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Box &Number &Rotate...CancelF2M X- X   N X-w  Federal Communications Commission`)(# DA 972584 ă  yxdddy vK#X\  P6G;IP# Before the Federal Communications Commission  yO}"Washington, D.C. 20554 ă  XA-#Xj\  P6G; XP#In the Matter of hh,V)  X*-Liability of` `  hh,V) ` `  hh,V)  X-RAMAR COMMUNICATIONS, INC.V) ` `  hh,V)  X-Licensee of Television Stationhh,V)  X-KJTV(TV), Lubbock, Texashh,V) ` `  hh,V)  X -for a Forfeiture hh,V)  XD -  MEMORANDUM OPINION AND ORDER lU  X-X` hp x (#%'0*,.8135@8:27, 1994. The forfeiture was assessed for apparent willful and repeated violation of Section   73.670 of the Commission's Rules, 47 C.F.R. 73.670, which limits the amount of commercial matter that may be aired during children's programming.  2. On April 1, 1993, Ramar filed an application for renewal of license for KJTV(TV), File   No. BRCT930401KR. In response to Question 9(b) of that application, KJTV(TV) stated that   it had not complied with the limits on commercial matter in children's programming. In   kaccordance with Question 9(c), KJTV(TV) submitted Exhibit 5 to its application, listing each   segment of children's programming which exceeded the commercial limits. Exhibit 5 revealed   that between February 12 and August 20, 1992, KJTV(TV) exceeded the commercial limits on   children's television on 6 occasions. Of these 6 commercial overages, two were 30 seconds in   .duration, one was 15 seconds in duration, and three were programlength commercials. Ramar   stated that all six overages were inadvertent and resulted from human error; and that, in order to   prevent recurrence of these commercial overages the station "instituted a series of procedures and crosschecks, including screening of content and review of spot scheduling instructions...." "%X,))ZZ$"Ԍ   3. Ramar also stated that a 30second overage on July 16, 1992, occurred because the   ^station was off the air for 50 minutes between 3:00 p.m. and 3:50 p.m. due to technical   difficulties; and that the children's programming broadcast between 3:50 p.m. and 4:30 p.m., a   period of 40 minutes, contained eight minutes of commercial matter. Ramar asserted that,   although this figure complies with the Commission's 12 minutes per hour commercial limit on   children's weekday programming when prorated for the 40 minutes of children's programming   actually broadcast, the discrete halfhour children's program broadcast between 4:00 p.m. and   4:30 p.m. contained six minutes and 30 seconds of commercial matter, which, if considered as   an isolated halfhour children's program, would exceed the prorated commercial limit of six   minutes per halfhour. Ramar argued that, in view of the "extraordinary circumstance" of the   [shutdown due to technical difficulties, the 40minute period of children's programming should   =be "treat[ed]...as a single block of time" which was in compliance with the children's television   ycommercial limits when the amount of commercial matter contained in the 40minute time period   /is prorated according to the perhour limit. Finally, with regard to one of the three reported   [programlength commercials, Ramar stated that, during a broadcast of the program "Tale Spin"   on July 22, 1992, the station aired a commercial advertisement for a Kelloggs breakfast cereal   "in which, at the end of the commercial, certain Tale Spin characters briefly appeared and Tale   [S]pin figurines were offered as a giveaway"; that the appearance of the Tale Spin characters   L"was extremely brief (approximately 3 seconds), and the figurine giveaway offer was also quite brief (approximately 6 seconds)."  X- O4. In Ramar NAL, supra, the Chief of the Mass Media Bureau, pursuant to delegated  X-  authority, considered factors discussed in Policy Statement Standards for Assessing Forfeitures,  X-  8 FCC Rcd 6215 (1993)("Policy Statement/Assessing Forfeitures"),* ,[ yOh-  ԍ These factors include the number and duration of commercial overages, the period of time over which the   overages occurred, and whether the licensee had established an effective program to ensure compliance with the  yO-  ichildren's television commercial limitations. See, e.g., KEVN, Inc. (KEVNTV and KIVVTV), 8 FCC Rcd 5077,  yO-5078 (1993); Mountain States Broadcasting, Inc. (KMSBTV), 9 FCC Rcd 2545 (1994).* and determined that a   forfeiture in the amount of $10,000 was appropriate for the six commercial overages, including  X-  the three programlength commercials, reported in KJTV(TV)'s renewal application. Ramar  X-NAL, supra 9 FCC Rcd at 1831.  