IMES White Paper Version 1.0 June 31, 2016 GNSS Technologies, Inc. Page 1 / 59. IMES White Paper. Version 1.0. Naoko Yoshida and Dines Manandhar

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1 GNSS Technologies, Inc. Page 1 / 59 IMES White Paper Version 1.0 By Naoko Yoshida and Dines Manandhar GNSS Technologies Inc. Japan June 31, 2016

2 GNSS Technologies, Inc. Page 2 / 59 Revision History Date Version Revised Page Revision Smarmy Issued By 2016/6/ n/a First Release Naoko Yoshida

3 GNSS Technologies, Inc. Page 3 / 59 Table of Contents 1 Introduction Problems of Indoor Navigation What is IMES? Signal Design IMES Advantages Comparison between IMES and GPS IMES PRN Code IMES Message Types IMES Message Structure Preamble Message Type CNT Data Combination of IMES Messages IMES Transmitter IMES Transmitter Chip IMES Transmitter Module IMES Transmitter Finished Product IMES Transmitter with PoE IMES Transmitter Signal Power IMES Interference Analysis IMES / GNSS Receiver Chips Broadcom U-blox SONY Smartphones and Tablets IMES compatible smartphones in Europe JAXA Guidelines and Regulation Roles and Functions of Control and Management Operator Operation Agency IMES Operation Manager... 39

4 GNSS Technologies, Inc. Page 4 / IMES Product Manager Sales Operator Manufacturer Tasks of IMES Transmitter User IMES Transmitter Types IMES V5 Command IMES Control and Management System Indoor Map Apps Characteristics of Indoor Map Tool Structure Map Generation Step Indoor Map Example Other Indoor Map Providers Google Indoor Map Apple Micello HERE GNSS Technologies, Inc Patents IMES Signal Structure Patent IMES Transmitter Patent License Condition for IMES Patents ECC Regulation for Indoor Position ECC Regulation Summary ECC Document References List of EU Countries that Approved ECC Regulation Map of European Countries Status on ECC Regulation Guideline ECC Locations News and Press Releases Additional Resources References... 58

5 GNSS Technologies, Inc. Page 5 / 59 List of Figures Figure 1 IMES Introduction... 8 Figure 2: Comparison of IMES vs. Wi-Fi based Indoor Position Accuracy Figure 3: Seamless Navigation based on GPS / IMES Figure 4: Message Type 0 (3 words) Figure 5: Message Type 1 (4 words) Figure 6: Message Type 3 (1 word) Figure 7: Message Type 4 (2 words) Figure 8: Combination of Message Type 1 and Type Figure 9: Combination of Message Type 0 and Type Figure 10: Combination of Message Type 4 and Type Figure 11: IMES Transmitter Chip Figure 12: IMES Transmitter Chip Circuit Diagram Figure 13: IMES Transmitter Module Figure 14: IMES Transmitter Finished Product (Medical Version) Figure 15: PoE Version of IMES Figure 16 Receiver Power and Distance from Users Figure 17: Free Space Propagation Model, Signal Power and Coverage Figure 18: Direct Signal Power with Wall/Partition Effects Figure 19 Experiment setup for interference study Figure 20 Test to setup IMES Transmitter for Off limit area Figure 21TTFF at different vertical distance for different Figure 22: Broadcom s IMES Capable GNSS Receiver Chip Figure 23: u-blox IMES Capable GNSS Receiver Module Figure 24: SONY s IMES Capable GNSS Receiver LSI Figure 25: GNSS/IMES Compatible Chip, Module and Devices Figure 26: Roles and Functions of Control and Management Figure 27: Tasks of IMES Transmitter User Figure 28: IMES V5 Command ( 評価版 ) verison Figure 29: IMES Control and Management System Figure 30: Structure of Indoor Map Generation Tool Figure 31; Indoor Map Example Figure 32:User interface of IMES Indoor Map Apps Figure 33: Location information shown in IMES Indoor Map Apps Figure 34:World Map of IMES Signal Structure Patent Status Figure 35:World Map of IMES Transmitter Patent Status Figure 36: European Countries Status on Regulation Figure 37: ECC Locations in Europe... 54

6 GNSS Technologies, Inc. Page 6 / 59 List of Tables Table 1: IMES Advantages Table 2: Comparison between GPS and IMES Table 3: List of IMES PRN Codes Table 4 Recommended Gold Codes Table 5: IMES Message Types Table 6: IMES compatible smartphones in European counties Table 7: Summary of IMES Transmitter Types... 41

7 GNSS Technologies, Inc. Page 7 / 59 List of Acronyms ARNS C/No CDMA CEPT CW DME EC ECC EESS EIRP ESA ETSI EU FDMA GALILEO GNSS GPS ICAO IMES ITU-R JAXA MSG NAV PL PoE PRN QZSS RLS RNSS Rx or RX SNR Tx or TX Aeronautical Radio Navigation Service Carrier-to-Noise Ratio Code Division Multiple Access European Conference of Postal and Telecommunication Administration Continuous Wave Distance Measuring Equipment European Commission Electronic Communications Committee Earth Exploration Satellite Service Equivalent Isotropic Radiated Power European Space Agency European Telecommunications Standardisation Institute European Union Frequency Division Multiple Access Global Positioning System of the European Union, a GNSS system Global Navigation Satellite System operating within the RNSS Global Positioning System of the United States, a GNSS system International Civil Aviation Organisation Indoor Messaging System International Telecommunications Union Radio sector Japan Aerospace Exploration Agency Message Navigation Pseudolite Power over Ethernet Pseudo Random Number Quasi Zenith Satellite System Radio Location Service Radio Navigation Satellite Service Receiver Signal-to-Noise Ratio Transmitter

8 GNSS Technologies, Inc. Page 8 / 59 1 Introduction This document explains all aspects of IMES including signal design, transmitter, hardware, software, applications, patents, regulations and business models. Figure 1 IMES Introduction IMES is a unique solution that provides positon data indoors even in a deep indoor location. It uses a RF signal similar to the GPS. In order to allow GNSS receiver to receive IMES without any hardware modification. Any device with a GPS receiver can be used to obtain positioning information from IMES by implementing only a set of PRN codes specifically defined for IMES. Users will be able to get position data from GNSS receiver regardless of whether the user is outside or inside of the room even in the deep inside as long as the IMES transmitter is installed. This is the concept of seamless positioning as users do not have to worry about outside or inside, In order to provide the seamless positioning; GNSS Technologies, Inc. has invented the IMES together with JAXA. The development of IMES has solved the problems and shortcomings of indoor positioning by providing accurate and reliable 3D position data in indoor or deep indoor areas. IMES can provide 3D position with Floor ID by using a single IMES transmitter.

