May 11, 2020

Ex Parte

Marlene H. Dortch, Secretary

Federal Communications Commission
445 12th Street SW
Washington, DC 20554

Re: Unlicensed Use of the 6 GHz Band, ET Docket No. 18-295; Expanding Flexible Use in
Mid-Band Spectrum between 3.7 and 24 GHz, GN Docket No. 17-183

Dear Ms. Dortch:

On May 8, 2020 and May 11, 2020, Paul Caritj of Harris, Wiltshire & Grannis and I
spoke with Ira Keltz of the Office of Engineering and Technology. We noted four errata in the
recently adopted 6 GHz Report & Order (“R&O”) that should be corrected prior to publication
(suggested additions in boldface and deletions in strikeout):

• 15.403: “Subordinate Device. For the purpose of this subpart, a device that operates in
the 5.925-7.125 GHz band under the control of an Indoor Access Point is supplied power
from a wired connection plugged into a wall outlet …”. The current language is
inconsistent with the decision in the R&O’s text and the definition of Indoor Access
Point.

• 15.407(d)(4): “Indoor access points and subordinate access devices, as well as client
devices designed to work exclusively with indoor access points, must bear the following
statement . . .” The R&O includes rules for “subordinate devices” but does not discuss
“subordinate access devices.” And the R&O permits client devices to work with outdoor
AFC access points in the 6 GHz band, access points in other bands, and indoor LPI
access points in the 6 GHz band. The indoor-only limit applies only to LPI client devices
designed to work exclusively with LPI access points, as other client devices will work
with outdoor access points.

• 15.407(l)(1)(ii): “Path-loss (L) = Σi P(i) * Li = PLOS * LNLOS + PNLOS * LNLOS”. Here, we

suggested that the “N” in “LNLOS” should be removed as this variable should be line-of-
sight rather than non-line-of-sight path loss. This change should also be made to footnote
156 to paragraph 65.

• Paragraph 235: The Commission proposed to permit VLP operations “across the entirety
of the 6 GHz range.” But, in a parenthetical, mistakenly lists the band as starting at
“5.950” GHz rather than 5.925 GHz. This mistake also appears in the Regulatory
Flexibility Analysis (Appendix C, Section A).

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 Pursuant to the FCC’s rules, I have filed a copy of this notice electronically in the above
referenced dockets. If you require any additional information, please contact the undersigned.

Sincerely,

Paul Margie
Counsel to Apple Inc., Cisco Systems, Inc.,
Facebook Inc., Google LLC, and Hewlett Packard
Enterprise