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


In the Matter of                  )
                                 )
                                 )
NEW NORTHWEST BROADCASTERS,       )   File No. EB-02-IH-0696
L.L.C.                            )   NAL/Acct. No. 200432080161
                                 )   FRN # 0003799814 
Licensee of Stations KEGX(FM),    )   Facility   ID  Nos.   53140, 
KIOK(FM), KALE(AM), Richland,     )   12455, 63359, 35717, 53139
Washington, KNLT(FM), Walla       )
Walla, Washington, and 
KTCR(AM), Kennewick, 
Washington1


         NOTICE OF APPARENT LIABILITY FOR FORFEITURE

Adopted:   May 24, 2004                 Released:    May 25, 
2004

By the Chief, Enforcement Bureau:

                      I.  INTRODUCTION

     1.   In   this  Notice   of   Apparent  Liability   for 
Forfeiture  (``NAL''), we  find New  Northwest Broadcasters, 
L.L.C.  (``NNB''), licensee  of Stations  KEGX(FM) KIOK(FM), 
KALE(AM),  Richland,  Washington,   KNLT(FM),  Walla  Walla, 
Washington, and KTCR(AM),  Kennewick, Washington, apparently 
liable  for a  monetary  forfeiture in  the  amount of  Four 
Thousand Dollars ($4,000) for a violation of section 73.1216 
of the Commission's rules.2   That rule requires a broadcast 
licensee to conduct its  contests substantially as announced 
or advertised.  We find that NNB broadcast contests in which 
it awarded  prizes to callers  who did not satisfy  its pre-
announced contest rule parameters.  

                      II.   BACKGROUND

     2.   The Commission  received a  confidential complaint 
dated  July  31, 2002,  alleging  that  NNB, time-broker  of 
Station  KUJ-FM, Walla  Walla,  Washington,  had engaged  in 
``rampant rigging  of contests''  there.3  According  to the 
complaint, the  station's on-air announcers  were instructed 
by NNB's  managers to award  contest prizes ``to  women that 
sound[ed] over  the age  of 18,''  even where  the announced 
contest rules  specified that the ninety-ninth  caller would 
win the applicable prize.4  

     3.   On  November  15,  2002,  the  Investigations  and 
Hearings Division of the Enforcement Bureau sent a letter of 
inquiry to NNB.5  NNB responded by letter dated December 23, 
2002.6   In its  response, NNB denied that  its stations and 
its employees,  including NNB's  Operations Manager,  and an 
announcer, violated the  applicable statutory and regulatory 
requirements.7  


                      III.  DISCUSSION

     4.   Applicable Statutory  and Regulatory Requirements.  
Section 508 of  the Act prohibits a  licensee from knowingly 
deceiving the public by engaging ``in any artifice or scheme 
for the  purpose of prearranging or  predetermining in whole 
or in part the outcome of  a purportedly bona fide contest . 
. . of chance.''8  Thus, section 73.1216 of the Commission's 
rules  requires a  broadcast  licensee  to conduct  station-
sponsored   contests   ``substantially   as   announced   or 
advertised,''  and  to  disclose fully  and  accurately  the 
``material terms'' of such contests.9  Material terms, among 
other things, include any eligibility restrictions, means of 
selection of  winners, and instructions regarding  entry and 
participation.10     
     5.   With  respect to  the contest-rigging  allegation, 
NNB has  represented that its stations,  except for KALE(AM) 
and KTCR(AM), have conducted various station-sponsored grand 
and  minor prize  contests, typified  by call-in  parameters 
(i.e., contests  awarded to designated  numbered callers).11  
As  an  example, NNB  provided  a  transcript of  a  typical 
contest announcement.12  NNB contends that the parameters of 
and the procedures for  such station-sponsored contests were 
established  and   implemented  by  its   stations'  program 
directors  and  disc  jockeys.13   NNB  maintains  that  its 
employees did not rig contest results, and that its stations 
conducted contests  and awarded  prizes consistent  with the 
announcements   and  in   accordance  with   the  applicable 
statutory and regulatory  requirements.14  NNB acknowledged, 
however, that, in its investigation into the allegations, it 
discovered that,  in a  few incidents  in which  call volume 
fell  short of  the announced  designated numbered  callers, 
prizes had been awarded to the next eligible callers.15  NNB 
maintained  that  these  incidents were  isolated  and  were 
attributable  to insufficient  call volume  -- not  from any 
desire  to favor  any type  of contestant,  adult female  or 
otherwise.16  NNB advised that it took corrective action, by 
informing   its  disc   jockeys  that,   in  the   event  of 
insufficient  call  volume,  they should  announce  a  lower 
number level and award the prize accordingly.17    