9 GNSS Technologies, Inc. Page 9 / 59 2 Problems of Indoor Navigation The problem of getting accurate and reliable indoor position has been a major problem so far. Technical solutions like Pseudolite was proposed but could not be implemented practically due to its complex structure cost and difficulties in providing required level of accuracy and reliability in indoor or deep indoor areas. With Pseudolite, three or more transmitters for 2D positing and four or more transmitters for 3D positioning are required with simulation of GPS signal for the specific time and position, and its receivers require performing range calculation between a receiver and multiple transmitters. In addition, multiple transmitters and receiver require synchronization of clocks. Thus it is complex and costly. And a lot of walls, doors, furniture and other objects with flat surfaces typically located indoor create multipath. Such multipath causes errors in the ranging calculation at receiver. Thus, Pseudolite is not able to satisfy users demands for accurate positioning and reliable accuracy with easy setup process at reasonable costs in indoor areas. As alternative solutions, Wi-Fi and Bluetooth are now being used. These technologies also have their own limitations in providing accurate and reliable position data. The position data acquired from Wi-Fi wanders due to various factors like multipath, irregular signal level degradation, lack of accurate AP database and regular maintenance difficulties to update the database itself. Moreover, Wi-Fi can provide only 2D position data with an accuracy level of few meters to few hundreds of meters depending upon area and device concentration. Typically, the location information obtained from hotspots is actually the position information of hotspots itself, it has innate inaccuracy of the distance between those hotspots and devices, that is approximately 100 meters the Height data can t be provided using Wi-Fi based systems. And there is no concept of providing Floor ID. Bluetooth, on the other hand, can provide receivers with positioning information using RFID tag based beacon to provide receivers with fingerprint locations. Since database of fingerprint locations need to be available in receiver, additional applications with dedicated map to match the fingerprint location are required. Bluetooth supported applications with indoor maps are not widely available. However, in the absence of other sensors or devices, we had no choice but to stick to Wi-Fi and Bluetooth devices although these devices and sensors are not built for positioning purpose. Then, the most typical problem of indoor navigation in the market now is position accuracy. Outdoor positioning information provided in mobile phone and smart phone is based on A-GPS with position accuracy between 5 to 30 meters in general. And as soon as those devices are moved to a location where GPS and GLONASS signal is not reachable, the updated positioning information becomes not available. Some of applications in those devices would use the location information obtained and saved previously or calculate the updated position with pedestrian dead reckoning (PDR) when there is no Wi-Fi positioning system (WPS). And the more the devices spend time indoors, the less the devices maintain position accuracy.

10 GNSS Technologies, Inc. Page 10 / 59 Even though there are GPS and GLONASS signal available indoor for example nearby windows, the device would maintain less accuracy than 5 to 30 meters due to multipath effect. And when WPS is used indoor, since the location obtained from hotspot is actually the position information of hotspot itself, it has innate inaccuracy of the distance between the hotspot and devices, which is approximately 100 meters since typical broadcasting range of b or g hotspots with the stock antenna is 100 meters. The following is the test result of comparison among IMES, A-GPS and WPS inside our office. These devices are put on a meeting table around 10 meters away from windows. A device with high sensitivity GPS had position error of 100 meters, the device with WPS had position error of around 50 meters, and the device with IMES had position error of less than 10 meters. Figure 2: Comparison of IMES vs. Wi-Fi based Indoor Position Accuracy Due to the high position error, existing technology is not desirable for indoor navigation especially for guiding emergency exit, shop and shelf locations and other locations where availability of indoor navigation is important. Figure 2 shows the comparison of indoor position accuracy between IMES and Wi-Fi. 3 What is IMES? IMES is a unique solution that provides positon data with floor number at indoor and deep indoor locations using a radio signal that is similar to the GPS signal. In order to receive IMES signal, a GPS receiver does not require any hardware modification. Thus any device with a GPS receiver can be used to obtain positioning information from IMES. The GPS receiver needs to implement only a set of PRN codes specifically defined for IMES. IMES can provide 3D position data with Floor ID only with a single transmitter. This is possible because the receiver does not need to compute distance between the receiver and the transmitter. Once the receiver demodulates the IMES signal, it captures navigation data with position data of the transmitter. This position data is given to the user. This makes the receiver very simple, low power consumption and low cost.

11 GNSS Technologies, Inc. Page 11 / Signal Design The signal structure of IMES is designed in a way that any GPS or GNSS receiver can be used without any hardware modification. Currently, IMES signal is compatible with GPS L1C/A signal but it can be made also compatible with other signals including Galileo E1. The reason why signal design is made compatible is to use the existing GPS/GNSS receivers as it is without hardware modification. Thus any product with a GPS receiver can be used to acquire IMES signal. The receiver only needs firmware modification. This modification requires implementation of 10 IMES PRN codes and message decoding logics. This design allows seamless navigation between indoor and outdoor using GPS and IMES as shown in Figure 3: Seamless Navigation based on GPS / IMES Figure 3: Seamless Navigation based on GPS / IMES

12 GNSS Technologies, Inc. Page 12 / IMES Advantages A fundamental advantage of IMES is that it can provide 3D position data with Floor ID with only one IMES transmitter using a standard GPS receiver. Since, IMES transmits the position data itself embedded in its navigation message, the receiver does not have to perform any range calculation between a receiver and multiple transmitters unlike it is required in GPS. Table 1 shows the advantages of IMES with respect to Pseudolite. Since IMES does not require ranging calculation, both transmitter and receiver do not need to synchronize clock. And IMES is not affected by multipath effects, which are normally causing errors in the ranging calculation in GPS/GNSS receiver. The impact of multipath effects is greater with Pseudolite due to the fact that there are usually a lot of walls, doors, furniture and other objects with flat surface indoor. Pseudolite requires three transmitters for 2D positioning and four transmitters for 3D positioning in order to allow receiver to perform ranging calculation. And the locations of those transmitters have to be carefully arranged in a way that the receiver can calculate accurate position with correct ranging calculations between one receiver and multiple transmitters. Therefore, the location arrangement of transmitters becomes complex. However, with IMES, only one unit of transmitter is required for both2d and 3D positioning and locations of transmitters can be flexibly arranged for easier installation plan While all those differences between IMES and Pseudolite, both are common in using GPS/GNSS signal and only a change of PRN codes is required for the receiver. The following Table 1 shows summary of IMES advantages. Table 1: IMES Advantages Item IMES Pseudolite Range Measurement No Ranging Ranging Synchronization Not required Required Multipath effect Nothing Strong 2D positioning by 1 unit by 3 units 3D positioning by 1 unit by 4 units Flexibility of installation Perfect Complex Implementation to GNSS receiver PRN code only PRN code only

