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

In the Matter of                  )
Minority Television Project,      )   EB-03-IH-0126
Inc.                              )   NAL/Account No. 200532080019
                                 )   Facility ID No. 43095
                                 )   FRN 0008886293
Licensee of Noncommercial         )
Educational Television Station    )
KMTP-TV, San Francisco, 


Adopted:  02/08/2005                                   
Released:  02/09/2005

By the Chief, Enforcement Bureau:


     1.   In this Notice of Apparent Liability for 
Forfeiture (``NAL''), we find that Minority Television 
Project, Inc. (``Minority''), licensee of noncommercial 
educational television Station KMTP-TV, San Francisco, 
California, has apparently violated section 399B of the 
Communications Act of 1934, as amended (the ``Act''),1 and 
section 73.621 of the Commission's rules,2 by willfully and 
repeatedly broadcasting prohibited  advertisements.  Based 
upon our review of the facts and circumstances of this case, 
we conclude that Minority is apparently liable for a 
monetary forfeiture in the amount of $7,500.


     2.   This case arises from allegations contained in a 
reply pleading filed with the Commission by Lincoln 
Broadcasting Company (``Lincoln'') on April 17, 2002, during 
the course of a prior investigation by the Enforcement 
Bureau (the ``Bureau'') concerning Station KMTP-TV's 
underwriting practices.3  In that pleading, Lincoln alleged 
that Minority had broadcast prohibited underwriting 
announcements on behalf of the Honda Accord, Charles Schwab, 
and Star Cruises, on January 9, February 25, and March 26, 
2002, respectively.4  The Bureau thereafter inquired of the 
licensee concerning the new announcements.5  Minority 
responded, acknowledging that Station KMTP-TV aired the 
announcements in question during the period January through 
March 2002 a total of 98 times, and defended its 
underwriting practices.6     


     3.   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 forfeiture 
penalty.7  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.8  
The Commission will then issue a forfeiture if it finds, by 
a preponderance of the evidence, that the person has 
willfully or repeatedly violated the Act or a Commission 
rule.  As described in greater detail below, we conclude 
under this procedure that Minority is apparently liable for 
a forfeiture in the amount of $7,500 for its apparent 
willful and repeated violations of section 399B of the Act 
and section 73.621 of the Commission's rules. 

    A.   Minority Apparently Has Willfully and Repeatedly 
       Broadcast Advertisements in Violation of Section 399B 
       of the Act and Section 73.621 of the Commission's 

     4.   Advertisements are defined by the Act as program 
material broadcast "in exchange for any remuneration" and 
intended to "promote any service, facility, or product" of 
for-profit entities.9 The pertinent statute specifically 
provides that noncommercial educational stations may not 
broadcast advertisements.10  Although contributors of funds 
to noncommercial stations may receive on-air 
acknowledgements, the Commission has held that such 
acknowledgements may be made for identification purposes 
only, and should not promote the contributors' products, 
services, or business.11  Specifically, such announcements 
may not contain comparative or qualitative descriptions, 
price information, calls to action, or inducements to buy, 
sell, rent or lease.12  At the same time, however, the 
Commission has acknowledged that it is at times difficult to 
distinguish between language that promotes versus that which 
merely identifies the underwriter.  Consequently, the 
Commission expects only that licensees exercise reasonable, 
good-faith judgment in this area.13
     5.   At issue are three underwriting announcements 
which Minority acknowledges that the station broadcast a 
total of 98 times during the period January through March 
2002.14  The announcements for the Honda Accord and Charles 
Schwab were televised in Mandarin Chinese and that on behalf 
of Star Cruises was aired in the Vietnamese language.  The 
translations offered by Lincoln and Minority are 
substantially similar.  To the extent that the translations 
offered by Minority represent its attempt to exercise its 
``good-faith'' discretion under Xavier, supra, we will defer 
to it.  Accordingly, we will accept and rely on Minority's 
translations in evaluating whether it acted reasonably in 
its exercise of that discretion.15   