X|- 5. Ramar's Response to the NAL. With regard to the 30second overage which occurred   jon July 16, 1992, because KJTV(TV) went off the air for 50 minutes due to technical difficulties,   Ramar states that the "extraordinary" circumstances surrounding that overage were described in   its renewal application; and that broadcasters should be allowed "to adapt to the exigencies of a  X -  Kparticular broadcast day, without adverse regulatory consequences." Ramar also asserts that the  X -  Tale Spin program treated as a programlength commercial in Ramar NAL, supra, did not come   [within the Commission's definition of programlength commercial. In addition, Ramar reasserts  X-  that all three incidents of programlength commercials cited in Ramar NAL were inadvertent, and   that the station had taken steps to prevent their recurrence. Further, Ramar argues that its   >violations were "far less egregious" than those for which the Commission imposed only an"!,-(-(ZZ "   admonition in another case. Finally, Ramar states that the Commission established certain   ]"upward and downward adjustment criteria" for determining the amount of forfeitures in  X-  .Forfeiture Policy Statement, supra; and argues that, although "several" downward adjustment  X-criteria are applicable, they were not mentioned in Ramar NAL, supra.  X-8NDiscussionă  X_- 6. Assessed Forfeiture Amount. Before we address Ramar's arguments concerning   particular children's television commercial overages on KJTV(TV), we shall address its assertion  X1-  jthat the aggregate violations for which a $10,000 forfeiture was assessed in Ramar NAL, supra,   jwere "far less egregious" than those for which the Commission imposed only an admonition in  X -  another case. Ramar cites Idaho Independent Television, Inc. (KTRV(TV)), (Chief, Video   Services Division Letter 1800E1LJ, dated March 28, 1994), in which the Commission   .admonished that licensee for a total of six commercial overages, including one programlength   commercial, one overage of 150 seconds in duration, two overages of 90 seconds in duration and   two overages of 30 seconds in duration. Ramar asserts that overages of 30 seconds or more are  X-  considered "serious", citing R&R Media Corporation (WTWS(TV)), 9 FCC Rcd 1715 (1994); and  Xy-  \that a forfeiture was imposed in Ramar NAL, supra, for "only two overages" (one "serious"   overage of 30 seconds and one "negligible" overage of 15 seconds) and two programlength  XK-  {commercials, "as compared with the five overages (all serious) and one program[]length  X4-  commercial" for which only an admonition was imposed in KTRV(TV), supra. Ramar concludes  X-  that the "only possible distinction" between its situation and that in KTRV(TV), supra, is   KJTV(TV) "broadcast two program[] length commercials rather than one..."; that this alleged   jsole distinction is "more than offset" by the "fact" that KTRV(TV)'s commercial overages were  X-  x"so much more numerous and egregious" than KJTV(TV)'s; that, pursuant to Melody Music , Inc.  X-  v. F.C.C., 345 F.2d 730 (D.C. Cir. 1965), the Commission is required to accord similar treatment  X-  to parties that are similarly situated; and that, therefore, Ramar NAL, supra, should be rescinded and replaced with, at most, a letter of admonition.  #HR   7. Initially we note that Ramar's Response misstates the number of overages upon which  XN-  the $10,000 forfeiture was based in Ramar NAL, supra. As clearly stated in Ramar NAL, id. 9   lFCC Rcd at 1831, the forfeiture was assessed because KJTV(TV) exceeded the children's  X -  television commercial limits "on six occasions, including three programlength commercials."  X -  Thus, Ramar is in error in asserting that the violations in KTRV(TV), supra, were "much more numerous" than those for which the forfeiture was assessed in the instant case.  l8. Further, Ramar's Response misconceives the seriousness with which the Commission   consistently has considered and treated programlength commercials. When the Commission   ladopted its children's television commercial rules and policies pursuant to the Children's  X#-  Television Act of 1990,#,[ yO%-ԍ Pub. L. No. 101437, 104 Stat. 9961000, codified at 47 U.S.C. Sections 303a, 303b and 394. the Commission specifically provided that, where a program is  Xh$-  \determined to be a programlength commercial, the entire program "would count toward the"h$X,-(-(ZZF#"  X-  statutory commercial limits."o,[ yOy-ԍ Children's