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                      WASHINGTON, D.C. 20554
                        December 20, 2005


Global Business Acquisitions, Inc.
Attn: Johannah Seelig, President
2301 S. Congress Avenue, Apt. 222
Boynton Beach, Florida  33426

          RE:  EB-05-TC-080

Dear Ms. Seelig:

     This is an official CITATION, issued pursuant to section 
503(b)(5) of the Communications Act of 1934, as amended (the 
Act), 47 U.S.C.  503(b)(5), for violations of the Act and the 
Federal Communications Commission's rules that govern telephone 
solicitations and unsolicited advertisements.1  As explained 
below, future violations of the Act or Commission's rules in this 
regard may subject you and your company to monetary forfeitures.

     It has come to our attention that your company, acting under 
your direction, apparently sent one or more unsolicited 
advertisements to telephone facsimile machines in violation of 
Section 227(b)(1)(C) of the Communications Act, as described in 
the attached complaint(s).2 Section 227(b)(1)(C) makes it 
``unlawful for any person within the United States, or any person 
outside the United States if the recipient is within the United 
States . . . to use a telephone facsimile machine, computer, or 
other device to send an unsolicited advertisement to a  telephone 
facsimile machine.'' 3   The term ``unsolicited advertisement'' 
is defined in the Act and the Commission's rules as ``any 
material advertising the commercial availability or quality of 
any property, goods, or services which is transmitted to any 
person without that person's prior express invitation or 
permission.''4  Under Commission rules and orders currently in 
effect, the Commission considers an established business 
relationship between a fax sender and recipient to constitute 
prior express invitation or permission to send a facsimile 
advertisement.5  Mere distribution or publication of a fax 
number, however, does not establish consent to receive 
advertisements by fax.6

     If, after receipt of this citation, you or your company 
violate the Communications Act or the Commission's rules in any 
manner described herein, the Commission may impose monetary 
forfeitures not to exceed $11,000 for each such violation or each 
day of a continuing violation. 

     You may respond to this citation within 30 days from the 
date of this letter either through (1) a personal interview at 
the Commission's Field Office nearest to your place of business, 
or (2) a written statement.  Your response should specify the 
actions that you are taking to ensure that you do not violate the 
Commission's rules governing telephone solicitation and 
unsolicited advertisements, as described above.  
     The nearest Commission field office appears to be the Tampa 
Office, Tampa, Florida; however, please contact Al McCloud at 
(202) 418-2499 if you wish to schedule a personal interview.  You 
should schedule any interview to take place within 30 days of the 
date of this letter.  You should send any written statement 
within 30 days of the date of this letter to: 

               Kurt A. Schroeder
               Deputy Chief
                                    Telecommunications Consumers 
               Enforcement Bureau
               Federal Communications Commission
               445-12th Street, S.W., Rm. 4-C222
               Washington, D.C.  20554
Reference EB-05-TC-080 when corresponding with the Commission.

     Reasonable accommodations for people with disabilities are 
available upon request.  Include a description of the 
accommodation you will need including as much detail as you can.  
Also include a way we can contact you if we need more 
information.  Please allow at least 5 days advance notice; last 
minute requests will be accepted, but may be impossible to fill.  
Send an e-mail to or call the Consumer & 
Governmental Affairs Bureau:

          For sign language interpreters, CART, and other 
reasonable accommodations: 
     202-418-0530 (voice), 202-418-0432 (tty);

          For accessible format materials (braille, large print, 
electronic files, and audio 
     format): 202-418-0531 (voice), 202-418-7365 (tty). 

     Under the Privacy Act of 1974, 5 U.S.C.  552(a)(e)(3), we 
are informing you that the Commission's staff will use all 
relevant material information before it, including information 
that you disclose in your interview or written statement, to 
determine what, if any, enforcement action is required to ensure 
your compliance with the Communications Act and the Commission's 

     The knowing and willful making of any false statement, or 
the concealment of any material fact, in reply to this citation 
is punishable by fine or imprisonment under 18 U.S.C.  1001.

     Thank you in advance for your anticipated cooperation.


                         Kurt A. Schroeder
                         Deputy Chief, Telecommunications 
                         Consumers Division
                         Enforcement Bureau
                         Federal Communications Commission


Copy to: General Counsel Advisors, P.A., Registered Agent 
        Attn: Kenneth Gluckman, President
        1001 N. Lake Destiny Road, Suite 300
        Maitland, Florida  32751

1 47 U.S.C.  227; 47 C.F.R.  64.1200.  A copy of these 
provisions is enclosed for your convenience.  Section 227 was 
added to the Communications Act by the Telephone Consumer 
Protection Act of 1991 and is most commonly known as the TCPA.  
The TCPA and the Commission's parallel rules restrict a variety 
of practices that are associated with telephone solicitation and 
use of the telephone network to deliver unsolicited 
advertisements, including fax advertising.

2 We have attached the 98 complaints at issue in this letter.

3 47 U.S.C.  227(b)(1)(C); see also 47 C.F.R.  64.1200(a)(3) 
(providing that no person or entity may . . . use a telephone 
facsimile machine, computer, or other device to send an 
unsolicited advertisement to a telephone facsimile machine).  
Both the TCPA and the Commission's rules define ``telephone 
facsimile machine'' as ``equipment which has the capacity to 
transcribe text or images, or both, from paper into an electronic 
signal and to transmit that signal over a regular telephone line, 
or to transcribe text or images (or both) from an electronic 
signal received over a regular telephone line onto paper.'' 47 
U.S.C.  227(a)(2); 47 C.F.R.  64.1200(f)(8).  The Commission 
has stated that ``[t]he TCPA's definition of `telephone facsimile 
machine' broadly applies to any equipment that has the capacity 
to send or receive text or images.''  Thus, ``faxes sent to 
personal computers equipped with, or attached to, modems and to 
computerized fax servers are subject to the TCPA's prohibition on 
unsolicited faxes. . . [although] the prohibition does not extend 
to facsimile messages sent as email over the Internet.'' Rules 
and Regulations Implementing the Telephone Consumer Protection 
Act of 1991, Report and Order, 18 FCC Rcd 14014, 14131-32 (2003) 
(2003 TCPA Report and Order).

4 47 U.S.C.  227(a)(4); 47 C.F.R.  64.1200(f)(10).
5 See Rules and Regulations Implementing the Telephone Consumer 
Protection Act of 1991, Memorandum Opinion and Order, 10 FCC Rcd 
12391, 12405 (1995) (1995 TCPA Reconsideration Order);  see also 
Rules and Regulations Implementing the Telephone Consumer 
Protection Act of 1991, Order, FCC 05-132 (rel. June 27, 2005).  
Under the recently enacted Junk Fax Prevention Act of 2005, Pub. 
L. 109-21, 119 Stat. 359 (2005), Congress amended the 
Communications Act to specify, among other things, the conditions 
under which an established business relationship provides an 
exception to the prohibition on unsolicited fax advertising.

6 1995 Reconsideration Order, 10 FCC Rcd at 12408-09; see also 
2003 TCPA Report and Order, 18 FCC Rcd at 14128 (concluding that 
mere publication of a fax number in a trade publication or 
directory does not demonstrate consent to receive fax