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March 5, 2017

BY EMAIL

Mr. 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 follow up response (“Response”) to the


previously submitted response by Energous Corporation (“Energous”) on December 12, 2016 to
certain inquiries from the Federal Communications Commission’s (“FCC” or “Commission”)
Office of Engineering and Technology (“OET”) that were raised during Energous’ meeting with
OET staff on Wednesday, October 26, 2016 and Tuesday February 28, 2017. 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general public in the normal course and that it will not be published as part of the Commission’s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 further response to certain inquiries proffered by
OET during Energous’ October 26 meeting with OET. The inquiries related
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
contains commercially sensitive, proprietary, and confidential technical
information, the release of which would adversely affect Energous’
competitive position.

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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,

Jeff McNeil
Sr Vice President of Operations and Regulatory
Energous Corporation

Attachment

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Energous Response to OET’s Inquiry
Regarding Energous’ Wireless Power Transfer Desktop System Technology

March 5, 2017

Overview

In the meeting between Energous Corporation (“Energous”) and the Federal Communications
Commission’s (“FCC” or “Commission”) Office of Engineering and Technology (“OET”) on
October 26, 2016, the parties discussed (b) (4)
Energous submitted a response to OET in
connection with these inquiries on December 12, 2016. The information set forth herein
supplements the information provided by Energous in that initial response. This report
demonstrates that the WPT AAD desktop system (“Desktop System”) that Energous will submit
for certification (b) (4)

Desktop Transmitter

In the December 12, 2016 report (b) (4)

The design of the transmitter was modified to (b) (4) (b) (4) The
picture in Figure 1 below is the transmitter that Energous plans to work with a TCB to certify.

The configuration of the transmitter in Figure 1 has 12 antennas that are positioned with six
antennas at each end of the transmitter. (b) (4)

The table below is a description of the system.

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

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 1 – Desktop Transmitter

Figure 2: (b) (4)

(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 3:(b) (4)
(b) (4)

Figure 4: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 5: (b) (4)
(b) (4)

Figure 6: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 7: (b) (4)
(b) (4)

Figure 8: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 9: (b) (4)

(b) (4)

Figure 10: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 11: (b) (4) .
(b) (4)

Figure 12: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 13: (b) (4)

(b) (4)

Figure 14: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 15: (b) (4)

(b) (4)

(b) (4)

Figure 16: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 17: (b) (4)

(b) (4)

Figure 18: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 19: (b) (4)
(b) (4)

Figure 20: (b) (4)


(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 21: (b) (4)

(b) (4)

Figure 22: (b) (4)

(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 23:(b) (4)

(b) (4)

Figure 24:(b) (4)

(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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Figure 25:(b) (4)

(b) (4)

Figure 26: (b) (4)

(b) (4)

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Conclusion

The measured and simulation data supports the conclusion(b) (4)

CONFIDENTIAL – NOT FOR PUBLIC INSPECTION


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