Television Programming, 6 FCC Rcd 2111, 2118 (1991).o Finally, the Commission has made it abundantly clear that,   .independent of their duration, programlength commercials, by their very nature, are extremely  X-  serious. In Children's Television Programming, id. 6 FCC Rcd at 2118, the Commission stated  X-  that its programlength commercial policy "directly addresses a fundamental regulatory concern,   lthat children who have difficulty enough distinguishing program content from unrelated   commercial matter, not be all the more confused by a show that interweaves program content   and commercial matter." (Emphasis added.) Accordingly, in numerous cases assessing forfeitures for violations of the children's television commercial limits, the Commission has stated that   AXX` ` Congress was particularly concerned about programlength commercials because   young children often have difficulty distinguishing between commercials and   programs. S. Rep. No. 227, 101st Cong., 1st Sess. 24 (1989). Overages of this   nature and magnitude mean that children have been subjected to commercial   matter greatly in excess of the limits contemplated by Congress when it enacted  X -  the Children's Television Act of 1990. Children's Television Programming, supra 6 FCC Rcd at 211718.(#`  Xy-  Le Sea Broadcasting Corp. (WHKE(TV)), 10 FCC Rcd 4977, 4978 (1995); Buffalo Management  Xb-  Enterprises Corp. (WIVBTV), 10 FCC Rcd 4959, 4960 (1995); Act III Broadcasting License  XK-Corp. (WUTV(TV)), 10 FCC Rcd 4957, 4958 (1995).  9. In accordance with this policy of treating programlength commercials as extremely   serious violations of the children's television commercial limitations, the Commission has   routinely assessed higher forfeitures for programlength commercials than for a significantly  X-  jgreater number of conventional overages. Thus, in Channel 12 of Beaumont, Inc. (KBMTTV),  X-  9 FCC Rcd 1825 (1994), and Mt. Mansfield Television, Inc. (WCAXTV), 10 FCC Rcd 8797   (1995), forfeitures of $10,000 were assessed for totals of 40 and 30 overages, respectively, of  X-  which none were programlength commercials. In contrast, in Gannett Massachusetts  X|-  Broadcasting, Inc. (WLVITV), 9 FCC Rcd 1555 (1994), a forfeiture of $10,000 was assessed   <for a total of seven overages, three of which were 60, 30 and 28 seconds in duration, respectively,  XN-  jand four of which were programlength commercials; in WUTV(TV), supra 10 FCC Rcd at 4957  58, a forfeiture of $10,000 was assessed for a total of eight overages, one of which was 30   lseconds in duration, three of which were 15 seconds in duration, and four of which were  X -  [programlength commercials; and in Quad Cities Television (KLJBTV), 9 FCC Rcd 1711 (1994),   a forfeiture of $10,000 was assessed for a total of three overages, all which were programlength   commercials. The forfeiture amounts for the number and type of children's television commercial  X -  limit violations specified in the latter four cases are generally consistent with those in Ramar  X!-  NAL, supra. Accordingly, Ramar's assertion that, pursuant to Melody Music , Inc. v. F.C.C.,  X"-  supra, the forfeiture assessed in Ramar NAL, supra, should be rescinded and replaced with a letter of admonition, is without merit and shall be denied. "h$X,-(-(ZZF#"Ԍ X- 10. Technical Difficulties. In establishing rules and policies limiting the amount of   commercial matter which may be aired during children's programming, the Commission   specifically recognized that licensees may experience "occasional emergency scheduling   Zchange[s]", and stated that such emergency schedule changes would be taken into consideration   in determining whether "extenuating circumstances" mitigated any resulting children's television  X-  Mcommercial limit violations.w,[ yO-ԍ Children's Television Programming, supra 6 FCC Rcd at 2126 n.123.w Upon reconsideration, the Commission, inter alia, affirmed this   policy, stating that "where the facts demonstrate that a slight overage is caused by a lastminute   Memergency scheduling change, we will consider such a lapse to be 'de minimis.'" (Footnote  XH-omitted.)yHX,[ yOQ -ԍ Children's Television Programming (Recon.), 6 FCC Rcd 5093, 5096 (1991). y   X - |11. Upon reexamination of Ramar NAL, supra, we believe that the 30second overage   which occurred because the station was off the air due to technical difficulties for 50 minutes on   KJuly 16, 1992, resulted from the kind of "lastminute emergency scheduling change" which should   have been considered to be an "extenuating circumstance" with regard to the resulting violation   of the children's television commercial limits. Accordingly, that 30second overage shall not be considered in determining the amount of any forfeiture.  