WPC4w 2MBVRKZ3|jy.X80,IX\  P6G;P"i~'^09CSS999S]+9+/SSSSSSSSSS//]]]Ixnnxg]xx9?xgxx]xn]gxxxxg9/9MS9ISISI9SS//S/SSSS9?/SSxSSIP!PZ9+ZM999+99999999S/xIxIxIxIxIlnIgIgIgIgI9/9/9/9/xSxSxSxSxSxSxSxSxSxSxIxSxRxSxSxS]SxIxIxInInInZnIxigIgIgIgIxSxSxSxZxSxZxS9/9S999Su]ZZxSg/gCg9g9g/xSbxSxSxSxSxn9n9n9]?]?]?]ZgFg/gMxSxSxSxSxSxSxxZgIgIgIxSg9xS]?g9xSi+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN><q*"xxxxWWxxxWWkkxxxA.SSxSSJJSJS+SSSSS8SSSSSSSSS.xJxJxJxJxJorJiJiJiJiJ8.8.8.8.{SxSxSxSxS{S{S{S{SxSxJ{SxSxSxS{S`SxIxSxIqIqIrSrS{dgIiSiSgIxSxSxSxSxS{S{S8.SSSS8Sz]SSuSg/g/>/>/>/x]SSSSx]x]x]x]xSxSx]SSxSxSf]xSxSxSxIxIxWxIx{nInInInISSSWS]a?/?]?9?]]WW]n/nKn9nCn/x]xx]x]SSxxIxIxI]?]?]?]WnUn9nax]x]x]x]x]x]xxWnInInIx]n9x]]?n9xSz+SS8-8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNfx6X@`7X@8wC;,=Xw PE37XPD7zC;,bXz_ pi7XV"G($,hG PE37hP7jC:, Xj\  P6G;XP \5hC:,/Xh*f9 xr G;XX6uC;,F^Xu&_ x7XXx/c81,c PE37P z-b81,Fb&_ x7Xy.X80,IX\  P6G;P \{,W80,/?W*f9 xr G;X7nC:,VXn4  pG;XDy.f81,uf_ pi7y.\80,V [\4  pG;?xxx,kx `7XW!@(#,9h@\  P6G;hP6jC:,xLXj9 xOG;X8x8x8x(? ??000` 22w X S  X<X` hp x (#%'0*,.8135@8:telemarketing to solicit new business, it required IXCs to institute one of the following four  xconfirmation procedures before submitting PICchange orders generated by telemarketing:  x<(1)obtain the consumer's written authorization; (2) obtain the consumer's electronic authorization  xby use of an 800 number; (3) have the consumer's oral authorization verified by an independent  xthird party; or (4) send an information package, including a prepaid, returnable postcard, within  x=three days of the consumer's request for a PIC change, and wait 14 days before submitting the  xconsumer's order to the LEC, so that the consumer has sufficient time to return the postcard  X6- xdenying, cancelling, or confirming the change order. 6p {O&-#X\  P6G; IP#ЍXxSee 47 C.F.R.  64.1100; PIC Change Order, 7 FCC Rcd at 1045.(#ƶ Hence, the Commission's rules and orders"6j ,=(=(JJH"  xcurrently require that IXCs either obtain a signed LOA or, in the case of telemarketing  x.solicitations, complete one of the four telemarketing verification procedures before submitting PICchange requests to LECs on behalf of consumers.  X- ` x3.` ` Because of its continued concern over unauthorized PIC changes, the Commission  xrecently prescribed the general form and content of the LOA used to authorize a change in a  Xv- x-customer's primary long distance carrier.+ v yO-  >#X\  P6G; IP#ЍXxPolicies and Rules Concerning Unauthorized Changes of Consumers' Long Distance Carriers, 10 FCC Rcd  {O-9560 (1995) (LOA Order), reconsideration pending.(#+ The Commission's recent rules prohibit the potentially  xdeceptive or confusing practice of combining the LOA with promotional materials in the same  XH- xdocument. H" {O -#X\  P6G; IP#ЍXxSee id. at 957375. (#ƅ The rules also prescribe the minimum contents of the LOA and require that the  X1- xLLOA be written in clear and unambiguous language.1 {O-#X\  P6G; IP#ЍXxSee id. at 956465.(#ƃ The rules prohibit all "negative option"  X -LOAs  F {O-  #X\  P6G; IP#ЍXxSee id. at 956566. "Negative option" LOAs require consumers to take some action to avoid having their long distance telephone service changed.(#  and require that LOAs be completely translated if they employ more than one language.  {Ok-#X\  P6G; IP#ЍXxSee id. at 9581.(#ƀ III. THE COMPLAINTS TP  X - ` 4x4.` ` This forfeiture action is based on the staff's investigation of five consumer  xLcomplaints involving allegations of slamming by Heartline that were filed with the Commission  Xy- xbetween August 10 and September 21, 1995.Xy2  yO\-  {#X\  P6G; IP#ЍXxSince January 1, 1993, the Commission has received numerous consumer complaints about Heartline's   alleged slamming practices. Many of these complaints are under active investigation by the staff. Our action here is based solely on the five complaints specifically mentioned herein.(#ƥ Each of the complainants allege that Heartline  xconverted their long distance service provider without their authorization through the apparent  xuse of falsified or forged LOAs. In each case, the LOAs were apparently submitted to Heartline  xby one of its several sales and marketing agents. We describe each of the complaints and Heartline's responses to them below.  