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Machiavellian said:

Actually is sounds more silly to not already have FCC Certification before going full production.  Would be really expensive if something cropped up and MS had to stop production, fix the issue, retool the plant and fix the already made consoles.  I think its safe to say that MS probably already got certification done already

Just did a quick search on the process and this part stood out

"Confidentiality

The manufacturer may request Confidentiality of the information from the FCC. This usually involves an additional $155 filing fee. If Confidentiality is not requested, all documentation will appear on the FCC website at the time the certification is granted. With the optional fee, the manufacturer can typically eliminate all design documents from this posting process."

They need at least to produce some units to sent to FCC... you can't use a prototype in FCC... and if they changed the clock in the latest months they need to make the certification again.

They did the FCC after the GPU upclock... I'm sure it was not in June.