Xy- 12. ProgramLength Commercials. In its Response, Ramar asserts that Ramar NAL,  Xb-  supra, "improperly characterized" a "brief threesecond appearance of a Tail [sic] Spin character   at the end of a Kelloggs cereal commercial" as a programlength commercial; that this did not   come within the Commission's definition of programlength commercial because the product  X-  being advertised was "a brand of Kelloggs cereal", and "no Tail [sic] Spin products were being   offered for sale or advertised"; that the appearance of the Tale Spin characters in that Kelloggs   /cereal commercial "[a]t most,...constituted 'host selling'"; and that host selling "is to be the  X-  subject of admonitions, not forfeitures", citing Children's Television Programming, id. 6 FCC Rcd   >at 2127 n.147 (1991). However, these assertions misstate the record with regard to both the   description of the commercial advertisement contained in KJTV(TV)'s renewal application and  X-the discussion of that advertisement in Ramar NAL, supra.  Xe- 13. Exhibit 5 to KJTV(TV)'s renewal application clearly states that, in addition to the  XN-  =appearance of "certain Tale Spin characters" in the cereal commercial in question, "Tale [S]pin  X7-  figurines were offered as a giveaway." (Emphasis added.) As noted in Ramar's Response, in  X -  Children's Television Programming, supra 6 FCC Rcd at 2117, a programlength commercial is   Kdefined as "a program associated with a product in which commercials for that product are aired."  X-  KThe "Tale [S]pin figurines" offered during the cereal commercial in question are products "related  X-  to" the Tale Spin Program. Therefore, Ramar NAL, supra, included the Tale Spin program in   question among KJTV(TV)'s programlength commercial violations specifically because "a  X!-  commercial for Kelloggs cereal aired during...[that] show contained a giveaway promotion for  X"-Tail [sic] Spin characters." (Emphasis added.) Id., 9 FCC Rcd at 1831."",-(-(ZZ!"Ԍ ԙ14. The Commission has repeatedly held that, where a commercial announcement is   =primarily for a product otherwise unrelated to a program, but that announcement also includes  X-  Lreferences to or offers of products which are related to the program, than the broadcast of that   commercial announcement during the program to which the included products relate will render  X-  that program a programlength commercial.[X,[ yO-  ԍ See, e.g., Scripps Howard Bcstng Co. (KNXVTV), 9 FCC Rcd 2547 (1994)(inter alia, "a commercial for   Kelloggs Frosted Flakes that contained an offer for a free character from the show 'Ducktails' w[as] aired during the 'Ducktails' show").[ Indeed, the Commission has specifically ruled that   this principle applies to "Tale Spin" programs containing Kelloggs cereal advertisements which  Xv-  include offers of "Tale Spin" character figurines.v,[ yO -  ԍ Max Television of Syracuse, L.P. (WSYT(TV)), 10 FCC Rcd 8905 (1995); KLJBTV, supra 9 FCC Rcd at 1711. Accordingly, Ramar NAL, supra, correctly   includes the Tale Spin program in question among KJTV(TV)'s programlength commercial  XH-violations. H@,[ yO9-  [ԍ Ramar's Response is partially correct, to the extent that it asserts that the appearance by the Tale Spin   characters (as opposed to the offer of Tale Spin figurines) in the Kelloggs cereal commercial constituted "host yO-  yselling", which merited an admonition for violating the Commission's policy against that practice. Children's  yO-Television Programming, id. 6 FCC Rcd at 2127 n.147 (1991).  15. In addition to its arguments concerning the Tale Spin programlength commercial,  X -  Ramar's Response reasserts that all three incidents of programlength commercials cited in Ramar  X -  iNAL were inadvertent, and that the station had taken steps to prevent their recurrence. However,   the Commission has repeatedly held that inadvertence and/or lack of intention to violate the  X -  children's television commercial limits do not excuse such violations. X ( ,[ yO-  Jԍ See, e.g., UTV of San Francisco, Inc. (KBHKTV), 10 FCC Rcd 10986, 10987 & note 1 (1995); WHKE(TV),  yO_-  supra 10 FCC Rcd at 4978; WIVBTV, supra 10 FCC Rcd at 4960; WUTV(TV), supra 10 FCC Rcd at 4958; WLVI yO'-TV, supra 9 FCC Rcd at 1555. Further, the Commission   has repeatedly held