     6.   In this case, it appears that NNB violated section 
73.1216 of the Commission's rules by not conducting at least 
one of its contests  substantially as announced.  NNB admits 
that  its station  announcers, in  a few  instances, awarded 
prizes to call-in contestants who did not meet the contests' 
announced parameters and requirements.  Licensees, as public 
trustees,  have the  affirmative obligation  to prevent  the 
broadcast   of  false,   misleading  or   deceptive  contest 
announcements,18   and   for   conducting   their   contests 
substantially  as  announced.19   Although  NNB  later  took 
remedial  actions to  correct  the conduct  of its  contests 
prospectively,  these   actions  do  not  absolve   it  from 
liability and the proposed forfeiture penalty.20   

                       V.  FORFEITURE

     7.   Under section 503(b)(1) of the Act, any person who 
is  determined  by  the  Commission  to  have  willfully  or 
repeatedly failed to comply with any provision of the Act or 
any  rule, regulation,  or  order issued  by the  Commission 
shall  be  liable  to  the  United  States  for  a  monetary 
forfeiture penalty.21  In order  to impose such a forfeiture 
penalty,  the Commission  must  issue a  notice of  apparent 
liability,  the  notice must  be  received,  and the  person 
against  whom  the  notice  has been  issued  must  have  an 
opportunity  to show,  in  writing, why  no such  forfeiture 
penalty should be imposed.22  The Commission will then issue 
a forfeiture if it finds  by a preponderance of the evidence 
that the person has violated the Act or a Commission rule.23  
As we set  forth in greater detail below,  we conclude under 
this standard that NNB is apparently liable for a forfeiture 
for its apparent willful violation of section 73.1216 of the 
Commission's rules.

     8.    Based upon  the evidence before us,  we find that 
NNB apparently  willfully24 violated section 73.1216  of the 
Commission's  rules.  The   Commission's  Forfeiture  Policy 
Statement  sets  a  base  forfeiture amount  of  $4,000  for 
failure  to  conduct  a  station  contest  substantially  as 
announced.25 In assessing the monetary forfeiture amount, we 
must take  into account the  statutory factors set  forth in 
Section 503(b)(2)(D) of the Act,26 which include the nature, 
circumstances,  extent, and  gravity of  the violation,  and 
with respect to the violator, the degree of culpability, any 
history of  prior offenses, ability  to pay, and  other such 
matters  as  justice  may require.   After  considering  the 
record, the factors contained in section 503(b)(2)(D) of the 
Act,  47 U.S.C.   503(b)(2)(D),  and the  Forfeiture Policy 
Statement,   we  believe   that  a   $4,000  forfeiture   is 
appropriate in this case.


                    V.  ORDERING CLAUSES

     9.   ACCORDINGLY,  IT IS  ORDERED, pursuant  to section 
503(b) of the Communications Act  of 1934, as amended,27 and 
sections 0.111, 0.311, and 1.80 of the Commission's rules,28 
that New  Northwest Broadcasters, L.L.C. is  hereby NOTIFIED 
of its  APPARENT LIABILITY FOR  FORFEITURE in the  amount of 
Four  Thousand  Dollars  ($4,000)  for  willfully  violating 
section 73.1216 of the Commission's rules. 

     10.   IT  IS FURTHER ORDERED, pursuant  to section 1.80 
of the Commission's  rules, that within thirty  (30) days of 
the  release of  this  Notice,  New Northwest  Broadcasters, 
L.L.C. SHALL PAY the full  amount of the proposed forfeiture 
or  SHALL  FILE a  written  statement  seeking reduction  or 
cancellation of the proposed forfeiture.