13 GNSS Technologies, Inc. Page 13 / Comparison between IMES and GPS Basically, there are no differences between GPS and IMES signals. IMES signal is designed based on GPS L1C/A signal so that the same receiver can receive both GPS and IMES signals. However, the carrier frequency is offset by +/- 8.2kHz and two types of navigation data rates (50/250bps) are defined. Please note that IMES can be designed to adopt any other GNSS signal like Galileo E1 or Beidou signals. The basic concept is to replace the contents of the navigation message by required position data and IDs. The following Table 2 shows summary of comparison between GPS and IMES. Table 2: Comparison between GPS and IMES Item GPS IMES Center Frequency MHz MHz +/- 8.2kHz PRN ID PRN Code Chip Rate PRN Code Length 1.023MHz 1ms 1.023MHz 1ms Data Rate 50bps 50bps or 250bps Modulation BPSK BPSK Polarization RHCP RHCP

14 GNSS Technologies, Inc. Page 14 / IMES PRN Code Pseudo Random Noise Code (PRN Code) is a set of ranging codes comprised of zero (0) and one (1) used for measuring distances between GNSS satellites and a receiver. PRN code for GPS satellite is controlled and managed by Global Positioning Systems Directorate, a US government body of a joint service effort directed by the US Air Force and managed at the Space and Missile Systems Center, Air Force Space Command, Los Angeles Air Force Base, Calif. Its former organization of Global Positioning System Wing (GPSW) allocated ten PRN codes for the use of IMES in Japan. The list of PRN codes is shown in Table 3. Please refer to for further details. The characteristics of the IMES PRN codes are the same as GPS PRN codes. Please refer to for further information about IMES PRN Code. Table 3: List of IMES PRN Codes

15 GNSS Technologies, Inc. Page 15 / 59 Table 4 Recommended Gold Codes Gold Codes are PRN Codes without any regulations for its usage, which are actually the codes currently not reserved for GPS. If such Gold Code will be used for any implementations and installations of IMES in specific country or region, from technical perspective, certain sets of PRN codes are technically recommended. Out of those 556 balanced PRN codes technically suitable for the IMES, the green highlighted PRN codes shown in the Table 4. Are recommended.

16 GNSS Technologies, Inc. Page 16 / IMES Message Types The following Table 5 describes message ID, frame length and message contents. Currently, four message types with Message ID #0, #1, #3 and #4 are defined as shown in Table 5. Message ID #0 is used for 2D position data with Floor ID, Message ID #1 is used for 3D position data with Floor ID. We propose that at least Message ID #0 would be used as Global Standard for Position Data. Message ID #3 and #4 are defined for short ID and medium ID. These IDs can be freely defined by user for any purpose. For example, it can be a set of predefined categories to link these IDs to corresponding data in database system for location based services or any other applications. Medium ID (33bit) can be used for UUID (Universally Unique ID) depending on the configuration of database system. Please refer to for further information about IMES Message Types. Table 5: IMES Message Types Message ID Frame Length Message Contents #0 3 Words 2D Position, floor info #1 4 Words 3D Position, floor info #2 - Reserved #3 1 Word Short ID #4 2 Words Medium ID #5 - Reserved #6 - Reserved #7 - Reserved

17 GNSS Technologies, Inc. Page 17 / IMES Message Structure IMES message structure is defined by WORD and FRAME. A WORD is 30bits long and a FRAME may contain 1, 2, 3, or 4 words depending upon message type. Thus, each IMES message has a frame of one or multiple words. The first word in any message contains 8-bit preamble, 3-bit message type and 6-bit parity. If a message type has multiple words, then the remaining words contain 3-bit CNT data at the beginning of the word and 6-bit parity at the end. Brief explanations about Preamble, Message Type and CNT data are as follows. Please refer to for further information about IMES Message Structure Preamble The preamble for IMES is 0x9E and 8-bit long in size. Preamble value can be changed to 0x8B (same as in GPS) if required for test purpose using IMES setup program Message Type IMES message type is 3-bit long. Currently, message types 0, 1, 3 and 4 are defined and other types are reserved.

18 GNSS Technologies, Inc. Page 18 / CNT Data CNT data for Message Type 0, 1, 2, 3, and 4 is defined as shown in the following Figure 4, Figure 5, Figure 6, and Figure 7. Figure 4: Message Type 0 (3 words) Figure 5: Message Type 1 (4 words) Figure 6: Message Type 3 (1 word) Figure 7: Message Type 4 (2 words)

19 GNSS Technologies, Inc. Page 19 / Combination of IMES Messages Any combination of message types can be formed and transmitted as shown in Figure 8, Figure 9 or Figure 10. For example, Figure 9 shows the combination of message type 0 and type 4 to transmit 2D position and medium ID. This allows the users to obtain 2D position immediately and further information from a server based on medium ID. The combination of messages depends upon the target applications and usage. However, we recommend that the transmitter would be configured to transmit at least Message Type 0 as a global standard. Figure 8: Combination of Message Type 1 and Type 3 Figure 9: Combination of Message Type 0 and Type 4 Figure 10: Combination of Message Type 4 and Type 1

20 GNSS Technologies, Inc. Page 20 / 59 4 IMES Transmitter IMES transmitters are available in three different types: (1) IMES Chip, (2) IMES Module and (3) IMES Transmitter Finished Product. And several different IMES transmitter finished products are available in the market with a combination of other sensors including Wi-Fi, Bluetooth and different power supply systems such as PoE. Depending upon installation areas, surrounding environments and application types, IMES transmitter products can be customized in many different ways. 4.1 IMES Transmitter Chip IMES Transmitter Chip is 12mm x 12mm in size, consisting of a dual channel signal processor. Figure 11 shows the appearance of the IMES Transmitter Chip. It can transmit two IMES signals synchronized to the same local clock. These two signals can be independently controlled in terms of PRN code, Carrier Frequency Offset, Navigation data contents, transmit power and combination of message types. This gives flexibility in setting and deploying the transmitter in many different environments like office buildings, shopping complexes, airports, underground railway stations, tunnels and so many other complex areas. Figure 11: IMES Transmitter Chip