that the fact that a licensee may have instituted a plan to eliminate future  X-  overages does not relieve that licensee of liability for prior violations. H ,[ yO-  iԍ See International Broadcasting Corp., 19 FCC 2d 793 (1969). See also, e.g., KBHKTV, supra 10 FCC Rcd  yOQ-  at 10988; WCAXTV, supra 10 FCC Rcd at 8798; WHP Television, L.P., 10 FCC Rcd 4979, 4980 (1995);  yO-  <WHKE(TV), supra 10 FCC Rcd at 4978;   WIVBTV, supra 10 FCC Rcd at 4960; WUTV(TV), supra 10 FCC Rcd  yO-  at 4958; KMSBTV, supra 9 FCC Rcd at 2546; KJTLTV, supra 9 FCC Rcd at 1830; KEVNTV and KIVVTV,  yO -supra 8 FCC Rcd at 5078. In view of the foregoing,   any forfeiture or other sanction imposed for the children's television commercial limit violations   =reported in KJTV(TV)'s renewal application should be based on a total of five violations: three programlength commercials, one overage of 30 seconds, and one overage of 15 seconds.  X- 16. Adjustment Criteria. Ramar states that in Policy Statement/Assessing Forfeitures,  X-  supra, the Commission established certain "upward and downward adjustment criteria" for   <determining the amount of forfeitures; and argues that, although "several" downward adjustment" ,-(-(ZZ"  X-  criteria are applicable in the instant case, they were not mentioned in Ramar NAL, supra. In this   regard, Ramar asserts that all of its violations were disclosed in its renewal application   L"voluntarily...[and] in good faith"; that its violations were "isolated and 'minor' in nature"; and that its "history of overall compliance" was such that the fine should be further reduced.  X- 17. In United States Telephone Ass'n. v. FCC, 28 F3rd 1232 (D.C. Cir. 1994), the U.S.  Xv-  Court of Appeals for the District of Columbia set aside Policy Statement/Assessing Forfeitures,  X_-  supra, stating that the guidelines for assessing forfeitures established therein must be subject to   public comment to comply with the Administrative Procedure Act. In accordance with the  X1-  court's decision, the Commission released Forfeiture Guidelines Notice of Proposed Rulemaking  X -  in CI Docket No. 956, 10 FCC Rcd 2945 (1995). After receiving and considering comments   from the public in that proceeding, the Commission adopted guidelines for assessing forfeitures.  X -  Forfeiture Guidelines Report and Order in CI Docket No. 956,   FCC Rcd  (FCC 97218,  X -  adopted June 19, 1997, released July 28, 1997)("Forfeiture Guidelines"). Forfeiture Guidelines,  X -  id., became effective on October 14, 1997. 62 Fed. Reg. 43474 (August 14, 1997). However,  X -  with regard to (i) all cases pending when Forfeiture Guidelines, supra, was adopted, and (ii) all   cases involving "violations arising from facts that occurred before the effective date of th[at]   order", forfeiture amounts are to be assessed "under the casebycase approach in effect when the   _violation occurred", in conformity with the standards set out in Section 503 of the  XK-Communications Act. Id. at 49.  X- 118. In Ramar NAL, supra 9 FCC Rcd at 1831, the Commission specifically recognized  X-  [that a petition for review of Policy Statement/Assessing Forfeitures, supra, was pending in the  X-  \court of appeals. As stated in footnote 2, supra, in determining the forfeiture amount in the   instant case the Commission considered the number and duration of commercial overages at   .KJTV(TV), the period of time over which the overages occurred, and whether the licensee had   established an effective program to ensure compliance with the children's television commercial  X-  limits. Id., 8 FCC Rcd at 5082. These criteria, which were developed and applied by the  X|-  NCommission in previous cases, |,[ yO-  ԍ See, e.g., Koplar Communications, 8 FCC Rcd 7884 (1993); Independent Communications, Inc., 8 FCC Rcd  yO-7886 (1993); KXRM Partnership, 8 FCC Rcd 7890 (1993). are appropriate in analyzing violations of the children's  Xe-  ytelevision commercial limits, since they take into account, inter alia, "the nature, circumstances,   jextent, and gravity of the violation, and, with respect to the violator, the degree of culpability",  X7-  .as required under 503(b)(2)(D) of the Communications Act. 7 ,[ yO!-  Kԍ See, e.g., Clear Channel Television, Inc. (KTTU(TV)), 10 FCC Rcd 3773 (1995); Northstar Television of  yO!-Erie, Inc. (WSEETV), 10 FCC Rcd 3779 (1995). Thus, as specified in Forfeiture  X -  Guidelines, supra at 49, the forfeiture amount in the instant case was determined in accordance   with the criteria developed and applied by the Commission in previous cases, in conformity with the standards established in Section 503 of the Communications Act.  