X-A.xJohn C. Best  X- ` x5.` ` In July 1995, Millennium Telecom, an independent agent of Heartline, apparently  xysent Heartline an order to switch the PIC of John C. Best, of San Diego, California, from AT&T,  X- xhis presubscribed long distance service provider, to Heartline. R  yO'-  #X\  P6G; IP#ЍXxLetter from Kristal Rasch, Consumer Complaints Analyst for Heartline, to Kathie A. Kneff, Chief,   Consumer Protection Branch (Dec. 26, 1995) (Best Response). Although Heartline states that it received   @Best's telephone number and LOA from Millennium Telecom, the LOA itself has no reference to   ]Millennium Telecom. Instead, it authorizes Tropic Tel to act as the signor's agent to switch the long"),** *"   distance provider for that number, and agrees that Tropic Tel may designate Heartline as the new preferred provider.(# Heartline states that the PIC" ,**Q"  xchange was submitted to Pacific Bell on July 11, 1995, apparently on the basis of Millennium  X- xKTelecom's representation that it had obtained the necessary authorization. p {O-  >#X\  P6G; IP#ЍXxId. Pacific Bell's records indicate that it received the order to switch from Allnet, and that USBI was the   {billing agent for Allnet. Letter from E. M. Saiz, ManagerInformal Appeals, Pacific Bell, to Suzanne   Perrin, FCC (Dec. 29, 1995). On the telephone bill provided by Best, USBI appears to be billing for   Heartline. Nowhere in Heartline's response to the Notice of Informal Complaint is there an explanation of the relationship between Heartline and Allnet or USBI.(#ƒ Upon learning of the  xswitch, Best contacted Heartline by telephone on August 7, 1995 and denied authorizing any  xchange to his PIC. In response, Heartline sent to Best a copy of the LOA upon which it had  X- x=relied to request the PIC change.np yO' -#X\  P6G; IP#эXxBest Response.(#n Best examined the signature on the LOA, which was dated  xMay 7, 1995, and determined that it was a forgery. He then sent a copy of his driver's license  x[to Heartline as evidence that the signatures on the LOA and the driver's license did not match.  xOn August 28, 1995, Best filed his complaint with the Commission, and included a copy of the  xallegedly forged LOA and a copy of his driver's license showing his signature as evidence to  X1- xZsupport his allegations.w1b p {OD-#X\  P6G; IP#эXxSee Attachment A.(#w Best also noted in his complaint that his street address is misspelled on  X - xthe LOA. The Common Carrier Bureau's Consumer Protection Branch p yO-#X\  P6G; IP#эXxFormerly known as the Informal Complaints and Public Inquiries Branch.(#Ʀ served the complaint  X -on Heartline and directed it to satisfy Best's complaint or explain why it was unable to do so. p yO8-#X\  P6G; IP#эXxNotice of Informal Complaint, File No. IC9526130 (Dec. 1, 1995).(#Ƣ  X -B.xMohammad Farooq  X - ` 3x6.` ` In July 1995, Millennium Telefonica, also an independent agent of Heartline, p yOl-  N#X\  P6G; IP#ЍXxAlthough Millennium Telefonica and Millennium Telecom have similar names, nothing in the record indicates that they are the same company. (#  x?apparently sent Heartline an order to switch the PIC of Mohammad Farooq, of Glendale,  Xy- x?California, from AT&T, his presubscribed long distance service provider, to Heartline.ylp yO!-  #X\  P6G; IP#ЍXxLetter from Kristal Rasch, Consumer Complaints Analyst for Heartline, to Kathie A. Kneff, Chief, Consumer Protection Branch (Dec. 13, 1995).(#  xHeartline states that it submitted the PIC change to Pacific Bell, apparently on the basis of  xMillennium Telefonica's representation that it had obtained the necessary authorization, and  xFarooq was switched from his preferred carrier to Heartline on July 17, 1995. Upon learning of  xjthe switch, Farooq contacted Heartline on August 18, 1995 and denied authorizing any change  x[to his PIC. In response, Heartline sent to Farooq a copy of the LOA upon which Heartline had",=(=(JJ("  xrelied to request the PIC change. Farooq compared the signature on the LOA, which was dated  x{May 7, 1995, with his signature on his California driver's license, and determined that the  xsignature on the purported LOA was a forgery. On August 28, 1995, Farooq filed his complaint  xwith the Commission, and included a copy of the allegedly forged LOA, a copy of his driver's  xlicense, and copies of his long distance phone bills from both AT&T and Heartline as evidence  X- xto support his allegations.Zp {O-  L#X\  P6G; IP#ЍXxSee Attachment B. Not the least of Farooq's concerns was, for example, the fact that although AT&T only   .charged him $6.02 for a sevenminute call to Pakistan, Heartline charged him $25.26 for virtually the same call, a 319% increase in rates.