21 GNSS Technologies, Inc. Page 21 / 59 Figure 12 shows the circuit diagram of IMES Transmitter Chip. The detail explanations of the circuit diagram are planned to be documented in the IMES Transmitter Chip Development Kit. Figure 12: IMES Transmitter Chip Circuit Diagram

22 GNSS Technologies, Inc. Page 22 / IMES Transmitter Module IMES Transmitter module consists of IMES transmitter chip and all other necessary components to generate IMES signals. It has on-board TCXO, RF ports, on-board IMES transmitter antenna for channel 1, two RF connectors to connect external antenna. Figure 13 shows the appearance of IMES Transmitter Module. Figure 13: IMES Transmitter Module IMES Transmitter Finished Product Figure 14 shows appearance of IMES transmitter finished product designed for the installations at hospitals and homes for the inpatient management and homecare systems. Figure 14: IMES Transmitter Finished Product (Medical Version)

23 GNSS Technologies, Inc. Page 23 / IMES Transmitter with PoE Figure 15 shows IMES transmitter finished product with Wi-Fi and PoE based power supply. This device is specially designed for Push-and-Fit type of installation in Japanese buildings. The device is fitted in the false ceiling of the room. Since more and more intelligent buildings are developed with network platform and other intelligent functions already from when the buildings are constructed, this type of IMES transmitter finished products are developed and now installed in several new buildings in Japan. The PoE chassis can accommodate not only IMES but other functions including Wi-Fi hotspot and Bluetooth indoor positioning devices. 4.3 IMES Transmitter Signal Power Figure 15: PoE Version of IMES Signal power from the IMES Transmitter can be changed with RF Attenuator Setting of the IMES V5 Command. Selectable range is from 0 to 60 db attenuated from -66dBm. Figure 16 shows relationship between the signal power received at user and distance from transmitter to the user for your reference. Figure 16 Receiver Power and Distance from Users

24 GNSS Technologies, Inc. Page 24 / 59 Figure 17 explains Free Space Propagation Model, Signal Power and Coverage for your reference. The Free Space Propagation Model on the left hand side shows the relationship between distance from transmitter and propagation loss in db. The more there is a distance between transmitter and receiver, the more propagation loss. Its theoretical model of standard value was proven with actual measurement. The propagation loss is increasing as the distance from transmitter increases with a curve of 10 x log 10 (d2). And the right chart showing Signal Power and Coverage is the reference distance and signal power attenuator based on the model. For a spherical area of 1 m radius, when the signal power is -90dBm, its power at receiver is minimum -130dBm. When the signal power is -76dBm, the signal power at receiver by the distance from the transmitter is as it is shown in the chart. This model is also proven with the actual measurement as shown in the chart below although there are a lot of fluctuations due to multipath. * Y is a distance from a glass window in the measurement environment shown in the photograph. X is a distance from a point directly under the transmitter. The height of ceiling is 2.5 m and receiver is positioned 1 m above the floor. The transmitter is positioned 1 m away from the glass window. Figure 17: Free Space Propagation Model, Signal Power and Coverage

25 GNSS Technologies, Inc. Page 25 / 59 Figure 18 explains Direct Signal Power with Wall/Partition Effects for your reference. Figure 18: Direct Signal Power with Wall/Partition Effects 4.4 IMES Interference Analysis It is of utmost important to analyze the impact of the IMES signal on existing GPS signals. Since IMES compatible receivers are supposed to work at the same signal level as GPS receivers, there must not be any interference from IMES signal. The expected signal at the receiver will vary from -126dBm to -130dBm which are similar to GPS signal at the receiver. However, IMES transmitters are ground-based transmitters that may be located indoors or outdoors locations where users cannot obtain enough accuracy heavy multipath circumstance like sidewalk in the urban canyon. In such case, it is necessary to transmit the signal at the transmitter at much higher power level so that the signal at the receiver will be between -126dBm to -130dBm at a distance of about five meters from the transmitter antenna. The power level at the transmitter decides the IMES coverage zone. The larger the coverage zone is, the higher transmission power is required However, the maximum power is limited by regulation for license free signals. In Japan this limits the signal level at 35microVolt/m at 3m distance. The signal level regulation varies by countries and regions. This means that the transmit power you need to use for the IMES (e.g. -70dBm) is lower than the allowed value. Therefore, an experiment in typical Japanese building was conducted for the interference of the IMES signal on GPS signal. The experiment setup is shown in Figure 19.The typical building materials and size are different by countries and regions. Thus this is only a reference data. IMES transmitter is set outdoors on a pole with adjustable antenna height. The transmitter antenna is a standard GPS passive patch antenna. The height of the transmitter antenna can be varied from few tens of centimeters to four meters. Data are logged by changing the vertical distance between the IMES transmitter antenna and GPS receiver antenna at every 20cm interval from 20cm to 320cm. These data are logged for three different transmission power settings at -64dBm, -70dBm and -76dBm.

26 GNSS Technologies, Inc. Page 26 / 59 Figure 19 Experiment setup for interference study Two GPS receivers are set vertically beneath the IMES transmitter antenna. One of the receivers is software GPS receiver and another is a commercial GPS receiver (Rx1). One more commercial GPS receiver (Rx2) is set at 30m away from the IMES transmitter antenna (as reference for GPS signal) so that the IMES signal will not have impact on this receiver. Receiver Rx1 and Rx2 are of the same type and have the same configurations. Since the distance between Rx1 and Rx2, we can observe the same GPS satellites during the experiment period.

27 GNSS Technologies, Inc. Page 27 / 59 Figure 20 Test to setup IMES Transmitter for Off limit area Figure 20 shows the results for C/No with respect to vertical distance for visible GPS satellites including the IMES and vertical separation threshold distances where the first fix observed. These graphs show the minimum distance required for a GPS receiver to provide a fix. The graphs on top, middle and bottom of Figure 8 shows the results for 64dBm, - 70dBm and -76dBm respectively. At -64dBm, the GPS receiver provides first fix when the vertical separation between the IMES and GPS antenna is 240cm. This means IMES has impact on GPS signal when the GPS receiver is very near to the IMES transmitter antenna. Thus, for the GPS receiver to work properly at least a separation of 240cm is necessary. This distance is 100cm for - 70dBm transmitter power. Thus, at least 100cm of separation is necessary for a GPS receiver to work properly. At -76dBm, the GPS receiver provides first fix when the vertical separation is 60cm.