X - ]19. Voluntary Disclosure. Initially we note that in the Children's Television Act of 1990,   Congress not only required the establishment of limits on the amount of commercial matter that"!x ,-(-(ZZ "   may be included in children's television programming, but also directed that "the Commission   [shall, in its review of any application for renewal of a commercial...television broadcast license,  X-  xconsider the extent to which the licensee...has complied with such standards...."A,[ yOK-ԍ 47 U.S.C. Section 303b.A Pursuant to this   Congressional mandate, the Commission added a supplement to FCC Form 303S, Application   for Renewal of License, directing the applicant to (i) state whether or not it had complied with   the children's television commercial limits; and (ii) if it had not so complied, submit an exhibit  Xv-  to the renewal application listing "each segment of programming, 5 minutes or more in duration,   zdesigned for children 12 years old and under and broadcast during the license period which   ycontained commercial matter in excess of the limits" (emphasis added), including "the length of   the segment, the amount of commercial matter contained therein, and an explanation of why the   \limits were exceeded." Supplement to FCC Form 303S, Application for Renewal of License,   jQuestion 9(b) and (c). Section 73.3514 of the Commission's Rules, 47 C.F.R. 73.3514, provides   that "[e]ach application shall include all information called for by the particular form on which   the application is required to be filed...." Section 1.17 of the Commission's Rules, 47 C.F.R.   y1.17, provides that "[n]o licensee, permittee or applicant shall...in any application ... submitted   [to the Commission, make any material misrepresentation or willful material omission bearing on any matter within the jurisdiction of the Commission."  20. Failure to provide the information called for in the renewal application, or providing   incomplete or incorrect information, could have resulted in an additional forfeiture against Ramar  X4-  for violation of Section 1.17 of the Rules. Cf., David A. Ringer, 8 FCC Rcd 7037 (1993).   Further, failure to disclose the occurrence of violations of the children's television commercial   limitations in response to the questions in the renewal application, or providing incomplete or   incorrect information, could constitute a misrepresentation or lack of candor by the applicant,   which would raise a serious question as to whether the applicant possesses the character  X-  {qualifications to be a Commission licensee. Policy Regarding Character Qualifications in  X-  Broadcast Licensing, 102 FCC 2d 1179, 121011, recon. 1 FCC Rcd 421, 422 (1986)("Character  X-  Qualifications"), appeal dismissed sub nom. National Association for Better Broadcasting v.  X|-F.C.C., No. 861179 (D.C. Cir. June 11, 1987).  21. Finally, the history of overall compliance by the licensee of Commission Rules and policies is not such as to justify forfeiture reduction.  X -&MConclusionă  22. Accordingly, IT IS ORDERED THAT the Response to Notice of Apparent Liability  X -  filed by Ramar Communications, Inc., requesting that the forfeiture assessed in Ramar  X!-  "Communications, Inc., supra, be reduced or eliminated, IS DENIED. IT IS FURTHER   ORDERED THAT, pursuant to Section 503(b) of the Communications Act of 1934, as amended,   47 U.S.C. 503(b), Ramar Communications, Inc., licensee of Television Station KJTV(TV),   Lubbock, Texas, FORFEIT to the United States the sum of ten thousand dollars ($10,000) for"h$X,-(-(ZZF#"   repeated violations of Section 73.670 of the Commission's Rules, 47 C.F.R. 73.670. Payment   {of the forfeiture may be made by mailing to the Commission a check or similar instrument   payable to the Federal Communications Commission. With regard to this forfeiture proceeding,   ?Ramar Communications, Inc., may take any of the actions set forth in Section 1.80 of the   >Commission's Rules, 47 C.F.R. 1.80, as summarized in the attachment to this Memorandum Opinion and Order. ` `  hh,VFEDERAL COMMUNICATIONS COMMISSION ` `  hh,VRoy J. Stewart ` `  hh,VChief, Mass Media Bureau " ,-(-(ZZ"  X- kkjtvrd3.rel  ?<#n6X@`7Fc&@##x6X@`7>fX@#  }:< #n6X@`7Fc&@#$// RAMAR COMMS, INC., KJTV(TV) (LUBBOCK, TX) DA 972584 //$ $/ 300.503(b) FORFEITURES (FORFEITURE ORDER) /$ $/ 73.670 COMMERCIAL LIMITS ON CHILDREN'S PROGRAMS /$  ? < #x6X@`7>fX@#