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

In the Matter of                )
                                )
Joe L. Ford, d/b/a/             )    File No. EB-00-TS-149
 Ford Communications            )    NAL/Acct. No. 200132100005
Licensee of Paging Stations KNKM966, KNKM224 )         
KNKL902, KNKO751 and KNKO274   ) 
Various Locations in Kentucky   )
                                   

                        FORFEITURE ORDER 

Adopted:  February 12, 2001                  Released:   February 
14, 2001

By the Chief, Technical  and Public Safety Division,  Enforcement 
Bureau:

                        I.  INTRODUCTION

1.        In  this  Forfeiture  Order  (``Order''),  we  issue  a 
  monetary  forfeiture in  the amount  of five  thousand  dollars 
  ($5,000)  against  Joe  L.  Ford,  d/b/a  Ford   Communications 
  (``Ford''), for violation of Section 301 of the  Communications 
  Act of  1934 (``Act''),  as amended,  and Section  22.3 of  the 
  Commission's Rules (``Rules'').1  The noted violation  involves 
  Ford's   operation  of   paging  systems   without   Commission 
  authorization.

2.        On November 29,  2000, the  Chief, Enforcement  Bureau, 
  issued a Notice of Apparent Liability (``NAL'') for  Forfeiture 
  in the amount  of five thousand dollars ($5,000).2  Ford  filed 
  a response on December 6, 2000.

                         II.  BACKGROUND

3.        Ford's authorization for the captioned stations expired 
  on April  1, 1999.   Ford, however, did  not file  applications 
  for renewal of the authorization for the above listed  stations 
  until  March  7,  2000.  On  April  20,  2000,  the  Commission 
  reinstated Ford's authority to operate the captioned stations.

4.        On November 29,  2000, the  Chief, Enforcement  Bureau, 
  issued a Notice of Apparent Liability for Forfeiture  (``NAL'') 
  to Ford  in the amount  of $5,000 for  its operation of  paging 
  stations  without  valid  licenses  in  willful  and   repeated 
  violation of Section 301 of the Communications Act and  Section 
  22.3 of the Commission's Rules.3  In response to the NAL,  Ford 
  argues that  it is a small  business whose primary business  is 
  to better serve  its community, and suggests that its  revenues 
  are insufficient to  cover the forfeiture amount.  Ford  states 
  that it  has not  made a profit  in the last  three years.   In 
  support  of  this  assertion,  Ford  submits  profit  and  loss 
  statements from 1997, 1998, and 1999.

                      III.      DISCUSSION

5.        Section 301 of the Act  sets forth the general  mandate 
  that  no person  shall use  or operate  any apparatus  for  the 
  transmission of  energy or communications  or signals by  radio 
  within the United States except under and in accordance with  a 
  license.4  Section 22.3 of the Commission's Rules provides,  in 
  pertinent  part, that  stations in  the Public  Mobile  Service 
  must be  operated with a  valid Commission authorization.5   We 
  find that  Ford willfully and  repeatedly violated Section  301 
  of the  Communications Act  and Section  22.3 of  the Rules  by 
  operating paging stations without valid licenses.

6.        Ford submits profit and  loss statements in support  of 
  its assertion that  its revenues are insufficient to cover  the 
  proposed   forfeiture.   The   Commission  requires   licensees 
  claiming inability to  pay a forfeiture to provide tax  returns 
  or financial statements  prepared in accordance with  generally 
  accepted accounting principles for the most recent three  years 
  or other reliable  and objective documentation that  accurately 
  reflects the  licensee's current financial  status.  See  Barry 
  A. Stevenson, 12 FCC Rcd 1976, 1977 (Compl. & Inf. Bur.  1997).  
  Ford's financial  statements do not  include any  certification 
  as  to their  correctness, and  we  cannot determine  from  the 
  information  available  that these  financial  statements  were 
  prepared  in  accordance  with  generally  accepted  accounting 
  principles.  In  any event, Ford's  profit and loss  statements 
  indicate that  it had  gross revenues of  $237,171.30 in  1997, 
  $190,935.93 in  1998, and  $231,332.82 in  1999.  The  proposed 
  forfeiture amount of $5,000 is not excessive in the context  of 
  these  revenues.   Therefore,  we  affirm  the  forfeiture   of 
  $5,000.

                      IV.  ORDERING CLAUSES

7.        Accordingly, IT IS  ORDERED THAT,  pursuant to  Section 
  503(b) of  the Act6, and Sections  0.111, 0.311 and  1.80(f)(4) 
  of  the   Commission's  Rules7,   Joe  L.   Ford,  d/b/a   Ford 
  Communications,  IS LIABLE  FOR A  MONETARY FORFEITURE  in  the 
  amount of $5,000 for willful and repeated violation of  Section 
  301 of the Communications Act of 1934, as amended, and  Section 
  22.3 of the Commission's Rules. 

8.        Payment of the forfeiture shall  be made in the  manner 
  provided for in Section 1.80 of the Commission's Rules8  within 
  30 days  of the release  of this Order.   If the forfeiture  is 
  not paid within the period specified, the case may be  referred 
  to  the  Department  of  Justice  for  collection  pursuant  to 
  section 504(a) of the  Act.9  Payment shall be made by  mailing 
  a check  or similar  instrument, payable  to the  order of  the 
  Federal    Communications   Commission,    to    the    Federal 
  Communications Commission,  P.O. Box  73482, Chicago,  Illinois 
  60673-7482.   The  payment   should  note  the  NAL/Acct.   No. 
  200132100005.  Requests for  full payment under an  installment 
  plan  should be  sent to:  Chief,  Credit and  Debt  Management 
  Center, 445 12th Street, S.W., Washington, D.C. 20554.10

9.        IT IS FURTHER  ORDERED that a  copy of this  Forfeiture 
  Order shall be sent by Certified Mail Return Receipt  Requested 
  to counsel  for Joe L. Ford,  d/b/a Ford Communications,  Lewis 
  H. Goldman Law Offices, Attention Lewis H. Goldman, 4141  North 
  Henderson Road, Plaza Suite 9, Arlington, Virginia 22203.


                         FEDERAL COMMUNICATIONS COMMISSION
                         


                         Joseph P. Casey
                         Chief,  Technical   and  Public   Safety 
Division
                         Enforcement Bureau
_________________________

  1 47 C.F.R.  22.3.

  2 Notice  of Apparent Liability  for Forfeiture, NAL/Acct.  No. 
200132100005 (Enf. Bur., rel. November 29, 2000).

  3  47 U.S.C.  301; 47 C.F.R.  22.3.

  4  47 U.S.C.  301.

  5  47 C.F.R.  22.3.

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

  7 47 C.F.R.  0.111, 0.311, 1.80(f)(4).

  8 47 C.F.R.  1.80.

  9 47 U.S.C.  504(a).

  10 See 47 C.F.R.  1.1914.