FCC Regulations and Multi-band Operation Month Year doc.: IEEE 802.11-11/draft November 2011 FCC Regulations and Multi-band Operation Date: 2011-11-08 Authors: Notice: This document has been prepared to assist IEEE 802.18. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein. Rich Kennedy, Research In Motion John Doe, Some Company

Month Year doc.: IEEE 802.11-11/draft November 2011 Abstract There are a number of IEEE 802.11 groups looking at operating in one band after receiving an enabling signal in a different band, i.e. TGad, TGaf and TGai. The purpose of this discussion is to determine: Do FCC rules allow this, as the rules do not specifically ban it If they do, should we file an Inquiry to have this clarified If not, should we provide these task groups with guidance on how better to accomplish their requirements within the rules. Rich Kennedy, Research In Motion John Doe, Some Company

November 2011 Multi-Band Operation TGad wants to do rapid band switching to be able to move from 60 GHz to other bands as devices get out of range, while minimizing latency in streaming video and audio TGaf would benefit from the ability to access the Geo-location database in the 2.4 or 5 GHz band to find usable channels TGai has a requirement for fast initial link setup, which is difficult in the 5 GHz band, and want to actively scan the 2.4 GHz band for available channel information in the 5 GHz band, saving at least 100mS Rich Kennedy, Research In Motion

November 2011 FCC Part 15.202 Client devices that operate in a master/client network may be certified if they have the capability of operating outside permissible part 15 frequency bands, provided they operate on only permissible part 15 frequencies under the control of the master device with which they communicate. Master devices marketed within the United States must be limited to operation on permissible part 15 frequencies. Client devices that can also act as master devices must meet the requirements of a master device. For the purposes of this section, a master device is defined as a device operating in a mode in which it has the capability to transmit without receiving an enabling signal. In this mode it is able to select a channel and initiate a network by sending enabling signals to other devices. A network always has at least one device operating in master mode. A client device is defined as a device operating in a mode in which the transmissions of the device are under control of the master. A device in client mode is not able to initiate a network. Rich Kennedy, Research In Motion

November 2011 KDB 594280 Any device meeting the definition of a client as specified in Section 15.202 may have the ability to operate on other regulatory domain frequencies if it is under control of (automatically associated with) a certified master device. In this case, the "WARNING" statement mentioned above would not serve any purpose since frequency selection, power or grant conditions would be automatic, and regulatory domain selection would not be permitted. Rich Kennedy, Research In Motion

November 2011 KDB 594280 cont’d Many devices referred to by the WiFi industry as "client devices" may not meet the definition of a Section 15.202 client, and must be limited to operating as master devices on US frequencies, and within the grant conditions. To qualify as a Section 15.202 client, a device cannot initiate, or be configured to initiate, any transmission for any reason on non-US frequencies, or on frequencies not authorized for use. This includes probes, beacons, and ad hoc mode transmissions. Only if all features and functions that utilize initiating transmissions are within the frequencies as granted, can the device be authorized as a Section 15.202 client device. These devices can then automatically associate and operate on non-US frequencies when outside of the US, under the control of a foreign master device authorized on other regulatory domain frequencies. Rich Kennedy, Research In Motion

November 2011 Discussion Is it legal to operate on one band after receiving information about that band from a device operating on a different band? How can a device prove that the information regarding the second band is accurate and authentic? Location accuracy Information integrity How can this be tested to FCC satisfaction? Should we address this to the FCC in a KDB Inquiry? Rich Kennedy, Research In Motion

November 2011 Plan Rich Kennedy, Research In Motion