     6.   In this case, Minority acknowledges that it aired 
the subject messages on behalf of the station's 
underwriters, all of which are for-profit entities, 98 
times.16  Minority argues, however, that its broadcast of 
the announcements was consistent with pertinent Commission 
     7.   In this regard, Minority represents that, as 
specifically permitted by section 73.621 of the Commission's 
rules, it received only ``general contribution[s made] to 
the station's operating cost'' from World Channel, Inc., a 
program supplier, and that such contributions to the station 
were not made in quid pro quo exchange for the broadcast 
inclusion of individual announcements, including those made 
on behalf of the Honda Accord and Charles Schwab, but, 
rather, to offset the station's general operating costs.18  
Minority avers that it has not received consideration 
directly from the underwriters themselves, or compensation 
on a per-spot basis for airing underwriting announcements, 
since contracting with program supplier World Channel, Inc., 
in December 1998. 19  Minority claims that, since that time, 
it has received only general annual station operating 
contributions to subsidize the cost of airing the programs 
that World Channel supplies.20  Although Lincoln argues that 
Minority's explanation is at odds with the account given in 
the prior forfeiture proceeding, viz., that Minority 
``received cash consideration for each of the 
announcements'' then under investigation, it appears that 
Minority may simply have been imprecise in previously 
explaining how it received such payments.21  

     8.   Regarding the third underwriting announcement, 
Minority represents that it had an ``oral barter or trade 
arrangement'' with another program supplier, Tron Do, in 
exchange for Minority's agreement to broadcast Mr. Do's 
program, ``Dien Dan Vietnam,'' on which program the Star 
Cruises messages were contained.22  Minority contends that 
Station KMTP-TV's broadcast of the underwriting 
announcements thus do not violate section 399B of the Act, 
even if the messages contained language or references that 
promoted for-profit entities, because they were not aired in 
exchange for consideration.   

     9.   We reject Minority's arguments, and find that each 
of the announcements at issue apparently exceeds the scope 
of what is permissible under section 399B of the Act, and 
the Commission's pertinent rules, in light of the ``good 
faith'' discretion afforded licensees under Xavier, supra.  
In this regard, the announcements each seek impermissibly to 
distinguish favorably their underwriters from competitors by 
directly stating or implying that they offer superior 
service or products, and some of the announcements also 
invite or urge business patronage.    

     10.  With regard to the Honda Accord announcement, we 
note that the visual aspects of the announcement depict the 
automobile in use, turning a circle, while the narrator, 
speaking in Chinese, describes several of the vehicle's 
attributes through the terms ``accuracy,'' ``flexibility,'' 
``power'' and ``level,'' suggesting that such qualities 
commend it as a vehicle that will accompany viewers ``around 
the direction of [their] life, straight or curve.''23  
Minority argues that, because these adjectives are not 
usually applied to describe automotive performance, and are 
``factually descriptive,'' they should not be deemed to be 
promotional.  This argument lacks merit.  As we have said 
previously, the purported factual descriptiveness or 
veracity of any reference is irrelevant to the issue of 
whether that message is promotional.24  Moreover, we find 
that these terms are clearly promotional.  Although the term 
``accuracy'' does not appear to refer to a quality 
ordinarily associated with automobiles, the same cannot be 
said for the other adjectives contained in the announcement.  
In this regard, the term ``flexibility'' appears to imply 
that the car possesses varied functionality, which, in this 
case, intends a comparative and qualitative reference.  It 
further appears that the term ``power,'' in this case, 
speaks to the vehicle's acceleration, torque or horsepower 
rating, which is similarly descriptive and pertinent to 
automotive quality.  Moreover, the announcement's reference 
to the term ``level'' reasonably suggests, in the context 
presented,  that the Honda Accord automobile's drivers enjoy 
a smooth ride, which is a favorable reference to the 
product's handling characteristics. 

     11.  Minority further contends that the Honda Accord 
announcement is not promotional because the automobile is 
portrayed being driven in a pattern that spells the Chinese 
character for the word ``life,'' and not ``racing down a 
roadway.''25   Minority claims that the instant presentation 
is therefore allegorical or symbolic and does not promote 
the featured product's automotive qualities.26  We note that 
Minority cites no precedent supporting this contention.  To 
the contrary, even where underwriting announcements utilize 
indirect or oblique forms of expression to convey their 
message, they may still be found to promote their 
subjects.27  We find that the instant announcement portrays 
the vehicle as one that would enhance or enrich the viewers' 
lifestyles, and by doing so, impermissibly promotes the 
underwriter's product.  
     12.  We find that the Charles Schwab announcement 
promotes the company by inviting business patronage.  In 
this regard, the message implores viewers to consider that 
``new tax laws are affecting different kinds of IRA 
retirement accounts,'' and then invites them to ask the 
advisers at Charles Schwab for specific advice on how best 
to respond to such changes.28  Similarly, the Star Cruises 
announcement describes its Hoi Ngo Trung Duong vacation 
package in comparative and qualitative terms by stating that 
it is ``an interesting tour that has received many 
compliments,'' thus attempting to distinguish it favorably 
from other such tours.29  The announcement also 
characterizes the cruise ship's accommodations as ``world 
class,'' and not in permissible value-neutral terms.    
Furthermore, the announcement makes a prohibited call-to-
action through inviting viewers to ``please call,'' and by 
implying that, because ``seats are limited,'' that they 
should act promptly to secure a reservation.30 