28 GNSS Technologies, Inc. Page 28 / 59 Figure 21TTFF at different vertical distance for different Figure 21 shows TTFF at different vertical distance for - 64dBm, -70dBm and -76dBm cases. Figure 20 shows the minimum distance for the first fix which is called threshold value. However, this first TTFF is much longer than normal GPS operation TTFF. As seen in Figure 21 the first TTFF is two to four time higher than normal TTFF. There seems to be some strong IMES signal s impact on acquisition process for GPS receiver. Thus, it is necessary to consider the distance for normal TTFF when an appropriate separation threshold distances is investigated as a range there is no harmful impact on live GPS signals. Hence, we conclude that at least 160cm shall be the separation threshold distances between the IMES transmitter and GPS receiver antenna to avoid possible interference from the IMES transmitter to GPS receiver. This distance is for -70dBm transmitter power level. However, if the transmitter power is higher, e.g. -64dBm, then the separation shall be at least 300cm as results from experiment currently. Vertical threshold distances for the TTFF could be found even if a GPS receiver is used beneath the IMES transmitter, i.e. it could be a worst case. Actual transmit powers of IMES shall be set based on the antenna location so that the distance between the IMES transmitter s antenna and the edge of zone, which outside GPS receiver exist potentially, is maintained less than above threshold distances and the user received power of the IMES is between -110dBm to -130dBm.

29 GNSS Technologies, Inc. Page 29 / 59 5 IMES / GNSS Receiver Chips IMES / GNSS Receiver Chips are manufactured and marketed for mobile phone, smartphone, and other mobile devices by several major chip manufactures as GNSS receiver single function chips and combo chips with GNSS receiver and other functions including Wi-Fi and other RF communication capabilities. Currently IMES /GNSS Receiver Chips are manufactured and marketed by Broadcom, U-blox and Sony. Several other major chip manufactures are in the process of product development, including Taiwanese and Chinese chip manufacturers supplying GNSS chips to major mobile device OEMs. 5.1 Broadcom Broadcom GNSS chips BCM4752 and BCM 4753 are IMES compatible. These GNSS chips are capable of receiving GPS, GLONASS, QZSS (including IMES) and SBAS signals. Figure 22 shows appearance of Broadcom s IMES Capable GNSS Receiver Chip. Please refer to Broadcom s website, for further information. Figure 22: Broadcom s IMES Capable GNSS Receiver Chip All the smartphones using Broadcom GNSS chips are capable of receiving IMES signal. For example, Samsung Galaxy S4, Galaxy Note 4, Covia Fleaz+f4, and HTC Nexus 9 / Google Nexus 9 are the models supporting IMES in Japan. 5.2 U-blox U-blox s series 8T GNSS receiver modules are IMES compatible. It can track all 10 channels of IMES signals with auto-detection of navigation message rate between 50bps and 250bps. U-blox outputs the navigation messag sentence. Currently, NEO/LEA-M8T based modules are capable of acquiring IMES signals.

30 GNSS Technologies, Inc. Page 30 / 59 Figure 23 shows appearance of U-blox s IMES Capable GNSS Receiver Chip. Figure 23: u-blox IMES Capable GNSS Receiver Module Please refer to U-blox s website, blox.com/sites/default/files/products/documents/neo-lea- M8T_ProductSummary_%28UBX %29.pdf and for further information. U-blox evaluation kits are also available. Please refer to

31 GNSS Technologies, Inc. Page 31 / SONY SONY has produced two types of GNSS receiver LSI CXD5600GF and CXD5601GG one type of GNSS Receiver Module CXD5430. All these chips and module are capable of receiving GPS, GLONASS, QZSS and IMES signals. Figure 24 shows appearance of Sony s IMES Capable GNSS Receiver Chip. Figure 24: SONY s IMES Capable GNSS Receiver LSI Please refer to for further information.

32 GNSS Technologies, Inc. Page 32 / Smartphones and Tablets Off-the-shelf smartphones and tablets with IMES capable GNSS chip are already available in the market. Some of the brand names are Galaxy S4, Galaxy Note 4, Nexus 9 from HTC and Google, Covia Fleax+f4, Toshiba tablet, Panasonic Tough Book etc. Please see Figure 25 for some pictures of the devices. Figure 25: GNSS/IMES Compatible Chip, Module and Devices

33 GNSS Technologies, Inc. Page 33 / IMES compatible smartphones in Europe Table 6 describes IMES compatible smartphones currently available by service providers by countries in Europe. Due to the dynamic characteristics of the smartphones market, IMES compatible smartphones availabilities may rapidly change time to time. We are currently in discussions with global GNSS chip manufactures to expand the number of products supporting IMES. Please note that availability of the local smartphone models using the Broadcom chips need to be verified with actual products. GNSS Chips used in the listed models may vary by the areas and regions where they are sold and/or by the generations or versions of the product. This information is not publicly announced by smartphone OEM and/or chip manufacturers. GNSS Chip information is solely based on third party research results published in websites, including and some other resources. GNSS Technologies, Inc. is neither liable for the information nor responsible for the compatibility with IMES.. Table 6: IMES compatible smartphones in European counties Manufacturer Samsung Model Galaxy S6 Galaxy S6 edge Galaxy S6 edge+ Galaxy A3 Galaxy A5 GNSS Chip Broadcom BCM4773 Broadcom BCM4773 Broadcom BCM4773 Broadcom BCM4511 Broadcom BCM4753IA1 Country Germany IMES yes yes yes yes yes Service Provider IMES Capability Vodafone yes yes yes yes yes T-Mobile yes yes yes yes yes Telefonica (O 2) yes yes yes yes yes Orange yes yes yes yes yes Vodafone yes yes yes UK Telefonica (O 2) yes yes yes yes Orange (EE) yes yes yes yes 3 yes yes yes yes