     11.  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) 
referenced  above and  also  should note  the NAL/Acct.  No. 
referenced above.

     12.  The response,  if any,  must be mailed  to William 
Davenport,  Chief,  Investigations  and  Hearings  Division, 
Enforcement Bureau,  Federal Communications  Commission, 445 
12th Street,  S.W, Room  3-B433, Washington, D.C.  20554 and 
MUST INCLUDE the NAL/Acct. No. referenced above.

     13.  The  Commission  will  not  consider  reducing  or 
canceling a forfeiture  in response to a  claim of inability 
to  pay  unless  the  respondent 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 
respondent'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.

     14.  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. 20554.29

     15.  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 NNB qualifies 
as a small entity and if  it wishes to be treated as a small 
entity for  tracking purposes,  it should  so certify  to us 
within thirty (30) days of  this NAL, either in its response 
to  the NAL  or  in a  separate  filing to  be  sent to  the 
Investigations and  Hearings Division.   NNB's certification 
should indicate whether it,  including its 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.  NNB's response or failure 
to  respond to  this question  will  have no  effect on  its 
rights and  responsibilities pursuant  to Section  503(b) of 
the Communications Act.  If  NNB has questions regarding any 
of the information contained in Attachment A, please contact 
OCBO at (202) 418-0990.




     16.  IT IS FURTHER  ORDERED that a copy  of this Notice 
shall be  sent, by Certified Mail/Return  Receipt Requested, 
to  New  Northwest  Broadcasters, L.L.C.,  15405  S.E.  37th 
Street, Suite  130, Bellevue,  Washington 98006, and  to its 
counsel, M. Anne Swanson, Esq., Dow Lohnes & Albertson, 1200 
New  Hampshire Avenue,  N.W.,  Suite  800, Washington,  D.C. 
20036-6802.    


                         FEDERAL COMMUNICATIONS COMMISSION


     
                         David H. Solomon
                         Chief, Enforcement Bureau
                                                October 2002
                        ATTACHMENT A


                 FCC List of Small Entities

   As described below, a ``small entity'' may be a small 
                       organization,
  a small governmental jurisdiction, or a small business.

(1)  Small Organization 
Any  not-for-profit  enterprise that  is independently  owned 
and operated and 
is not dominant in its field.

  
(2)  Small Governmental Jurisdiction
Governments of  cities, counties, towns, townships, villages, 
school districts, or 
special  districts,  with a  population  of  less than  fifty 
thousand.


(3)  Small Business
Any   business  concern  that  is   independently  owned  and 
operated and 
is  not dominant in its  field, and meets the  pertinent size 
criterion described below.
  

       Industry Type          Description of Small Business 
                                     Size Standards
                 Cable Services or Systems
                             Special Size Standard - 
Cable Systems                 Small Cable Company has 400,000 
                             Subscribers Nationwide or Fewer
Cable   and   Other  Program 
Distribution                      $12.5 Million in Annual 
                                    Receipts or Less

Open Video Systems 
        Common Carrier Services and Related Entities
Wireline     Carriers    and 
Service providers 
                                1,500 Employees or Fewer
Local   Exchange   Carriers, 
Competitive           Access 
Providers,     Interexchange 
Carriers,  Operator  Service 
Providers,          Payphone 
Providers, and Resellers

Note:   With  the   exception  of  Cable  Systems,  all  size 
standards  are expressed  in  either millions  of dollars  or 
number  of employees  and  are generally  the average  annual 
receipts  or the  average employment  of a  firm.  Directions 
for   calculating   average  annual   receipts  and   average 
employment of a firm can be found in 
13 CFR 121.104 and 13 CFR 121.106, respectively.