(#ƃ The Consumer Protection Branch served the complaint on Heartline  Xv-and directed it to satisfy Farooq's complaint or explain why it was unable to do so.vp yO -#X\  P6G; IP#эXxNotice of Informal Complaint, File No. IC9526185 (Sep. 6, 1995).(#Ƣ  XH-C.xJoyce H. Park  X - ` Cx7.` ` In or around July 1995, Tropic Tel, another independent agent of Heartline,  xjapparently sent Heartline an order to switch the PIC of Joyce H. Park, of Northridge, California,  xfrom AT&T, her presubscribed long distance service provider, to Heartline. Heartline states that  xit submitted the PICchange order on the basis of a representation from Tropic Tel that it had  xobtained the necessary authorization to switch Park, and she was switched from her preferred  X - xcarrier on August 1, 1995. zp yO-  #X\  P6G; IP#ЍXxLetter from Kristal Rasch, Consumer Complaints Analyst for Heartline, to Kathie A. Kneff, Chief, Consumer Protection Branch (Sep. 28, 1995) (Park Response).(# Upon learning of the switch, Park contacted Heartline on August  x8, 1995 and denied authorizing any change to her PIC. In response, Heartline sent to Park a copy  Xy- x=of the LOA upon which it had relied to request the PIC change.iyp {O-#X\  P6G; IP#эXxId.(#i Park examined the signature  xon the LOA, which was dated July 13, 1995, and determined that the signature on the purported  xLOA was a forgery. Park filed her complaint, dated August 8, 1995, with the Commission, and  xincluded a copy of the allegedly forged LOA, a copy of her California driver's license, and copies  X- xof her long distance phone bills as evidence to support her allegations.wd p {O2-#X\  P6G; IP#эXxSee Attachment C.(#w The Consumer  x=Protection Branch served the complaint on Heartline and directed it to satisfy Park's complaint  X-or explain why it was unable to do so. p yO!-#X\  P6G; IP#эXxNotice of Informal Complaint, File No. IC9523924 (Sep. 28, 1995).(#ƣ  X-D.xNatalie L. Finley  X- ` ~x8.` ` In or around June 1995, Tropic Tel apparently sent Heartline an order to switch  xMthe PIC of Natalie L. Finley, of La Mesa, California, from Sprint, Finley's presubscribed long  xdistance service provider, to Heartline. Heartline submitted the PIC change to Pacific Bell, which"e ,=(=(JJ1"  xswitched Finley to Heartline on July 6, 1995. Finley contacted Heartline on August 17, 1995 and  xdenied authorizing any change in her PIC. In response, Heartline sent to Finley a copy of the  xlLOA upon which Heartline relied to make the switch. The copy of the LOA provided by  xKHeartline was dated May 8, no year, and bore the name and purported signature of Torlorf Finley,  xwhom Heartline believes to be Finley's husband. Upon comparing the signature on the LOA  xwith Torlorf Finley's Alabama driver's license and Armed Forces ID card, Finley determined that  xthe signature on the LOA was an apparent forgery. On September 18, 1995, Finley mailed her  xcomplaint to the Commission, and included a copy of the allegedly forged LOA and copies of  XH- xTorlorf Finley's driver's license and military ID card as evidence to support her allegations.h ZHp {O -  #X\  P6G; IP#ЍXxSee Attachment D. Finley also forwarded to the Commission copies of a letter sent to her by Heartline and   the Commission's public notice regarding slamming. We are treating these materials as an informal complaint.(#h  xThe Consumer Protection Branch served the complaint on Heartline and directed it to satisfy  X -Finley's complaint or explain why it was unable to do so.! p yO-#X\  P6G; IP#эXxNotice of Informal Complaint, File No. IC9527506 (Sep. 21, 1995).(#ƣ  X -E.xColleen Carranza  X - ` x9.