features including the integrated transmitter in your ThinkPad computer are required to be turned off.3. Users are requested to follow the RF Safety instructions on wireless option devices that are included in the RF option device’s user’s manual.Interference StatementAn improper installation or unauthorized use may cause harmful interferenceto radio communications. Also any tampering of the internal antenna willvoid the FCC certification and your warranty. Refer to the “Electronicemission notices” on page 68 for more detail.

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