34 GNSS Technologies, Inc. Page 34 / 59 Manufacturer Samsung Model Galaxy S6 Galaxy S6 edge Galaxy S6 edge+ Galaxy A3 Galaxy A5 Country France Italy GNSS Chip Service Provider Broadcom BCM4773 Broadcom BCM4773 Broadcom BCM4773 IMES Capability Broadcom BCM4511 Broadcom BCM4753IA1 Orange yes yes yes yes yes SFR yes yes yes yes yes Bouygues Telefonica yes yes yes yes Free yes yes yes Vodafone yes yes yes yes Yes Telefonica (WIND) yes yes yes yes Orange yes yes yes yes yes 3 yes yes yes yes TIM yes yes yes Spain Andorra Austria Vodafone yes yes yes yes Telefonica (Movistar) yes yes yes yes Orange yes yes yes yes Telia Sonera (Yoigo) Andorra Telecom Telecom Austria (A1) yes yes yes yes SIMM free SIMM free SIMM free SIMM free SIMM free yes yes yes yes T-Mobile yes yes yes 3 yes yes yes yes

35 GNSS Technologies, Inc. Page 35 / 59 Manufacturer Samsung Model Galaxy S6 Galaxy S6 edge Galaxy S6 edge+ Galaxy A3 Galaxy A5 GNSS Chip Broadcom BCM4773 Broadcom BCM4773 Broadcom BCM4773 Broadcom BCM4511 Broadcom BCM4753IA1 Country Denmark Service Provider IMES Capability TDC yes yes yes yes Telenor yes yes yes Telia yes yes yes yes 3 yes yes yes yes yes Telia (EMT) yes yes Estonia Elisa yes yes Tele2 yes yes yes yes yes Liechtenstein Telecom Liechtenstein AG Salt (Liechtenstein) AG Swisscom (Schweiz) AG yes yes yes yes Yes yes yes yes Yes yes yes yes yes Yes POST yes yes yes yes Yes Luxembourg Tango yes yes Orange yes yes Montenegro Telenor yes yes yes Telekom yes yes yes yes Yes

36 GNSS Technologies, Inc. Page 36 / 59 Manufacturer Samsung Model Galaxy S6 Galaxy S6 edge Galaxy S6 edge+ Galaxy A3 Galaxy A5 Country Norway GNSS Chip Service Provider Broadcom BCM4773 Broadcom BCM4773 Broadcom BCM4773 IMES Capability Broadcom BCM4511 Telenor yes yes yes yes NetCom yes yes yes yes Broadcom BCM4753IA1 KPN yes yes yes yes yes Netherlands Vodafone yes yes yes yes yes T-Mobile yes yes yes yes yes Telia yes yes yes yes Sweden Tele2 yes yes yes yes Telenor yes yes yes yes 3 yes yes yes mts yes yes Serbia Telenor yes yes yes yes vip yes yes yes yes yes Orange yes yes yes yes yes Slovenia Telekom yes yes yes yes yes O 2 yes yes yes yes Swisscom yes yes yes yes yes Switzerland Sunrise yes yes yes yes yes Salt yes yes yes yes

37 GNSS Technologies, Inc. Page 37 / 59 Manufacturer Samsung Model Galaxy S6 Galaxy S6 edge Galaxy S6 edge+ Galaxy A3 Galaxy A5 Country Finland GNSS Chip Service Provider Broadcom BCM4773 Broadcom BCM4773 Broadcom BCM4773 IMES Capability Broadcom BCM4511 Broadcom BCM4753IA1 Sonera yes yes yes yes yes Elisa yes yes yes yes yes DNA yes yes yes yes yes Omnitel yes yes yes yes yes Lithuania BITĖ yes yes yes yes yes Tele2 yes yes yes yes yes Teledema yes yes yes yes

38 GNSS Technologies, Inc. Page 38 / 59 6 JAXA Guidelines and Regulation JAXA published IMES transmitter Control and Management Procedure Document ( Japanese Only) for the purpose of appropriate control and management of IMES transmitters to avoid IMES transmitters from affecting GNSS services sharing the same frequency with IMES. The objectives of this procedure are to prevent IMES transmitters from inappropriate usages other than its original application and interference caused by duplication of PRN codes installed in between IMES transmitters controlled and managed by two different operators. 6.1 Roles and Functions of Control and Management There are six different types of entities: Operator, Operation Agency, IMES Operation Manage, IMES Product Manager, Sales Operator and Manufacturer, which are involved with control and management of IMES transmitters. The summary of roles and functions is shown in the Figure 26. Figure 26: Roles and Functions of Control and Management

39 GNSS Technologies, Inc. Page 39 / Operator Operator is an entity with the ownership of operations using IMES Transmitters at operator s specific site. Operator outsources installation, management and control of IMES Transmitters to Operation Agency. Operator manages and controls its own site and outsources its tasks to Operation Agency. When these functions and roles are not outsourced, the operator needs to assume the tasks involved at operation agency. Operator creates layout chart to specify the locations of IMES transmitters Operation Agency Operation Agency is an entity assumes roles and functions of operator as agency through providing outsourcing service to Operator. Tasks assumed by operation agency are management and control of IMES transmitters for its whole life cycle from installation to disposal, periodical check for location, signal power and frequency, and installation, change and disposal. Operation Agency also takes care of application to IMES Operation Manager and Sales Operator for the usage of IMES transmitters, and tasks involved with Management DB IMES Operation Manager Sales Operation Manager is an entity assumes roles and functions of management and control of IMES Transmitters. JAXA assumes those roles and functions for the time being. IMES Operation Manager has a central database for the management and control of IMES transmitters called IMES Product Management DB IMES Product Manager IMES Product Manager is an entity assumes roles and functions of approval on IMES Transmitters. JAXA assumes those roles and functions for the time being. IMES Product Manager has a central database called IMES Operation Management DB for the management and control of IMES Transmitters Finished Products Sales Operator Sales Operators is an entity assumes roles and functions of marketing IMES Transmitters under sufficient management and supervision from IMES Operation Manager and IMES Product Manage. Sales Operator is also responsible for Type-C Transmitter until installation at Operator. For the detail of Type-C Transmitter, please refer to 6.3 Transmitter Types.