` ` In or around June 1995, Tropic Tel apparently sent Heartline another PICchange  xorder, this time to switch the PIC of Colleen Carranza, of San Diego, California, from her  X- xpresubscribed long distance service provider to Heartline."zp yO-#X\  P6G; IP#эXxIn her complaint, Carranza does not state which presubscribed carrier she previously used.(#ƺ Heartline submitted the PIC change  xto Pacific Bell, which switched Carranza to Heartline on June 27, 1995. Carranza contacted  xHeartline on June 29, 1995 and denied authorizing any change in her PIC. In response, Heartline  xsent to Carranza a copy of the LOA, dated May 15, 1995, upon which Heartline relied to make  x[the switch. Carranza states in her complaint to the Commission, dated August 2, 1995, that the  xsignature on the LOA is not hers. The Consumer Protection Branch served the complaint on  X-Heartline and directed it to satisfy Carranza's complaint or explain why it is unable to do so.# p yO-#X\  P6G; IP#эXxNotice of Informal Complaint, File No. IC9523870 (May 10, 1995).(#Ƣ HIV. HEARTLINE'S RESPONSES  X- ` x 10.` ` In each case, Heartline responded to the Commission's Notice of Informal  xComplaint (NOIC) with what appears to be a form letter that had casespecific information  Xe- xinserted at various points.)$"ep yO$- #X\  P6G; IP#ЍXThe inserted information included names of the complainants; relevant dates, including the date of the  allegedly unauthorized conversion; names of the marketing agents involved; and summaries of contacts or  Lcorrespondence between Heartline and the complainants prior to service by the Commission of the informal  {O'-complaint. See supra notes 18, 25, 28, 33, and 35.(#) In each of these letters, Heartline states that it used a marketing agent"e $,=(=(JJ"  x]to obtain the LOAs that it relied upon to switch the complainants' long distance service.  xHeartline explains in each case that the marketing agents solicited new customers by using an  xLOA that was combined with a sweepstakes entry form that asked for the entrant's name,  X- xaddress, telephone number, and signature.%"p yO4-  #X\  P6G; IP#ЍXxHeartline states that these LOA forms complied with the Commission's rules that were in effect at the time   the forms were in use. Heartline further states that it no longer accepts such LOA forms in light of the fact  {O-   that the Commission's rules governing LOA forms have since changed. See supra para. 3 and notes 18, 25, 28, 33, and 35.(# Further, Heartline uniformly states that it has  xrefunded usage charges billed to the complainants in excess of the rates charged by each  x.complainant's preferred long distance carrier, that the LEC has refunded charges for switching  Xv- xlong distance carrirers, and that the complainants, except Farooq,W&vp yO -  k#X\  P6G; IP#ЍXxHeartline states without elaboration that it did not have enough information to switch Farooq back to his  {O -preferred carrier and that he would have to contact the carrier directly. See supra note 25.(#W have been switched back to  xKtheir carriers of choice. Heartline, however, neither denies that the signatures do not match those  xprovided by the complainants nor disputes the complainants' allegations that the signatures on the LOAs are forgeries. 'V. DISCUSSIONTP  X - ` x 11.` ` We have evaluated the information obtained as a result of the staff's investigation  xand based on the foregoing, we conclude that Heartline has apparently willfully or repeatedly  xviolated the Commission's rules and orders regarding PICchange requirements. We find  xHeartline's actions particularly egregious. It appears that Heartline submitted PICchange requests  xto various LECs based on apparently forged or falsified LOAs from a variety of its sales agents  xthat resulted in the unauthorized conversion of these five complainants' long distance telephone  xjservice from the complainants' preferred long distance carrier to Heartline. The statements and  x/information provided by the complainants leave virtually no doubt that the LOAs were not  x[executed by the complainants and that Heartline lacked the requisite authorization to request a  xPIC change to their long distance service. In addition to the apparent forged signatures, we note  xMthat three of the LOAs contain other discrepancies. Best's street address is misspelled and  x/Carranza's address is completely incorrect. Moreover, Farooq's name is misspelled and the  xsignature on the LOA is his full name, while his signature on his letter and his California drivers license is a stylized version of his last name only.  