                   International Services
International      Broadcast 
Stations






                                 $12.5 Million in Annual 
                                    Receipts or Less
International  Public  Fixed 
Radio  (Public  and  Control 
Stations)
Fixed              Satellite 
Transmit/Receive       Earth 
Stations
Fixed  Satellite  Very Small 
Aperture Terminal Systems
Mobile    Satellite    Earth 
Stations
Radio          Determination 
Satellite Earth Stations
Geostationary Space Stations
Non-Geostationary      Space 
Stations
Direct Broadcast Satellites
Home Satellite Dish Service
                    Mass Media Services
Television Services

                             $12 Million in Annual Receipts 
                                         or Less
Low     Power     Television 
Services    and   Television 
Translator Stations
TV     Auxiliary,    Special 
Broadcast  and Other Program 
Distribution Services
Radio Services
                              $6 Million in Annual Receipts 
                                         or Less
Radio   Auxiliary,   Special 
Broadcast  and Other Program 
Distribution Services
Multipoint      Distribution  Auction Special Size Standard -
Service                       Small  Business  is  less  than 
                             $40M in  annual gross  revenues 
                             for three preceding years
          Wireless and Commercial Mobile Services
Cellular Licensees
                                1,500 Employees or Fewer
220   MHz  Radio  Service  - 
Phase I Licensees
220   MHz  Radio  Service  -  Auction special size standard -
Phase II Licensees            Small Business is average gross 
                             revenues  of $15M  or less  for 
                             the   preceding   three   years 
                             (includes    affiliates     and 
                             controlling principals)
                             Very Small Business  is average 
                             gross revenues  of $3M  or less 
                             for the  preceding three  years 
                             (includes    affiliates     and 
                             controlling principals)
700 MHZ Guard Band Licensees


Private  and  Common Carrier 
Paging
Broadband           Personal 
Communications      Services     1,500 Employees or Fewer
(Blocks A, B, D, and E)
Broadband           Personal  Auction special size standard -
Communications      Services  Small Business is  $40M or less 
(Block C)                     in  annual gross  revenues  for 
                             three previous calendar years
                             Very Small Business  is average 
                             gross revenues of  $15M or less 
                             for    the   preceding    three 
                             calendar    years     (includes 
                             affiliates   and   persons   or 
                             entities that hold  interest in 
                             such    entity     and    their 
                             affiliates)
Broadband           Personal 
Communications      Services 
(Block F)
Narrowband          Personal 
Communications Services


Rural Radiotelephone Service     1,500 Employees or Fewer
Air-Ground    Radiotelephone 
Service
800  MHz  Specialized Mobile  Auction special size standard -
Radio                         Small Business is  $15M or less 
                             average  annual gross  revenues 
                             for  three  preceding  calendar 
                             years
900  MHz  Specialized Mobile 
Radio
Private Land Mobile Radio        1,500 Employees or Fewer
Amateur Radio Service                       N/A
Aviation  and  Marine  Radio 
Service                          1,500 Employees or Fewer
Fixed Microwave Services
                             Small    Business   is    1,500 
Public Safety Radio Services  employees or less
                             Small  Government Entities  has 
                             population of less  than 50,000 
                             persons
Wireless    Telephony    and 
Paging and Messaging             1,500 Employees or Fewer
Personal Radio Services                     N/A
Offshore      Radiotelephone     1,500 Employees or Fewer
Service
Wireless      Communications  Small Business is  $40M or less 
Services                      average  annual gross  revenues 
                             for three preceding years
                             Very Small Business  is average 
                             gross revenues of  $15M or less 
                             for the preceding three years 