40 GNSS Technologies, Inc. Page 40 / Manufacturer Manufacturer is an entity assumes roles and functions of manufacturing IMES or subcontracted manufacturing IMES Transmitters by Sales Operator. Manufacturer is also responsible for Type-C Transmitter until transfer to Sales Operator. For the detail of Type-C Transmitter, please refer to 6.3. Transmitter Types. 6.2 Tasks of IMES Transmitter User IMES Transmitter User is Operator and/or Operation Agency. The tasks are started from the status of Procurement of IMES Transmitter from Manufacturer and Sales Operator. And then IMES Transmitters are installed at site to provide positioning services. IMES Transmitter User always checks whether those IMES Transmitters are in the status of In- Service or Out-of-Service time to time based on its status changed through its suspension and resumption. IMES Transmitter User also checks change status of the IMES Transmitter in terms of location information of transmitter message, transmitted power and PRN number. IMES Transmitters would be also stored for later installation after procurement or retirement from installed locations being the status of In-Storage. IMES transmitters located at site and/or in storage would be disposed time to time being the status of Disposal. IMES User needs to conduct those tasks and also grasp the status of each and every IMES Transmitters. Summary of those tasks of IMES Transmitter User are shown Figure 27. Figure 27: Tasks of IMES Transmitter User

41 GNSS Technologies, Inc. Page 41 / IMES Transmitter Types There are three different types of IMES Transmitters of Type-A, Type-B and Type-C. Those three different types are categorized mainly by whether or not those IMES Transmitters have activation function and/or deactivation function. The summary of those three types of IMES Transmitters is shown in Table 7. Table 7: Summary of IMES Transmitter Types

42 GNSS Technologies, Inc. Page 42 / 59 7 IMES V5 Command The IMES V5 Command is used to operate the IMES Transmitter. This software needs to be installed in Windows PC. The version of IMES V5 Command included in the IMES Free Trial Kit is IMES V5 Command ( 評価版 ) version 2.4. This version of software is used to configure the IMES Transmitter through USB connection. The user interface of IMES V5 Command ( 評価版 ) version 2.4 is shown in Figure 28. Figure 28: IMES V5 Command ( 評価版 ) verison 2.4 It can set up various settings of each and every IMES Transmitter finished products by selecting serial numbers corresponding to individual products. It can also show the current status of the products in the status indicator section. If the IMES Transmitter is configured in the way that settings can be stored in text file (SN.TXT as Setup File, the file located within the same folder of the software becomes able to store information set through the user interface by serial number of IMES Transmitter finished products. The IMES Transmitter included in the IMES Free Trial Kit is not configured for this function. If you require to use this setting, please consult with GNSS Technologies, Inc. The settings configured through the user interface and saved in SN.TXT file are Offset frequency, PRNID, Accuracy Index, Preamble, Location Parameter including latitude, longitude, attitude, short ID, Medium ID, Floor ID, Configuration, RF attenuator, and Message Sequence. Since the latest IMES Transmitter finished product has two channels. 1CH and 2CH can be separately configured to save its setting in SN.TXT file.

43 GNSS Technologies, Inc. Page 43 / 59 8 IMES Control and Management System Figure 29 explains system framework of IMES Control and Management System. The system is comprised of five databases of Administrative DB, IMES Unit DB, History DB and Relational DB of IMES DB and CAD DB. Administrative DB stores and updates data of responsible party, registration, building and owners information. IMES Unit DB stores and updates data of IMES-ID, Position Data, PRN, Place Information, Floor Number, RF Attenuator Level, Doppler Offset, Manufacture and Data of Installation. And History DB stores and updates data of Data, Time, Building, Floor, Administration, Installation and Maintenance. System provides user interface to input data in three DBs of Administrative DB. IMES Unit DB and History DB and those data stored in three DBs updates two relational DBs of IMES DB and CAD DB real time to allow users to output reports for control and management on demand. Figure 29: IMES Control and Management System

44 GNSS Technologies, Inc. Page 44 / 59 9 Indoor Map Apps We have developed a tool to create Indoor Map Apps using various data formats. The supported data formats are SVG, GIF, PNG, JPEG, TIFF, GML, GeoJSON, Shape and some others. This tool can be used with both raster and vector maps, and/or scanned paper maps. In the case of maps that do not have reference coordinates, two control points can be used to register the map to world coordinate system. These two control points may be measured using a GPS or taken from other existing sources. 9.1 Characteristics of Indoor Map Tool Web-Based Application Support to Multiple popular data formats; SVG, GIF, PING, TIFF, GML, GeoJSON, Shape etc. Support for Geo-fencing. Support for Walking space network. API of various forms are offered, for example: Web-API, Android SDK, ios SDK, etc 9.2 Structure Site Building Building API Applications Floor Floor Floor Anchor Points Network Area POI Figure 30: Structure of Indoor Map Generation Tool

45 GNSS Technologies, Inc. Page 45 / Map Generation Step Maps for IMES Indoor Map Apps can be generated with the following steps: Create Site Create Building Create Floor Register Anchor Point Register Area Segmentations Register Network Data Register POIs Use Data Via API Indoor Map Example Figure 31 shows an example of user interface development menu of IMES Indoor Map Apps generation tool: Figure 31; Indoor Map Example

46 GNSS Technologies, Inc. Page 46 / Other Indoor Map Providers Google Indoor Map Google Indoor Map is an indoor map service to give users ability to explore and navigate themselves within facilities including shopping malls, airports, stations, universities, museums, and other public spaces. Facility owners can create their own indoor maps in accordance with Google Indoor Map specification in order to provide Google Map users with their facilities indoor maps as extensions to Google Map. Since the indoor location information made available with IMES is fully integrated as a location manager of Android as a part of GPS positioning function, positioning information obtained from IMES receives by Android smartphones are reflected to Google Indoor Map without any additional Apps or setting since as far as Google Map Apps is installed. Location Service API is installed in Android smartphone when Google Map Apps is installed. Please refer to for further information about Google Indoor Map Apple ios 9 Apple Maps, a standard Apps of iphone, support indoor map and public transit navigations. It is currently based on Location Services of ios 9 based on GPS, Wi-Fi and ibeacon, Apple s Bluetooth based positioning. Since iphone 6, 6S, and 6 plus and all ipad hardware do not support IMES, indoor maps of ios 9 Apple Maps are not used with IMES. Moreover, only a few indoor locations are supported by ios 9 Apple Maps. Unlike Google Indoor Map, Apple themselves are adding maps of indoor locations and there is no control from facility owners to add indoor maps. However, facility owners are able to provide their own ios Apps with indoor map using API provided by Apple for developers. Please refer to for further information about how to develop own ios Apps with indoor map support Micello Micello is a digital map company dedicated to indoor maps on ios and Android. The company develops their own indoor maps and platform for their partner s Apps as APIs and SDKs to provide their partner s Apps with functionality of indoor maps. Please refer to for further information about their services HERE HERE is digital map company mainly for outdoor maps and navigation on browsers and their own Apps on Android and ios. These indoor maps are based on Micello s own platform.

