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                           Before the
                Federal Communications Commission
                     Washington, D.C. 20554


CERTIFIED MAIL #7001 0320 0002 9838 7776
RETURN RECEIPT REQUESTED


Trade Center Management, Inc.   )       File Number EB-02-HL-073
Licensee of AM Station KHRA     )       NAL/Acct.             No. 
200332860001
Honolulu, Hawaii                )       FRN 0006351688


           NOTICE OF APPARENT LIABILITY FOR FORFEITURE

                                            Released: October 31, 
                                                             2002

By the Enforcement Bureau, Honolulu Resident Agent Office:

                        I.  INTRODUCTION

     1.   In this  Notice of  Apparent Liability  for  Forfeiture 
("NAL"), we find that Trade Center Management, Inc., licensee  of 
AM broadcast  station KHRA  in Honolulu,  Hawaii, has  apparently 
willfully and  repeatedly  violated  Section  73.3526(b)  of  the 
Federal Communications Commission (``FCC'') Rules and Regulations 
(``Rules''),1 by failing to maintain a public inspection file  at 
the station main studio.  We conclude, pursuant to Section 503(b) 
of the Communications  Act of 1934,  as amended (``Act''),2  that 
Trade  Center  Management,  Inc.,  is  apparently  liable  for  a 
forfeiture in the amount of ten thousand dollars ($10,000).

                         II.  BACKGROUND

     2.   On August 2, 2002, agents of the FCC Honolulu  Resident 
Agent Office inspected the KHRA main studio, located at 320  Ward 
Ave.,  Suite  211,  Honolulu,   Hawaii.   There  was  no   public 
inspection file available at the time of inspection.  At the time 
of the inspection, Mr. Ki-Yeoun  Kim, who represented himself  as 
the General  Manager  of  the station,  advised  that  no  public 
inspection file was maintained at the KHRA main studio. 

     3.   On August 12, 2002, a Notice of Violation was issued to 
Trade Center Management Center, Inc., for failure to comply  with 
Section  73.3526(b)  of  the  Rules.   The  Notice  of  Violation 
required a response within fourteen days of the release date.  No 
response has been received to date.
                        III.  DISCUSSION

     4.   Section 503(b) of the Act provides that any person  who 
willfully or repeatedly  fails to comply  substantially with  the 
terms and conditions of any  license, or willfully or  repeatedly 
fails to comply with any of the  provisions of the Act or of  any 
rule, regulation or  order issued by  the Commission  thereunder, 
shall be liable for a  forfeiture penalty.  The term  ``willful'' 
as used in  Section 503(b)  has been interpreted  to mean  simply 
that the acts  or omissions are  committed knowingly.3  The  term 
``repeated'' means the  commission or omission  of such act  more 
than once or for more than one day.4

     5.   Section 73.3526(b)  of  the  Rules  requires  that  the 
public inspection file be  maintained at the  main studio of  the 
station.  Based on  the evidence  before us, we  find that  Trade 
Center  Management,  Inc.,  willfully  and  repeatedly   violated 
Section 73.3526(b)  of  the  Rules by  failing  to  maintain  the 
required public inspection file at the KHRA main studio.

     6.   Pursuant  to   The   Commission's   Forfeiture   Policy 
Statement  and  Amendment  of  Section  1.80  of  the  Rules   to 
Incorporate  the  Forfeiture   Guidelines  (``Forfeiture   Policy 
Statement''),5 the base  forfeiture amount for  violation of  the 
public  file  rules  is   $10,000.  In  assessing  the   monetary 
forfeiture amount, we must also  take into account the  statutory 
factors set  forth  in Section  503(b)(2)(D)  of the  Act,  which 
include the  nature, circumstances,  extent, and  gravity of  the 
violation(s), and with  respect to  the violator,  the degree  of 
culpability, and history of prior  offenses, ability to pay,  and 
other  such  matters  as  justice  may  require.6   Applying  the 
Forfeiture Policy  Statement and  the  statutory factors  to  the 
instant case, a $10,000 forfeiture is warranted.
                       IV.  ORDERING CLAUSES

     7.   Accordingly, IT IS  ORDERED THAT,  pursuant to  Section 
503(b) of  the  Communications  Act  of  1934,  as  amended,  and 
Sections 0.111, 0.311 and 1.80  of the Commission's Rules,  Trade 
Center Management,  Inc.,  is  hereby  NOTIFIED  of  an  APPARENT 
LIABILITY FOR A FORFEITURE in the amount of ten thousand  dollars 
($10,000) for failure to maintain the KHRA public inspection file 
at the main  studio, in  violation of Section  73.3526(b) of  the 
Rules.7

     8.   IT IS FURTHER ORDERED THAT, pursuant to Section 1.80 of 
the Commission's Rules, within thirty days of the release date of 
this NOTICE OF APPARENT LIABILITY, Trade Center Management,  Inc. 
SHALL PAY the  full amount  of the proposed  forfeiture or  SHALL 
FILE a written statement seeking reduction or cancellation of the 
proposed forfeiture.

