Dynabook DCE46036A Tri-Mode Dual Band Analog/PCS Phone User Manual 307234

Toshiba Corporation Tri-Mode Dual Band Analog/PCS Phone 307234

EA873846 Users Manual Re Grant Set Aside

March 3, 2003
Mr. Richard Fabina, Chief,
FCC Authorization Branch,
Columbia, MD 21045
Subject: FCC ID: CJ6DCE46036A; EA873846
CellPhone/PCS Model CDM-9500
-Request for Grant Set Aside for Correction/Revision of SAR Values
Dear Richard:
Our great thanks to you for accepting our request to set aside the Grant for the subject
Phone for correction of the maximum Body SAR value
In addition to the Body SAR value, while in the set aside mode, we respectfully request
That the maximum Head SAR be revised. The reason and rationale for this are as
Follows:
Original Grant - 6/18/02
AMPS/CDMA Modes (Part 22) - Head SAR: 1.38 W/Kg
PCS/CDMA Modes (Part 24) - Head SAR: 1.25 W/Kg
Grant Reissued – 8/28/02
#1 C2PC - Application Date, 8/02/02 Comprised of:
>Metalized the front panel area of the cellphone
>Used production RF cables to set the conducted power
(cable loss for 800 MHz=1.5 dB (no change); Cable loss for
PCS=2.5dB
-SAR measurements were performed and submitted. Results were as follows:
AMPS/CDMA Modes (Part 22) - Head SAR: 1.33 W/Kg
PCS/CDMA Modes (Part22) - Head SAR: 1.35 W/Kg
Grant Reissued – 12/03/02
#2 C2PC - Application dated, 11/15/02 Comprised only of addition of new belt
clip & leather case
For this application, only Body SAR measurement was made. But the Grant
Was issued as follows:
AMPS/CDMA Modes (Part 22) - Head SAR: 1.38 W/Kg
PCS/CDMA Modes (Part 24) - Head SAR: 1.25 W/Kg
As you can see above, in this last permissive change grant, the highest
AMPS/CDMA SAR value was indicated. This value, 1.38 W/Kg was measured
on the original application for the very first CDM-9500 model. However, it was
decided not to produce and sell this model and within 6 weeks of receipt of the
grant, our factory submitted the modified model for testing at PC Test and an
application was filed on Aug. 2nd. (#1 C2PC)
As noted above, the grant reissued for the #1 C2PC, specified a lower
AMPS/CDMA Head SAR
value, thereby, making the PCS/CDMA head SAR the highest value, 1.35 W/Kg,
which is the value we specified in the users manual, which we printed for the
second version of the phone.
I can't stress to you strongly enough:
>we never produced or circulated any of the phones of the original design,
(1.38 W/Kg.), therefore, none exist in the field
>we never printed any manuals for the first version of the phone. The decision to
scrap the original phone design was made even before the grant was issued.
And only manuals for the second version were ever printed and circulated.
If necessary or needed, I will be glad to provide a signed affidavit in this regard.
>the manual currently in circulation correctly reflects the highest Head SAR value
(1.35 W/Kg) for the only phone version that was ever and is currently available
to the user.
Unfortunately, our factory was completely unaware that under a C2PC, the grant
always reflects the highest value measured and as a result, specified the value
they believed to be correct highest SAR value for the phone that would be
manufactured and circulated and not for the obsolete one.
Given that no phones were ever produced with the SAR value 1.38 W/Kg. we
respectfully and gratefully request that the grant be changed to reflect the actual
highest value, 1. 35 W/Kg., as this is a very critical issue for us and it would be
an incredible hardship for us to now amend all of the manuals that have been
shipped, as requested.
We would be truly grateful for the your understanding of this situation and
acceptance of our request. Thank you.
Best regards
Peter
PS. For complete accuracy, besides other values mentioned, the PCS/CDMA
Head SAR should be revised to 1.35 W/Kg, instead of 1.25 W/Kg
And, the PCS Body Worn SAR should be .56 W/Kg instead of .35 W/Kg.

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