39 GHz Service
                             Auction  special size  standard 
                             (1996) -
Multipoint      Distribution  Small Business is  $40M or less 
Service                       average  annual gross  revenues 
                             for  three  preceding  calendar 
                             years
                             Prior to Auction -
                             Small   Business   has   annual 
                             revenue of $12.5M or less
Multichannel      Multipoint 
Distribution Service              $12.5 Million in Annual 
                                    Receipts or Less
Instructional     Television 
Fixed Service
                             Auction  special size  standard 
                             (1998) -
Local             Multipoint  Small Business is  $40M or less 
Distribution Service          average  annual gross  revenues 
                             for three preceding years
                             Very Small Business  is average 
                             gross revenues of  $15M or less 
                             for the preceding three years 
                             First   Auction  special   size 
                             standard (1994) -
                             Small  Business  is  an  entity 
                             that,    together   with    its 
                             affiliates, has no  more than a 
218-219 MHZ Service           $6M   net  worth   and,   after 
                             federal income taxes (excluding 
                             carryover losses)  has no  more 
                             than $2M in annual profits each 
                             year for the previous two years
                             New Standard - 
                             Small Business is average gross 
                             revenues  of $15M  or less  for 
                             the   preceding   three   years 
                             (includes    affiliates     and 
                             persons or  entities that  hold 
                             interest  in  such  entity  and 
                             their affiliates)
                             Very Small Business  is average 
                             gross revenues  of $3M  or less 
                             for the  preceding three  years 
                             (includes    affiliates     and 
                             persons or  entities that  hold 
                             interest  in  such  entity  and 
                             their affiliates)
Satellite   Master   Antenna 
Television Systems                $12.5 Million in Annual 
                                    Receipts or Less
24 GHz - Incumbent Licensees     1,500 Employees or Fewer
24 GHz - Future Licensees     Small Business is average gross 
                             revenues  of $15M  or less  for 
                             the   preceding   three   years 
                             (includes    affiliates     and 
                             persons or  entities that  hold 
                             interest  in  such  entity  and 
                             their affiliates)
                             Very Small Business  is average 
                             gross revenues  of $3M  or less 
                             for the  preceding three  years 
                             (includes    affiliates     and 
                             persons or  entities that  hold 
                             interest  in  such  entity  and 
                             their affiliates)
                       Miscellaneous
On-Line Information Services  $18 Million in Annual Receipts 
                                         or Less
Radio     and     Television 
Broadcasting   and  Wireless 
Communications     Equipment      750 Employees or Fewer
Manufacturers
Audio  and  Video  Equipment 
Manufacturers
Telephone          Apparatus 
Manufacturers        (Except     1,000 Employees or Fewer
Cellular)
Medical    Implant    Device      500 Employees or Fewer
Manufacturers
Hospitals                     $29 Million in Annual Receipts 
                                         or Less
Nursing Homes                     $11.5 Million in Annual 
                                    Receipts or Less
Hotels and Motels              $6 Million in Annual Receipts 
                                         or Less
Tower Owners                  (See Lessee's Type of Business)


_________________________

1  New  Northwest  Broadcasters,  L.L.C.  also  time-brokers 
Station KUJ-FM, Walla Walla,  Washington.  Station KUJ-FM is 
licensed to Alexandria Communications.

2 47 C.F.R.  73.1216. 

3  See  Confidential Complaint  dated  July  31, 2002  at  2 
(``Complaint'').  

4 Id.

5 See  Letter from Charles W.  Kelley, Chief, Investigations 
and   Hearings   Division,   Enforcement   Bureau,   Federal 
Communications Commission  to NNB,  dated November  15, 2002 
(``LOI''). 

6 See  Letter from Trila Bumstead,  Chief Financial Officer, 
NNB,  to  Charles  W.   Kelley,  Chief,  Investigations  and 
Hearings  Division, Enforcement  Bureau, dated  December 23, 
2002 (``Response''). 

7 Id.

8 47 U.S.C.  509.

9 47 C.F.R.  73.1216  specifically provides that a licensee 
that broadcasts or advertises information about a contest it 
conducts shall  fully and  accurately disclose  the material 
terms  of  the  contest,   and  shall  conduct  the  contest 
substantially  as  announced   or  advertised.   No  contest 
description  shall be  false, misleading  or deceptive  with 
respect to any material term.

 10 See 47 C.F.R.   73.1216, notes  1(b) and 2.  Note  1 to 
 that rule provides that  the material terms of  the contest 
 include ``the  extent,  nature and  value  of prizes''  and 
 ``the basis for valuation  of the prizes.''  Note  2 to the 
 rule states: 

     In general,  the time and manner  of disclosure of 
     the  material terms  of a  contest are  within the 
     licensee's discretion.  However, the obligation to 
     disclose the material terms arises at the time the 
     audience is first told how to enter or participate 
     and  continues  thereafter.   The  material  terms 
     should be disclosed  periodically by announcements 
     broadcast on  the station conducting  the contest, 
     but   need  not   be  enumerated   each  time   an 
     announcement  is sufficient.   In addition  to the 
     required  broadcast  announcements, disclosure  of 
     material  terms may  be  made  in a  non-broadcast 
     manner.