Xe- ` x 12.` ` Heartline has provided no evidence or information to counter the complainants'  xclaims that the LOAs were forged or their claims that they did not otherwise authorize the PIC  xchanges. There is little similarity between the signatures provided by the complainants and their  xpurported signatures on the LOAs. In any event, Heartline has not contested any of the claims  xthat the signatures on the LOAs do not match those provided by the complainants. Under these  xcircumstances, we conclude that Heartline's apparent actions were in willful or repeated violation" &,=(=(JJ"  xzof the Commission's PICchange rules and orders and that a substantial forfeiture penalty is appropriate.  X- ` }x 13.` ` We also note that with regard to PIC changes, the actions of Heartline's marketing  x-agents do not relieve Heartline of its independent obligation to ensure compliance with our rules,  xnor do they otherwise mitigate Heartline's role in the apparent violations. The Communications  x.Act deems the acts or omissions of an agent or other person acting for a common carrier to be  X_- xthe acts or omissions of the carrier itself.}'_p yO-#X\  P6G; IP#ЍXx47 U.S.C.  217.(#} Hence, the Act expressly prohibits a carrier from  xevading the requirements of the Act or the Commission's rules or orders by hiring someone else to engage in conduct that contravenes these requirements.  X - ` x 14.` ` As a general matter, the unauthorized conversion of a customer's presubscribed  X - xZlong distance carrier continues to be a widespread problem in the industry.-( Xp yO-  .#X\  P6G; IP#ЍXxFrom September 1994 to September 1995, of the 32,598 informal complaints filed, 10,544 were for alleged unauthorized conversions of the customer's presubscribed long distance carrier.(#- We are particularly  xtroubled by what appears to be a common practice by some IXCs of relying on unverified LOAs,  x.which turn out to be falsified or forged, to effect changes in consumers' long distance service.  xThe pervasiveness of the problem suggests that our current administration of the law has not  xyproduced sufficient deterrence to noncompliance and the carriers have little incentive to curtail  xpractices that lead to consumer complaints. Furthermore, as a practical matter, the carriers'  x<responses to alleged unauthorized conversion complaints rarely provide a detailed explanation or  xjustifications of the carriers' actions. Therefore, to draw the industry's attention to the  xseriousness of the problem and to provide incentives to comply with the Commission's rules and  xorders, we intend to scrutinize consumer complaints and to take prompt enforcement action,  xincluding the imposition of substantial monetary fines, when the facts indicate that a carrier has  xfailed to take the necessary steps to ensure that LOAs are valid and duly authorized. If carriers  xintend to rely on a LOA to request a PIC change, they will be responsible for ensuring its validity.  X- ` Qx15.` ` Section 503(b)(2)(B) of the Communications Act authorizes the Commission to  xLassess a forfeiture of up to one hundred thousand dollars ($100,000) for each violation or each  xday of a continuing violation up to a statutory maximum of one million dollars ($1,000,000) for  XN- xa single act or failure to act.)Np yO!-#X\  P6G; IP#ЍXx47 U.S.C.  503(b)(2)(B).(#ƌ In exercising such authority, the Commission is required to take  xinto account "the nature, circumstances, extent, and gravity of the violation and, with respect to  x<the violator, the degree of culpability, any history of prior offenses, ability to pay, and such other  X - xmatters as justice may require."* @p yO%-#X\  P6G; IP#ЍXx47 U.S.C.  503(b)(2)(D).