1. doc.: IEEE 802.11-01/249 Submission May 2001 Zyren, Webster, Halford Intersil FCC Further Notice ET Docket 99-231 Zyren, Webster, Halford Intersil

2. doc.: IEEE 802.11-01/249 Submission May 2001 Zyren, Webster, Halford Intersil Summary of Further Notice Proposed Rules: –Allow new digital transmission technologies –Eliminate DSSS processing gain requirement –Facilitate adaptive hopping for FHSS systems Interim Waiver for Wi-LAN –Must meet requirements of 15.247 a, b, c, and d. –Interim power limit of 100 mW –Conditionally authorized devices must comply with rules that are ultimately adopted.

3. doc.: IEEE 802.11-01/249 Submission May 2001 Zyren, Webster, Halford Intersil Digitally Modulated Systems Elimination of Processing Gain Requirement –Current rules are unnecessarily restrictive (para. 8) –Rules should be modifies to permit new digitally modulated technologies (para. 15) New digitally modulated systems must meet modified (proposed) spread spectrum rules. –FCC suggests same power limit and PSD as existing DSSS devices 1 W tx power, 8 dBm/3 Khz PSD (para. 17) –Considering extending UNII band to include 2.45 GHz ISM band (para 18) –Processing Gain requirement eliminated (para. 22)

4. doc.: IEEE 802.11-01/249 Submission May 2001 Zyren, Webster, Halford Intersil Compliance with Proposed Rules Does OFDM Comply with Proposed Rules? –YES Does PBCC Comply with Proposed Rules? –YES

5. doc.: IEEE 802.11-01/249 Submission May 2001 Zyren, Webster, Halford Intersil Interim Waivers FCC will Grant Immediate Interim Waivers (para. 2) –Waivers granted for “Wi-LAN’s equipment and similar devices”. Proposed rules will accommodate devices such as Wi-LAN’s Waiver requirements (para. 26) –100 mW interim power limit –Must comply with rules ultimately adopted –Must also meet requirements of FCC 15.247 a, b, c, d –Processing gain compliance not required FCC 15.247 (e) is waived –Digitally modulated systems are permitted

6. doc.: IEEE 802.11-01/249 Submission May 2001 Zyren, Webster, Halford Intersil Waiver Requirements FCC 15.247 a: –-6dB bandwidth >500 kHz FCC 15.247 b: –Interim Power Limit of 100 mW –Transmit antenna restrictions FCC 15.247 c: –Out-of-band limits (-20 dBc and restricted band limits) FCC 15.247 d: –PSD Limit >8 dBm / 3 kHz

7. doc.: IEEE 802.11-01/249 Submission May 2001 Zyren, Webster, Halford Intersil Conclusions Do OFDM & PBCC comply with proposed rules? –Yes Do OFDM & PBCC qualify for waivers? –Yes OFDM and PBCC are on an equal footing in terms of regulatory compliance