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Federal Communications Commission
Washington, D.C. 20554
In the Matter of File No. EB-09-IH-1219
NTS Communications, Inc. NAL/Acct. No. 201032080024
Apparent Liability for Forfeiture FRN No. 0004266938
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: May 4, 2010 Released: May 6, 2010
By the Commission:
1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
that NTS Communications, Inc. ("NTS"), apparently violated section
254(d) of the Communications Act of 1934, as amended (the "Act"), and
section 54.706(a) of the Commission's rules, by willfully or
repeatedly failing to contribute fully and timely to the Universal
Service Fund ("USF"). Based on our review of the facts and
circumstances surrounding this matter, and for the reasons discussed
below, we find that NTS is apparently liable for a total forfeiture of
$284,250. We find this significant forfeiture is warranted based on
NTS's repeated failures to satisfy its obligations to the USF,
spanning well over a year and amounting to a delinquency of more than
$248,000 to the Fund.
2. We order NTS to submit within thirty days a report, supported by a
sworn statement or declaration under penalty of perjury of a corporate
officer, setting forth in detail its plan to come into compliance with
the payment obligations discussed herein.
3. The Act codifies Congress's historic commitment to promote universal
service to ensure that consumers in all regions of the nation have
access to affordable, quality telecommunications services. In
particular, section 254(d) of the Act requires, among other things,
that "[e]very telecommunications carrier [providing] interstate
telecommunications services . . . contribute, on an equitable and
nondiscriminatory basis, to the specific, predictable, and sufficient
mechanisms established by the Commission to preserve and advance
universal service." In implementing this Congressional mandate, the
Commission directed all telecommunications carriers providing
interstate telecommunications services and certain other providers of
interstate telecommunications to register with the Commission, comply
with annual and quarterly filing requirements, and contribute to the
universal service fund based upon their interstate and international
end-user telecommunications revenues. The Universal Service
Administrative Company ("USAC") currently administers the USF. USAC
uses the revenue projections submitted on the quarterly filings to
determine each carrier's monthly universal service contribution
amount, and bills them accordingly each month. Consistent with the
Debt Collection Improvement Act of 1996 ("DCIA"), USF contributions
that have become over 90 days delinquent are transferred to the
Commission for further action to collect the outstanding debt. Failure
by some providers to pay their share into the USF skews the playing
field by giving them an economic advantage over their competitors, who
must then shoulder more than their fair share of the costs of
4. The Commission has established specific procedures for the
administration of the USF and other associated federal regulatory
programs. Pursuant to section 54.711(a) of the Commission's rules, a
carrier is required to file FCC Form 499-A, also known as the annual
Telecommunications Reporting Worksheet ("annual Worksheet" or "Form
499-A"), for the purpose of determining its USF, Telecommunications
Relay Services Fund ("TRS Fund"), Local Number Portability ("LNP"),
and North American Numbering Plan ("NANP") administration and
regulatory fee payments, and, with certain exceptions, to file
Quarterly Telecommunications Reporting Worksheets ("quarterly
Worksheet" or "Form 499-Q") to determine its monthly universal service
contribution amounts. These periodic filings trigger a determination
of liability, if any, and subsequent billing and collection by the
administer the regulatory programs. Carriers must timely pay their
contribution invoices, and the Commission's rules explicitly warn
contributors that failure to file forms or submit payments potentially
subjects them to enforcement action.
5. NTS is a Texas-based company that has provided telecommunications
services since 1981. Through subsidiaries, NTS provides
facilities-based and resold long distance, private line, frame relay,
ATM, and toll-free telecommunications services. NTS is owned by Xfone,
6. In July 2009, USAC referred NTS to the Enforcement Bureau (the
"Bureau") for potential enforcement action, alleging that NTS had
failed to comply with the Commission's USF contribution rules. The
Bureau initiated an investigation against NTS on July 31, 2009,
issuing a letter of inquiry ("LOI") to NTS seeking information about
its compliance with USF and other related regulatory obligations.
NTS's LOI Response indicates that it failed to pay certain USAC
invoices in full and on time. Specifically, NTS failed on two
occasions to pay any contribution toward its outstanding USF
obligations, and it made only partial payments toward its USF
obligations on twelve additional occasions.
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 forfeiture
penalty. 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. 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, and the
Commission has so interpreted the term in the section 503(b) context.