     13.  Contrary to Minority's contentions, the 
underwriting announcements at issue appear to have been 
broadcast in exchange for consideration.  In this regard, 
``consideration,'' for purposes of section 399B of the Act, 
may consist of the program material itself.31  The Act does 
not require that the consideration involved be supplied 
directly by the sponsor or underwriter itself.32  
Furthermore, the Commission has long held that promotional 
statements made on behalf of for-profit entities, when made 
in exchange for the receipt or reasonable anticipation of 
direct or indirect consideration, are prohibited under 
section 399B, and that cognizable consideration may take 
many forms.33  Thus, even if the program supplier, World 
Channel, Inc., negotiated with the advertising firms or 
underwriters involved and received payments directly from 
them, that factor would be of no consequence, because 
Minority's decision to include the announcements in the 
material that it broadcast appears based on the fact that 
it, in turn, was to receive consideration from the 
programmer, if not on a ``per spot'' basis, then in the form 
of annual payments.34  The production orders and invoices 
supplied by Minority indicate that its program supplier 
World Channel, Inc., billed advertising firm Monva, Inc., 
for placing the Honda Accord and Charles Schwab 
announcements in program material intended for broadcast 
over the station.35  The invoices contemplate that the 
station would run the announcements on specific dates in 
exchange for payment, and belie any claim that the 
announcements were aired on a gratuitous basis. In addition, 
the inclusion of the Star Cruise announcement in the 
programming supplied to the station was, according to 
Minority, based on ``oral barter or trade arrangement'' and 
thus supported by consideration.36  
     B.  Proposed Action

     14.  Section 503(b) of the Act and section 1.80(a) of 
the Commission's rules both state that any person who 
willfully or repeatedly fails to comply with the provisions 
of the Act, the rules or Commission orders shall be liable 
for a forfeiture penalty.37  The Commission's Forfeiture 
Policy Statement sets a base forfeiture amount of $2,000 for 
violation of the enhanced underwriting requirements.38  The 
Forfeiture Policy Statement also specifies that the 
Commission shall adjust a forfeiture based upon 
consideration of the factors enumerated in section 
503(b)(2)(D) of the Act, such as ``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 such other 
matters as justice may require.''39  

     15.  In this case, it appears that, during the period 
January through March 2002, Minority willfully and 
repeatedly broadcast advertisements in violation of section 
399B of the Act and section 73.621 of the Commission's 
rules.  We believe that a substantial forfeiture is 
necessary due to several factors, including the period of 
time during which the prohibited announcements were aired -- 
three months -- and the significant number of times that the 
announcements were repeated - 98.  Nevertheless, we believe 
the potential liability if we simply applied the $2,000 bas 
amount to each of the 98 apparent violations would be 
excessive here.  Based on all the circumstances and after 
examining forfeiture actions in other recent underwriting 
cases, we believe that a proposed forfeiture of $7,500 is 
appropriate here.40  

     16.  Accordingly, applying the Forfeiture Policy 
Statement and the statutory factors to this case, we 
conclude that Minority is apparently liable for a forfeiture 
in the amount of $7,500, for violating the Commission's 
underwriting rules.  We will not hesitate to take even 
stronger enforcement action against noncommercial 
educational licensees that engage in similarly serious 
violations of our underwriting requirements.


     17.    In view of the foregoing, we conclude that a 
monetary sanction is appropriate.  Accordingly, 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, Minority Television Project, Inc., 
licensee of noncommercial educational Station KMTP-TV, San 
Francisco, California, is hereby NOTIFIED of its APPARENT 
LIABILITY FOR A FORFEITURE in the amount of $7,500 for 
willfully and repeatedly broadcasting advertisements in 
violation of section 399B of the Act, 47 U.S.C.  399b, and 
section 73.621 of the Commission's rules, 47 C.F.R.  