11 See Response at 4.  

12 Id. at Exhibit E.

13  Id. at 6.

14 Id. at 7.  

15 Id.

16 Id.

17 Id.

18 WMJX, Inc., 48 RR 2d 1339, 1355 (1981); Report and Order, 
Rules  Relating to  Licensee-Conducted Contests,  60 FCC  2d 
1072 (1976).

19 In  re Headliner  Radio, Inc. (KSXY-FM),  8 FCC  Rcd 2962 
(MMB 1993); In re Lincoln Dellar, 8 FCC Rcd 2582, 2585 (MMB-
ASD 1993) (where the cancellation of a pre-announced contest 
violated the  pertinent Commission rule because  the contest 
was not then conducted ``substantially as announced'').

20 See AT&T Wireless Services, Inc., 17 FCC Rcd 21866, 21871 
(2002);  see also  Station KVGL,  Inc., 42  FCC 2d  258, 259 
(1973).

21 47  U.S.C.   503(b)(1)(B); 47  C.F.R.   1.80(a)(1); see 
also 47 U.S.C.   503(b)(1)(D) (forfeitures for violation of 
14 U.S.C.   1464).   Section 312(f)(1)  of the  Act defines 
willful  as ``the  conscious  and  deliberate commission  or 
omission  of  [any]  act,  irrespective  of  any  intent  to 
violate'' the  law.  47 U.S.C.   312(f)(1). The legislative 
history to section 312(f)(1) of  the Act clarifies that this 
definition  of  willful applies  to  both  sections 312  and 
503(b) of the Act, H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 
51 (1982), and the Commission has so interpreted the term in 
the  section 503(b)  context.   See,  e.g., Application  for 
Review of  Southern California Broadcasting  Co., Memorandum 
Opinion and Order,  6 FCC Rcd 4387,  4388 (1991) (``Southern 
California  Broadcasting Co.'').   The  Commission may  also 
assess a forfeiture for violations that are merely repeated, 
and  not willful.   See,  e.g.,  Callais Cablevision,  Inc., 
Grand  Isle, Louisiana,  Notice  of  Apparent Liability  for 
Monetary  Forfeiture,  16 FCC  Rcd  1359  (2001) (issuing  a 
Notice  of  Apparent  Liability  for, inter  alia,  a  cable 
television    operator's     repeated    signal    leakage).  
``Repeated''  merely means  that  the act  was committed  or 
omitted  more  than  once,  or  lasts  more  than  one  day.  
Southern California Broadcasting  Co., 6 FCC Rcd  at 4388,  
5; Callais Cablevision, Inc., 16 FCC Rcd at 1362,  9.    

22 47 U.S.C.  503(b); 47 C.F.R.  1.80(f).

23 See,  e.g., SBC Communications, Inc.,  Apparent Liability 
for Forfeiture, Forfeiture Order, 17 FCC Rcd 7589, 7591,  4 
(2002) (forfeiture paid). 

24  Section 312(f)(1)  of the  Act, 47  U.S.C.   312(f)(1), 
which applies  to 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).

25   The  Commission's   Forfeiture  Policy   Statement  and 
Amendment of  Section 1.80 of  the Rules to  Incorporate the 
Forfeiture  Guidelines,  12  FCC Rcd  17087,  17113  (1997), 
recon.  denied 15  FCC Rcd  303 (1999)  (``Forfeiture Policy 
Statement''); 47 C.F.R.  1.80(b).

26 47 U.S.C.  503(b)(2)(D).

27 47 U.S.C.  503(b).

28 47 C.F.R.  0.111, 0.311 and 1.80.

29 See 47 C.F.R.  1.1914.