The Commission may also assess a forfeiture for violations that are
merely repeated, and not willful. "Repeated" means that the act was
committed or omitted more than once, or lasts more than one day. To
impose such a forfeiture penalty, the Commission must issue a notice
of apparent liability, 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. The Commission will then issue a
forfeiture if it finds, based on the evidence, that the person has
violated the Act or a Commission rule. As set forth below, we conclude
that NTS is apparently liable for forfeiture for its apparent willful
and repeated violations of section 254(d) of the Act and section
54.706(a) of the Commission's rules.
8. The fundamental issue in this case is whether NTS apparently violated
the Act and the Commission's rules by willfully or repeatedly failing
to make required contributions to the USF. We answer this question in
the affirmative. Based on the facts and circumstances before us, we
therefore conclude that NTS is apparently liable for a forfeiture of
A. NTS Apparently Failed To Make Full and Timely Universal Service Fund
9. We conclude that NTS has apparently violated section 254(d) of the Act
and section 54.706 of the Commission's rules by willfully and
repeatedly failing to contribute fully and timely to the universal
service support mechanisms. Section 54.706(a) of the Commission's
rules unambiguously directs that "entities [providing] interstate
telecommunications to the public . . . for a fee . . . contribute to
the universal service support mechanisms." "Interstate
telecommunications" include, among other things, "private line
service," "toll-free service," and "resale of interstate services"
such as those provided by NTS. NTS acknowledges that it was required
to make USF contributions at all relevant times.
10. NTS failed to make any payment on its USF invoice for the payment due
in February 2009, made only partial payments toward its outstanding
balance from March to November 2009, then failed to make any payment
toward its balance in December 2009. NTS resumed making partial
payments toward its outstanding balance in January 2010. NTS claims it
was not able to make full payments to the USF because of financial
difficulties. We do not credit this argument. During the same period
of time, the company continued to collect USF surcharges from its
customers and it continued to receive disbursement credits from the
USF. As a result of its failures to pay, NTS has maintained large
outstanding USF balances with USAC since early 2009, and as of March
22, 2010, had a past due balance of more than $248,000. NTS does not
dispute that it is obligated to pay the invoiced amounts or that it
has failed to pay the full balance due to the USF. Based on the record
developed in our investigation, we find that NTS has apparently
violated section 254(d) of the Act and section 54.706 of the
Commission's rules by willfully and repeatedly failing to contribute
fully and timely to the USF since February 2009.
B. Proposed Forfeiture Amount
11. Section 503(b)(1) of the Act provides that any person who willfully or
repeatedly fails 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. Section 503(b)(2)(B) of the
Act authorizes the Commission to assess a forfeiture of up to $150,000
for each violation or each day of a continuing violation, up to a
statutory maximum of $1,500,000 for a single act or failure to act. In
determining the appropriate forfeiture amount, we consider the factors
enumerated in section 503(b)(2)(E) of the Act, including "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," as well as our forfeiture guidelines.
12. We find that NTS failed to make payments to the USF in February and
December 2009, and it made only partial payments on a total of twelve
occasions - between March and November 2009 and between January and
March 2010. Nonpayment of universal service contributions is an
egregious offense. It not only deprives the USF of resources necessary
to preserve and advance universal service, but it also bestows on
delinquent entities an unfair competitive advantage by shifting to
compliant contributors the economic costs and burdens associated with
universal service. An entity's failure to make required universal
service contributions frustrates Congress's policy objective in
section 254(d) of the Act to ensure the equitable and
non-discriminatory distribution of universal service costs among all
telecommunications providers. The Commission has established a base
forfeiture amount of $10,000 for each month in which a contributor has
failed to fully pay required universal service contributions and
$20,000 for each month in which a contributor has failed to make any
required universal service contribution, plus an upward adjustment
based on one-half of the company's approximate unpaid contributions.
In addition, the Commission has treated failures to pay universal
service and other obligations as continuing violations. Our forfeiture
calculation therefore reflects not only violations that began within
the last twelve months, but all violations, unless they were cured
more than one year ago.
13. As a result, we find that NTS is apparently liable for willfully and
repeatedly failing to contribute fully and timely to the USF on a
total of fourteen occasions between February 2009 and March 2010.