     18.  IT IS FURTHER ORDERED, pursuant to section 1.80 of 
the Commission's rules, that within thirty days of the 
release of this Notice, Minority SHALL PAY the full amount 
of the proposed forfeiture or SHALL FILE a written statement 
seeking reduction or cancellation of the proposed 

     19.  Payment of the forfeiture must be made by mailing 
a check or similar instrument, payable to the order of the 
Federal Communications Commission.  The payment must include 
the NAL Acct. No. and FRN referenced above.  Payment by 
check or money order may be mailed to Forfeiture Collection 
Section, Finance Branch, Federal Communications Commission, 
P.O. Box 73482, Chicago, Illinois 60673-7482.  Payment by 
overnight mail may be sent to Bank One/LB 73482, 525 West 
Monroe, 8th Floor Mailroom, Chicago, Illinois 60601.  
Payment by wire transfer may be made to ABA Number 
071000013, receiving bank Bank One, and account number 

     20.  The response, if any, must be mailed to William H. 
Davenport, Chief, Investigations and Hearings Division, 
Enforcement Bureau, Federal Communications Commission, 445 
12th Street, S.W, Room 4-C330, Washington D.C. 20554 and 
MUST INCLUDE the NAL/Acct. No. referenced above.

     21.  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 

     22.  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. 20554.41

     23.  IT IS ALSO ORDERED that the complaint filed by 
Lincoln Broadcasting Company IS GRANTED to the extent 
indicated herein and IS OTHERWISE DENIED, and the complaint 

     24.  IT IS FURTHER ORDERED that a copy of this Notice 
shall be sent, by Certified Mail/Return Receipt Requested, 
to Minority Television Project, Inc., c/o its attorney, 
James L. Winston, Esq., Rubin, Winston, Diercks, Harris & 
Cooke, L.L.P., Sixth Floor, 1155 Connecticut Avenue, N.W., 
Washington, D.C.  20036, and by regular mail to Lincoln 
Broadcasting Company, c/o its attorney, Michael D. Berg, 
Esq., Law Offices of Michael D. Berg, 1730 Rhode Island 
Avenue, N.W., Suite 200, Washington, D.C. 20036. 


                         David H. Solomon
                         Chief, Enforcement Bureau

1 See 47 U.S.C.  399b.

2 See 47 C.F.R.  73.621.

3 See Reply of Lincoln Broadcasting Company, in File Nos. EB 
00-IH-0153 and 01-IH-0652, dated April 17, 2002 (``April 
17th Reply'').

4 Id. 

5 See Letter from Maureen F. Del Duca, Chief, Investigations 
and Hearings Division, Enforcement Bureau, to Minority 
Television Project, Inc., dated July 11, 2003 (``July 11th 

6 See Letter from Minority Television Project, Inc. to 
Maureen F. Del Duca, Chief, Investigations and Hearings 
Division, Enforcement Bureau, dated August 19, 2003 
(``August 19th Response''); see also Reply of Lincoln 
Broadcasting Company, dated October 31, 2003  (``October 
31st Reply''); Letter from William D. Freedman, Deputy 
Chief, Investigations and Hearings Division, Enforcement 
Bureau, to Minority Television Project, Inc., dated July 14, 
2004 (``July 14th LOI''); Letter from Minority Television 
Project, Inc. to William D. Freedman, Deputy Chief, 
Investigations and Hearings Division, Enforcement Bureau, 
dated July 28, 2004 (``July 28th Response''); Reply of 
Lincoln Broadcasting Company, dated August 12, 2004 
(``August 12th Reply''); Letter from William D. Freedman, 
Deputy Chief, Investigations and Hearings Division, 
Enforcement Bureau, to Minority Television Project, Inc., 
dated August 24, 2004 (``August 24th LOI''); Letter from 
Minority Television Project, Inc. to William D. Freedman, 
Deputy Chief, Investigations and Hearings Division, 
Enforcement Bureau, dated August 31, 2004 (``August 31st 
Response''); Reply of Lincoln Broadcasting Company, dated 
September 15, 2004 (``September 15th Reply'').

747 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'' 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.

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

9 47 U.S.C.  399b(a).

10 Id.

11 Commission Policy Concerning the Noncommercial Nature of 
Educational Broadcasting Stations, Public Notice (1986), 
republished, 7 FCC Rcd 827 (1992) (``Public Notice'').  

12 Id.

13   See  Xavier  University, Letter  of Admonition,  issued 
November  14,   1989  (Mass  Med.  Bur.),   recon.  granted, 
Memorandum Opinion and Order, 5 FCC Rcd 4920 (1990).