     9.   Payment of  the forfeiture  may be  made by  mailing  a 
check or similar instrument, payable to the order of the  Federal 
Communications Commission, to the Forfeiture Collection  Section, 
Finance  Branch,  Federal  Communications  Commission,  P.O.  Box 
73482, Chicago, Illinois  60673-7482.  The  payment must  include 
the FCC Registration Number (FRN) and NAL/Acct. No. referenced in 
the caption.

     10.  The  response,  if  any,  must  be  mailed  to  Federal 
Communications  Commission,  Enforcement  Bureau,  Technical  and 
Public Safety  Division, 445  12th Street,  S.W., Washington,  DC 
20554, and  must  include the  NAL/Acct.  No. referenced  in  the 
caption.  

     11.  The Commission will not consider reducing or  canceling 
a forfeiture in response  to a claim of  inability to pay  unless 
the petitioner  submits: (1)  federal tax  returns for  the  most 
recent  three-year  period;  (2)  financial  statements  prepared 
according to generally accepted accounting practices  (``GAAP''); 
or (3)  some  other  reliable and  objective  documentation  that 
accurately reflects  the petitioner's  current financial  status.  
Any claim  of inability  to pay  must specifically  identify  the 
basis for the claim by  reference to the financial  documentation 
submitted.  

     12.  Requests for payment of the full amount of this  Notice 
of Apparent Liability  under an installment  plan should be  sent 
to: Chief,  Revenue and  Receivables Operations  Group, 445  12th 
Street, S.W., Washington, D.C. 20554.8 
     13.  Under the Small Business Paperwork Relief Act of  2002, 
Pub L. No.  107-198, 116 Stat.  729 (June 28,  2002), the FCC  is 
engaged in  a two-year  tracking process  regarding the  size  of 
entities involved  in forfeitures.   If you  qualify as  a  small 
entity and  if you  wish to  be  treated as  a small  entity  for 
tracking purposes, please  so certify  to us  within thirty  (30) 
days of this  NAL, either in  your response  to the NAL  or in  a 
separate  filing  to  be  sent  to  the  Federal   Communications 
Commission,  Enforcement  Bureau,  Technical  and  Public  Safety 
Division.   Your  certification  should  indicate  whether   you, 
including your parent  entity and its  subsidiaries, meet one  of 
the definitions  set forth  in  the list  provided by  the  FCC's 
Office of Communications Business Opportunities (OCBO) set  forth 
in Attachment  A  of this  Notice  of Apparent  Liability.   This 
information will  be  used  for  tracking  purposes  only.   Your 
response or  failure to  respond to  this question  will have  no 
effect on your  rights and responsibilities  pursuant to  Section 
503(b)  of  the  Communications  Act.   If  you  have   questions 
regarding any  of  the  information contained  in  Attachment  A, 
please contact OCBO at (202) 418-0990.

     14.  IT IS FURTHER  ORDERED THAT  a copy of  this NOTICE  OF 
APPARENT LIABILITY shall be sent by Certified Mail Return Receipt 
Requested to Trade Center Management, Inc., 101 Enterprise, Suite 
330, Aliso Viejo, CA 92656.


                              FEDERAL COMMUNICATIONS COMMISSION
                         

                              John R. Raymond
                              Honolulu Resident Agent
_________________________

1  47 C.F.R. 73.3526(b).

2  47 U.S.C.  503(b).

3  Section 312(f)(1) of the Act, 47 U.S.C.  312(f)(1), which 
applies to violations for which forfeitures are assessed under 
Section 503(b) of the Act, provides that "[t]he term 'willful', 
when used with reference to the commission or omission of any 
act, means the conscious and deliberate commission or omission of 
such act, irrespective of any intent to violate any provision of 
this Act ...."  See Southern California Broadcasting Co., 6 FCC 
Rcd 4387 (1991).

4  Section 312(f)(2) of the Act, 47 U.S.C.  312(f)(2), which 
also applies to violations for which forfeitures are assessed 
under Section 503(b) of the Act, provides that "[t]he term 
'repeated', when used with reference to the commission or 
omission of any act, means the commission or omission of such act 
more than once or, if such commission or omission is continuous, 
for more than one day.''

5  12 FCC Rcd 17087 (1997), recon. denied 15 FCC Rcd 303 (1999).

6  47 U.S.C.  503(b)(2)(D).

7 47 U.S.C.  503(b); 47 C.F.R.  0.111, 0.311, 1.80, 
73.3526(b).

8 See 47 C.F.R.  1.1914