Accordingly, we assess a $20,000 forfeiture for each of the two months
in which NTS failed to remit any contribution toward its outstanding
USF obligation. We also assess $10,000 for each of the twelve months
in which NTS contributed less than the amount of its monthly
obligation, as provided on the corresponding invoices. Thus, we find
NTS apparently liable for a base forfeiture of $160,000 for its
willful and repeated failures to contribute fully and timely to the
USF on fourteen occasions between February 2009 and the date of this
NAL. Moreover, consistent with our approach for assessing liability
for apparent USF violations, and taking into account all the factors
enumerated in section 503(b)(2)(E) of the Act, we also add an upward
adjustment of $124,250, approximately one-half of the largest amount
of NTS's unpaid USF contributions due to USAC and the FCC during the
period at issue, to the base forfeiture. We therefore find NTS
apparently liable for a forfeiture of $284,250 for its apparent
willful or repeated failures to contribute fully and timely to the
14. In light of the seriousness, duration and scope of the apparent
violations, we propose a forfeiture in the amount of $284,250 for
NTS's failure to pay its USF obligations. We caution that additional
violations of the Act or the Commission's rules could subject NTS to
further enforcement action. Such action could take the form of higher
monetary forfeitures and/or possible revocation of NTS's operating
authority, including disqualification of NTS's principals from the
provision of any interstate common carrier services without the prior
consent of the Commission.
V. ORDERING CLAUSES
15. ACCORDINGLY, IT IS ORDERED THAT, pursuant to section 503(b) of the
Communications Act of 1934, as amended, 47 U.S.C. S: 503(b), and
section 1.80 of the Commission's rules, 47 C.F.R. S: 1.80, that NTS
Communications, Inc. is hereby NOTIFIED of its APPARENT LIABILITY FOR
A FORFEITURE in the amount of $284,250 for willfully and repeatedly
violating the Act and the Commission's rules.
16. 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, NTS SHALL PAY the full amount of the
proposed forfeiture or SHALL FILE a written statement seeking
reduction or cancellation of the proposed forfeiture.
17. IT IS FURTHER ORDERED THAT NTS shall submit within thirty days of the
release date of this NOTICE OF APPARENT LIABILITY, a report supported
by a sworn statement or declaration under penalty of perjury of a
corporate officer setting forth in detail its plan to come into
compliance with the reporting and payment obligations discussed
herein. The report must be mailed to Hillary S. DeNigro, Chief,
Investigations and Hearings Division, Enforcement Bureau, Federal
Communications Commission, 445 12th Street, S.W., Suite 4-C330,
Washington, D.C. 20554. NTS shall also transmit a copy of the report
via email to firstname.lastname@example.org.
18. Payment of the forfeiture must be made by check or similar instrument,
payable to the order of the Federal Communications Commission. The
payment must include the NAL/Acct. No. and FRN No. referenced above.
Payment by check or money order may be mailed to Federal
Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.
Payment by overnight mail may be sent to U.S. Bank - Government
Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
63101. Payments by wire transfer may be made to ABA Number 021030004,
receiving bank Federal Reserve Bank of New York, and account number
27000001. For payment by credit card, an FCC Form 159 (Remittance
Advice) must be submitted. When completing the FCC Form 159, enter
the NAL/Account number in block number 23A (call sign/other ID), and
enter the letters "FORF" in block number 24A (payment type code). NTS
will also send electronic notification within forty-eight (48) hours
of the date said payment is made to email@example.com.
19. The response, if any, to this NOTICE OF APPARENT LIABILITY must be
mailed to Hillary S. DeNigro, 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.
20. 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
21. Requests for payment of the full amount of this Notice of Apparent
Liability under an installment plan should be sent to: Chief Financial
Officer -- Financial Operations, Federal Communications Commission,
445 12th Street, S.W., Room 1-A625, Washington, D.C. 20554. For
answers to questions, please contact the Financial Operations Group
Help Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov.
22. IT IS FURTHER ORDERED that a copy of this NOTICE OF APPARENT LIABILITY
FOR FORFEITURE shall be sent by certified mail, return receipt
requested, to NTS Communications, Inc., Barbara Baldwin, Chief
Executive Officer, 5307 W. Loop 289, Lubbock, TX 79414.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
47 U.S.C. S: 254(d).
47 C.F.R. S:S: 54.706(a).
47 U.S.C. S: 254(d).
47 C.F.R. S:S: 54.706(b), 54.711, 64.1195. See also 47 U.S.C. S: 254(d)
("Any other provider of interstate telecommunications may be required to
contribute to the preservation and advancement of universal service if the
public interest so requires."). Contributions are based on a contributor's
projected revenues, and individual universal service contribution amounts
that are based upon quarterly filings are subject to an annual true-up.