(#ƌ For purposes of determining an appropriate forfeiture penalty  X- x<in this case, we regard the conversion of  each of the five complainants' telephone line as a single,"*,=(=(JJZ"  x=separate violation. After weighing the circumstances surrounding each violation, we find that  xHeartline is apparently liable for a forfeiture of forty thousand dollars ($40,000) for the  x=unauthorized conversion of each of the five complainants' long distance service, resulting in a  xLtotal forfeiture of two hundred thousand dollars ($200,000). Heartline will have an opportunity  xto submit evidence and arguments in response to this NAL to show that no forfeiture should be  X- x/imposed or that some lesser amount should be assessed.+p {O-#X\  P6G; IP#эXxSee 47 U.S.C.  503(b)(4)(C); 47 C.F.R.  1.80(f)(3).(#ơ In this regard, we note that the  xCommission has previously held that a licensee's gross revenues are the best indicator of its  x[ability to pay a forfeiture and that use of gross revenues to determine a party's ability to pay is  xZreasonable, appropriate, and a useful yardstick in helping analyze a company's financial condition  X1- xfinancial condition for forfeiture purposes.U, 1Zp yO< -  #X\  P6G; IP#ЍXxPJB Communications of Virginia, 7 FCC Rcd 2088, 2089 (1992) (finding that forfeitures of $5,000 and   \$3,000 assessed against two jointly owned and operated paging companies were not excessive because the   .total forfeiture amount ($8,000) represented approximately 2.02 percent of the companies' combined gross  {O-  revenues of $395,469); see also David L. Hollingsworth d/b/a Worland Services, 7 FCC Rcd 6640 (Com.   Car. Bur. 1992) ($6,000 forfeiture representing approximately 1.21 percent of licensee's 1991 gross revenues   and approximately 1.34 percent of projected 1992 gross revenues not found to be excessive); Afton   Communications Corp., 7 FCC Rcd 6741 (Com. Car. Bur. 1992) ($6,000 forfeiture representing   approximately 3.91 percent of 1990 gross revenues and 2.75 percent of projected 1992 gross revenues not found to be excessive).(#U We will give full consideration to any financial information provided by Heartline before assessing a final forfeiture amount. x xk VI. CONCLUSIONS AND ORDERING CLAUSES  X - ` x16.` ` We have carefully reviewed the information obtained through our investigation and  xconclude that during the period of June, July, and August, 1995, Heartline apparently converted  xor caused a local exchange carrier to convert the five complainants' telephone lines without their  xzauthorization. We further conclude that Heartline thereby apparently willfully or repeatedly  xviolated Commission rules governing primary interexchange carrier conversions, and that its  X4-conduct warrants a forfeiture in the amount of   two hundred thousand dollars ($ 200,000).  X- ` $x17.` ` Accordingly, IT IS ORDERED, pursuant to Section 503(b) of Communications  x Act of 1934, as amended, 47 U.S.C.  503(b), and Section 1.80 of the Commission's rules, 47  xC.F.R.  1.80, that Heartline Communications, Inc., IS HEREBY NOTIFIED of an Apparent  X- xLiability for Forfeiture in the amount of two hundred thousand dollars ($ 200,000) for its willful  X- xor repeated violation of the Commission's PICchange rules and orders, 47 C.F.R.  64.1100; PIC  X- x{Change Order, 7 FCC Rcd 1038 (1992); Allocation Order, 101 FCC 2d 911 (1985); Waiver  X-Order, 101 FCC 2d 935 (1985).  XT- ` x18.` ` IT IS FURTHER ORDERED, pursuant to Section 1.80 of the Commission's rules,  x47 C.F.R.  1.80, that within thirty days of the   release of this NAL, Heartline SHALL PAY the"= , ,,=(=(JJ{"  X- xfull amount of the proposed forfeiture2- p yOy-  #X\  P6G; IP#ЍXxThe forfeiture amount must be paid by check or money order drawn to the order of the Federal   ^Communications Commission. Reference should be made on Heartline's check or money order to   "NAL/Acct. No. 516EF0007." Such remittances must be mailed to Forfeiture Collection Section, Finance  yO-Branch, Federal Communications Commission, P.O. Box. 73482, Chicago, Illinois 606737482. (#2 OR SHALL FILE a response showing why the proposed forfeiture should not be imposed or should be reduced.  X- ` Cx19.` ` IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability  xSHALL BE SENT by certified mail to Joseph R. Harrott, Heartline Communications, Inc., P.O. Box 53029, Houston, Texas 770523029. X` hp x (#%'0*,.8135@8: