March 28, 2017

BY EMAIL

Dr. Rashmi Doshi

Office of Engineering and Technology
Federal Communications Commission
445 12th Street SW
Washington, DC 20554

Re: Energous response to OET’s inquiries regarding Energous’ wireless power transfer
desktop system technology

Dear Rashmi:

Attached please find a confidential version of a response (“Response”) by Energous

Corporation (“Energous”) to certain inquiries from the Federal Communications Commission’s
(“FCC” or “Commission”) Office of Engineering and Technology (“OET”). The inquiries arose
during recent conversations in which the Commission pointed out that they have seen several
transmitter designs from Energous over the last few months and would like to have a clear
understanding of the specific device (“Desktop Transmitter”) that Energous will be submitting for
certification. Energous would be glad to further discuss with OET at its request the information
set forth in this Response.

Energous understands that this Response will not be made available by the OET to the
general public in the normal course and that it will not be published as part of the Commission’s
non-docketed mail. Energous nevertheless is submitting its Response under a formal request
for confidentiality in case the Commission receives at some point in the future a Freedom of
Information Act, 5 U.S.C. §552(b)(4) (“FOIA”), request to which this Response may be subject.
Energous is not submitting a redacted, public inspection version of the Response because all
portions of the Response warrant confidential treatment.

Specifically, Energous hereby requests confidential treatment, pursuant to Sections

0.457(d)(2) and 0.459 of the Commission’s Rules, 47 C.F.R. §§ 0.457(d)(2) and 0.459, for the
attached Response in its entirety because the Response involves confidential and proprietary
technical information regarding devices and technology that Energous is developing for
commercial sales. Energous has labeled the Response as “CONFIDENTIAL – NOT FOR
PUBLIC INSPECTION.” Energous is requesting that the Response be withheld from public
inspection under Exemption 4 to FOIA and Section 0.457(d)(2) of the Commission’s Rules. The
information set forth in the Response is proprietary, and Energous does not in the normal
course of business disclose this information to the public or its competitors.

In support of this request, Energous provides the following information, as required by

Sections 0.457(d)(2) and 0.459(b) of the Commission’s Rules.

1. Information for Which Confidentiality is Requested. Energous is requesting

confidential treatment for the Response.

2. Circumstances Giving Rise to Submission of Materials. Energous is

submitting the Response in response to certain inquiries proffered by OET
 during Energous’ October 26 meeting with OET as well as later meetings
and conversations. The inquiries relate to wireless equipment being
developed by Energous.

3. Nature of Confidential Information. The Response contains trade secrets

and commercially sensitive technical information that is proprietary and
confidential and that Energous customarily guards from its competitors.
Such proprietary and confidential information may be withheld from public
disclosure under FOIA Exemption 4. The Commission consistently has
recognized that for purposes of Exemption 4 “records are ‘commercial’ as
long as the submitter has a commercial interest in them.” Robert J. Butler,
6 FCC Rcd 5414, 5415 (1991), citing Public Citizen Health Research Group
v. F.D.A., 704 F.2d 1280, 1290 (D.C. Cir. 1983); American Airlines v.
National Mediation Board, 588 F.2d 863, 868 (2d Cir. 1978).

4. Degree to Which Information Concerns a Service That is Subject to

Competition. The information included in the Response derives from, and
relates to, Energous’ development of innovative new wireless equipment
technology, and the wireless device manufacturing sector is highly
competitive. In addition, Energous’ technology may be adopted for use by
the highly competitive wireless telecommunications industry in connection
with the provision of end-user mobile wireless services. Consequently, the
Response concerns market sectors and services that are “subject to
competition.” 47 C.F.R. § 0.459(b)(4).

5. Substantial Competitive Harm That Would Result from Disclosure of

Information. The information included in the Response is proprietary and
confidential, and its release would likely cause competitive harm to
Energous. The wireless equipment manufacturing sector is highly
competitive. Consequently, equipment developers and manufacturers
always are interested in learning what other equipment developers are
doing to advance the state of the art within the wireless equipment industry.
Providing Energous’ competitors with access to the Response, which
contains sensitive trade secrets and commercially sensitive technical
information, would therefore competitively harm Energous. The D.C. Circuit
has found that parties do not have to “‘show actual competitive harm’” to
justify confidential treatment. Rather, “[a]ctual competition and the
likelihood of substantial competitive injury is sufficient to bring commercial
information within the realm of confidentiality.” Public Citizen Health
Research Group, 704 F.2d at 1291, quoting Gulf & Western Industries v.
U.S., 615 F.2d 527, 530 (D.C. Cir. 1979).

6. Measures Taken to Prevent Unauthorized Disclosure. Energous treats the

information included in the Response as confidential and proprietary and
does not publicly disclose this information.

7. Previous Disclosure. The information set forth in the Response previously

has not been disclosed by Energous to the public.

8. Requested Duration of Nondisclosure. The information included in the

Response should never be released for public inspection because it

2
 contains commercially sensitive, proprietary, and confidential technical
information, the release of which would adversely affect Energous’
competitive position.

For the foregoing reasons, Energous respectfully requests that the Commission withhold
the Response from public inspection.

Please let us know if you have any further questions about this matter.

Sincerely,

Billy Manning
Director of Regulatory Operations
Energous Corporation

Attachment

3
 Confidential – Not for Public Inspection

Energous Response to OET’s Inquiries

Regarding Energous’ Wireless Power Transfer Desktop System Technology

March 28, 2017

Introduction

Energous Corporation (“Energous”) is submitting this document (“Response”) to the Federal

Communications Commission (“FCC”) Office of Engineering and Technology (“OET”) in
response to certain inquires by OET. Specifically, the Commission pointed out that they (b)
would like(4)
to have
a clear understanding of the specific device (“Desktop Transmitter” or “transmitter”) that
Energous will be submitting for certification. This Response provides a detailed description of
the technology incorporated into Energous’ Desktop Transmitter and receiver, as well as the
configuration of the devices. It is intended to provide background and technical information
requested by OET for purposes of OET’s consideration of the equipment authorization process
that will be used to certify the Desktop Transmitter. The Response contains the following
sections:

1. Overview of the Energous Desktop Transmitter and receiver that will be submitted for
certification.
2. Description and design of the transmitter-receiver authentication process.
3. Description of the transmitter sensor system and explanation of mechanisms causing it to be
reliable and robust.
4. Overview of methods used to demonstrate compliance.
5. Method for demonstrating exposure mitigation and compliance.

1. Overview of the Energous Desktop Transmitter and receivers that will be submitted
for certification.

The transmitter in Figure 1 has 12 antennas (b) (4)

Table
1 below is a description of the system.

Energous Response -- 4
 Confidential – Not for Public Inspection

Figure 1: Desktop Transmitter

(b) (4)

Table 1 below summarizes certain technical characteristics of the Desktop Transmitter(b) (4)

Use Case Small TX below monitor charging single

device
Target Platforms Angled Sound Bar for desktop usage
Wireless Power Transfer Frequency (b) (4)
Max Tx- Rx Distance (b) (4)
Transmitter Size (b) (4)
Number of Antennas 12
Conducted Output Power per Antenna (b) (4)
Receiver Size (b) (4)
Cumulative Receive Power at 30cm and 1m (b) (4)
Simultaneous Rx No – 1 Rx at a time
Number of Receivers Supported 1
BLE for Tx/Rx Yes
Sensor required for SAR Compliance Yes

Table 1: Technical Characteristics of the Desktop Transmitter

Energous Response -- 5
 Confidential – Not for Public Inspection

Table 2 below details the transmitting and received operational power levels(b) (4)

(b) (4)

Table 2: (b) (4)

As shown in Figure 2 below, the transmitter is composed of (b) (4)

(b) (4)

Figure 2: (b) (4)

Energous Response -- 6
 Confidential – Not for Public Inspection

(b) (4)

2. Description and design of the transmitter-receiver authentication process.

(b) (4)

Energous Response -- 7
 Confidential – Not for Public Inspection

Figure 3 below describes the operating area.

(b) (4)

Figure 3: Desktop Transmitter Operating Area

A detailed block diagram of the transmitter is shown in Figure 4.

(b) (4)

Figure 4: Desktop System Transmitter Detailed Block Diagram

Energous Response -- 8
 Confidential – Not for Public Inspection

A detailed block diagram of the receiver is shown in Figure 5.

(b) (4)

(b) (4)

(b) (4)

Figure 6:(b) (4)

Energous Response -- 9
 Confidential – Not for Public Inspection

(b) (4)

(b) (4)

Figure 7: (b) (4)

3. Description of (b) (4)

(b) (4)

Energous Response -- 10
 Confidential – Not for Public Inspection

(b) (4)

is depicted in Figure 8.

(b) (4)

Figure 8: (b) (4)

(b) (4)

4. Desktop Transmitter overview (b) (4)

(b) (4)

Energous Response -- 11
 Confidential – Not for Public Inspection

Component Area for Section/Part Applicable Specs

Compliance
1 EMC Part 18 MP5 for TX Charger
2 EMC Part 15 ANSI C63.10 for BLE TX, RX
3 SAR Part 1.1310, Part 2.1093 IEEE1528, KDB 865664
4 Sensor Testing Section 4A N/A
5 Operating Area Section 4B N/A
6 (b) (4) Section 4C N/A

Table 3: Key components for Compliance

A) (b) (4)

(b) (4)

(b) (4)

Figure 9: (b) (4)

Energous Response -- 12
 Confidential – Not for Public Inspection

B) (b) (4)

The “Operating Area” is defined as a region in front of the transmitter where authorized
receivers will charge. Sensors, BLE and the transmitter’s proprietary tuning is used to
determine if the receiver is within the authorized operating area before the transmitter is
allowed to charge the receiver. (b) (4)

(b) (4)

operating area per Figure 10.

(b) (4)

Figure 10: Operating area test plan (b) (4)

C) (b) (4)

Energous Response -- 13
 Confidential – Not for Public Inspection

(b) (4)

(b) (4)

Figure 11: (b) (4)

(b) (4)

Figure 12: (b) (4)

Energous Response -- 14
 Confidential – Not for Public Inspection
(b) (4)

Figure 13: (b) (4)

5. Method for demonstrating exposure mitigation and compliance.

To demonstrate RF exposure compliance, SAR measurement scenarios have been extensively

analyzed to determine the suitability of the use of commercially available scalar SAR probes to
measure SAR from a multiple antenna system. Extensive simulations and measurements will be
performed on the Desktop Transmitter to determine the positioning of the SAR scalar probe
considering the transmitter’s (b) (4) direction, location, the Operating Area, the person’s
approach rate and the sensor system’s detection. SAR measurements will be made to cover the
entire operating area to ensure the maximum SAR value is measured.
(b) (4)

(b) (4)

Energous Response -- 15
 Confidential – Not for Public Inspection

RF exposure compliance measurements will include:

A) (b) (4)
i) (b) (4)

ii) (b) (4)

iii) (b) (4)

iv) (b) (4)

B) (b) (4)
i) (b) (4)

ii) (b) (4)

iii) (b) (4)

a. (b) (4)

b. (b) (4)

c. (b) (4)

d. (b) (4)
iv) (b) (4)

v) (b) (4)

Energous Response -- 16