14 See August 19th Response at Attachment A.

15 The ``good-faith'' standard for licensee discretion is 
set forth by the Commission in Xavier, supra.
16 August 19th Response at 2-4.

17 Id.  Minority does acknowledge, however, that the 
announcement for Star Cruises included the expression 
``please call.''  Id. at 5.

18 Id. at 6.

19 August 31st Response at 2.  

20 Id. at 2, n. 2.

21 See Letter of Minority Broadcast Television Project, 
Inc., to Charles W. Kelley, Chief, Investigations and 
Hearings Division, dated December 20, 2001, in Enforcement 
Bureau proceedings numbered EB-00-IH-0153 and EB-01-IH-0652 
(``December 20th Response''), at 2; see also September 15th 
Reply at 6-9.  For the reasons set forth, infra, we find 
that Minority made the announcements at issue in exchange 
for consideration.  The manner in which the licensee 
received such payments from its program suppliers and 
underwriters, whether annually in a lump-sum, or on a per-
spot basis, is of no consequence to our analysis. 

22 See August 19th Response at 6-7.

23 Id. at 3.

24 See, e.g., Minority Television Project, Inc. (KMTP-TV), 
Notice of Apparent Liability for Forfeiture, 17 FCC Rcd 
15646 (Enf. Bur. 2002), Forfeiture Order, 18 FCC Rcd 26611 
(2003), application for review denied, Order on Review, 
___FCC Rcd ___ FCC 04-293 (rel. Dec. 23, 2004), recon. 
pending, citing Tri-State Inspirational Broadcasting 
Corporation, Memorandum Opinion and Order, 16 FCC Rcd 16800 
(Enf. Bur. 2001); Penfold Communications, Inc., supra.

25 August 19th Response at 3.

26 Id.

27 See, e.g., Minority Television Project, Inc. (KMTP-TV), 
supra, 17 FCC Rcd 15646, 15653 at  21, citing Board of 
Education of New York (WNYE-TV), 7 FCC Rcd 6864, 6865 (Mass 
Media Bur. 1992).

28 August 19th Response at 4 and Attachment C-1.

29 Id. at Attachment D.

30 Id.

31 See Commission Policy Concerning the Noncommercial Nature 
of Educational Broadcast Stations, Report and Order, 90 FCC 
2d 895 (1982), recon., 97 FCC 2d 255 (1984) (``1982 Policy 
Statement'');   Commission Policy Concerning the 
Noncommercial Nature of Educational Broadcasting Stations, 
Report and Order, 86 FCC 2d 141, 148 (1981) (consideration 
is broadly construed and may be deemed to include general 
contributions made to licensees) (``Second Report and 

32 47 U.S.C.  399b(a)(1) specifically provides: ``for 
purposes of this section, the term `advertisement' means any 
message or other programming material which is broadcast or 
otherwise transmitted in exchange for any remuneration, and 
which is intended to promote any service, facility or 
product offered by any person who is engaged in such 
offering for profit.''

33 1982 Policy Statement, 90 FCC 2d at 911-12,  26-28.  

34 August 19th Response at Attachments B-2, B-3; C-2, C-3; 
July 28th Response at Attachments B-2, B-3; C-2, C-3.    
35 Id.  In similar cases, the Commission has rejected 
arguments that such payments constituted general station 
contributions unrelated to the broadcast of underwriting 
announcements made on behalf of the donors involved.  See, 
e.g., Penfold Communications, Inc., supra.

36 See August 19th Response at 6-7.

37 See 47 U.S.C.  503(b); 47 C.F.R  1.80.

38 The Commission's Forfeiture Policy Statement and 
Amendment of Section 1.80 of the Rules to Incorporate the 
Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087, 
17115 (1997), recon. denied, 15 FCC Rcd 303 (1999) 
(``Forfeiture Policy Statement''); 47 C.F.R.  1.80(b).

39  47 U.S.C.   503(b)(2)(D).   See also  Forfeiture Policy 
Statement, 12 FCC Rcd at 17100  27.

40  See, e.g., Christian Voice of Central Ohio, 
Inc.(WCVZ(FM)), 19 FCC Rcd 23663 (Enf. Bur. 2004) ($20,000 
forfeiture proposed for underwriting violations), response 
pending; Minority Television Project, Inc. (KMTP-TV), supra 
($10,000 forfeiture imposed for underwriting violations).
41 See 47 C.F.R.  1.1914.

42For purposes of the forfeiture proceeding initiated by 
this NAL, Minority Television Project, Inc. shall be the 
only party to this proceeding.