47 GNSS Technologies, Inc. Page 47 / GNSS Technologies, Inc. GNSS Technologies, Inc. has own indoor map application platform called IMES Indoor Map Apps. The IMES Indoor Map Apps is combination of map application development platform to easily create indoor map based on either vector format (eg. SVG file) or raster format (eg. png, jpg, tiff, bmp file) and mobile phone application platform (currently based on Google Play Developer API only). The map application development platform can create indoor map from supported files based on interior construction drawings. By designating two locations in the map with known coordinates, it can automatically assign coordinate information across all areas on the map. In addition, it can set both area groups for geo-fencing and routings for navigation. The mobile application can use the area groups to allow users to access certain functionality of application only when the users are located in certain position in pre-configured area groups. It can also use the routings to allow users to set the current position and destination to display the shortest route in the map to navigate the users. Figure 32 shows user interface of IMES Indoor Map Apps and Figure 33 shows location information displayed on IMES Indoor Map Apps. Figure 32:User interface of IMES Indoor Map Apps

48 GNSS Technologies, Inc. Page 48 / 59 Figure 33: Location information shown in IMES Indoor Map Apps. The current position information in the mobile application can be developed in several different ways. It can be developed in the way that it obtains location information from Android OS or it obtains information output data directly from GNSS receiver or even it obtains information from any other data sources.

49 GNSS Technologies, Inc. Page 49 / Patents GNSS Technologies, Inc. filed patent applications globally for the technology of IMES signal structure and IMES transmitter IMES Signal Structure Patent IMES signal structure patent is registered by European Patent Office with publication number of EP A [ ]. Figure 34 shows a world map of the counties with IMES signal structure patents in the status of registered and applied. Patented Filed Figure 34:World Map of IMES Signal Structure Patent Status

50 GNSS Technologies, Inc. Page 50 / IMES Transmitter Patent IMES Transmitter patent is registered by European Patent Office with publication number of EP A [ ]. Figure 35 shows a world map of the counties with IMES transmitter patents in the status of registered and applied. Patented Filed Figure 35:World Map of IMES Transmitter Patent Status

51 GNSS Technologies, Inc. Page 51 / License Condition for IMES Patents On the condition that the IMES FREE TRIAL KIT AGREEMENT as shown in Exhibit B is signed by participants of the IMES Free Trial Program, we will grant a non-exclusive license on the patent right to the participating party solely for the use of IMES Free Trial Kit. When participating party and any other third party use IMES Free Trial Kit, participating party is required to provide us with a list with the following information: 1. Installed locations and number of units of IMES Transmitters according to the format shown in APPENDIX A of the IMES FREE TRIAL KIT AGREEMENT. 2. Responsible party s name, address, telephone number, contact person and her or his address, who takes care of management of IMES Transmitters In addition, participating party is required to obtain appropriate PRN Codes assigned by US government for the use of IMES in the Country. GTI shall provide Participating Party with references to obtain PRN Codes and change PRN Codes setting in the IMES transmitter, IMES transmitter PCBA and/or IMES chip. Currently Ten (10) sets of PRN codes L1 C/A PRN codes from 173 to 182 as listed in the GPS IS document had been assigned by US government for the indoor positioning application only in Japan.

52 GNSS Technologies, Inc. Page 52 / ECC Regulation for Indoor Position 11.1 ECC Regulation Summary Pseudolite (Pseudo satellites, PL) are ground based radio transmitters that transmit an RNSS -like navigation signal that can be received and processed by standard radio navigation receivers compatible to the signals published in the Signal-in Space Interface Control Documents (SIS-ICD [1]) of the GPS and Galileo systems. They are intended to complement systems in the Radio Navigation Satellite Service (RNSS) by transmitting on the same frequencies in the bands MHz, MHz, and MHz. Since other radio services could also be affected by an uncontrolled use of PL, CEPT conducted sharing studies between PL and other systems on the frequency bands. The purpose of this Report is to describe guidelines for a regulatory framework under which PL could be operated in CEPT countries. The focus of the report is on PL implemented in indoor environments. CEPT acknowledges that there is planned usage of PL applications for outside environments. A separate CEPT Report on those applications may be developed in the future. Therefore, CEPT recommends in the meantime that outdoor use of PL should not be authorized. The main conclusions and recommendations are: It is recommended that; indoor GNSS PL should be authorized in the band MHz; It is recommended that PL be operated through individual authorization in particular so as to ensure that in areas where case by case studies are necessary (i.e., airport areas), no PL should be installed before the completion of those studies; Individual authorization should only authorize PL with dedicated codes. PL with non-dedicated codes should only be authorized, if necessary, in case of temporary experimentation and on a national basis. In terms of this report, PRN codes associated with satellite transmissions are termed Non-Dedicated PL codes. PRN codes that are specifically associated with pseudolite transmissions are termed Dedicated PL codes ; Knowledge of the location of GNSS pseudolite installations through licensing is recommended. CEPT administrations should not allow the installation of GNSS pseudolite in mobile vehicles; Any authorization or licenses for GNSS pseudolite installations could include guidance for reduction and reasonable checking of the potential to cause interference; Military or other government authorities as well as meteorological services may require specific site limitations ECC Document References

53 GNSS Technologies, Inc. Page 53 / List of EU Countries that Approved ECC Regulation Andorra, Austria, Denmark, Estonia, Finland, France, Germany, Italy, Liechtenstein, Lithuania, Luxembourg, Montenegro, Netherlands, Norway, Serbia, Slovenia, Spain, Sweden, Switzerland, and UK 11.4 Map of European Countries Status on ECC Regulation Guideline Figure 32 shows regional map of Europe with counties that agreed (blue), disagreed (green) or under consideration (pink) on the regulation based on ECC Regulation Guideline Iceland Finland Sweden Norway Estoni a Ireland Denmark De\ Latvia Lithuania UK Belgium The Netherlands Germany ルクセンブルク Poland Czech France Switzerla nd Austria Slovenia Hungary Romania Portugal Spain Italy Croatia Herzegovin セルビア a Albani a Bulgaria Greek Figure 36: European Countries Status on Regulation

54 GNSS Technologies, Inc. Page 54 / ECC Locations Figure 37 shows locations of regulators supporting ECC. Figure 37: ECC Locations in Europe

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