Id.; 47 C.F.R. S: 54.709(b).
47 C.F.R. S: 54.701(a).
See 47 C.F.R. S: 54.709.
See Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110
Stat. 1321, 1358 (1996). Pursuant to the "red light rule," the Commission
withholds action on applications or other requests for benefits by
delinquent debtors and ultimately dismisses such applications or other
requests if the delinquency is not resolved. See 47 C.F.R. S: 1.1910.
Invoices for USF contributions that become over 90 days delinquent are
transferred to the Commission for further collection. See
Debt collection procedures may include further administrative efforts both
by the Commission and the United States Treasury or, as appropriate, the
Commission may refer the delinquent debt to the Department of Justice for
enforced collection action. 47 C.F.R. S: 1.1917. Collection efforts may
result in additional charges, to include interest and penalties, as
provided under 31 U.S.C. S: 3717, and administrative charges pursuant to
47 C.F.R. S:S: 1.1940 and 54.713, 31 C.F.R. S: 285.12(j).
See FCC Form 499-A Telecommunications Reporting Worksheet - Annual
Filing, http://www.fcc.gov/Forms/Form499-A/499a-2009.pdf (February 2009)
See Federal-State Joint Board on Universal Service, Petition for
Reconsideration filed by AT&T, Report and Order and Order on
Reconsideration, 16 FCC Rcd 5748 (2001) ("Quarterly Reporting Order").
Carriers report their revenues for the prior quarter by the beginning of
the second month in each quarter (i.e., February 1, May 1, August 1, and
November 1). See Quarterly Reporting Order, 16 FCC Rcd at 5755, P: 19 &
n.32. See also FCC Form 499-Q Telecommunications Reporting Worksheet -
Quarterly Filing for Universal Service Contributors,
http://www.fcc.gov/Forms/Form499-Q/499q.pdf (April 2009) ("Quarterly
See 47 C.F.R. S: 54.709.
See 47 C.F.R. S: 54.711(a) ("The Commission shall announce by Public
Notice published in the Federal Register and on its website the manner of
payment and the dates by which payments must be made."); "Proposed Second
Quarter 2006 Contribution Factor," Public Notice, 21 FCC Rcd 2379
(Wireline Comp. Bur. 2006) ("Contribution payments are due on the date
shown on the invoice."). See also 47 C.F.R. S: 54.713(b) (noting that if a
USF "contributor fails to make full payment on or before the date due of .
. . the monthly invoice provided by the Administrator, the payment is
delinquent."). Id. The Act and our rules, however, do not condition
payment on receipt of an invoice or other notice from USAC or other fund
administrator. See 47 U.S.C. S: 254(d); 47 C.F.R. S:S: 54.706(b) and
64.604(c)(5)(iii)(A). A carrier that does not file may not receive an
invoice from USAC, but is nonetheless required to contribute to the USF,
unless its revenues are considered de minimis. See Globcom, Inc., Notice
of Apparent Liability, 18 FCC Rcd 19890, 19896, P: 5, n.22 (2003)
("Globcom NAL") (subsequent history omitted). The instructions for the
Worksheet include tables for carriers to determine their annual
contributions. Providers whose annual contribution is less than $10,000
are considered de minimis and exempted from contributing to the USF. 47
C.F.R. S: 54.708.
See 47 C.F.R. S: 54.713.
See Response of NTS Communications, Inc. to the Enforcement Bureau's July
31, 2009 Letter of Inquiry, dated August 31, 2009, at response to
Questions 1 and 2 ("LOI Response").
Id. at response to Question 4(b).
Id. at response to Question 4(c).
Letter from Trent B. Harkrader, Deputy Chief, Investigations & Hearings
Division, Enforcement Bureau, FCC, to Barbara Baldwin, Chief Executive
Officer, NTS Communications, Inc., dated July 31, 2009 ("LOI").
See LOI Response at response to Question 9.
47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(1); see also 47 U.S.C. S:
503(b)(1)(D) (forfeitures for violation of 14 U.S.C. S: 1464).
47 U.S.C. S: 312(f)(1).
H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).
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.").
See, e.g., Callais Cablevision, Inc., Grand Isle, Louisiana, Notice of
Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359, 1362, P: 10
(2001) ("Callais Cablevision") (issuing a Notice of Apparent Liability
for, inter alia, a cable television operator's repeated signal leakage).
Southern California Broadcasting Co., 6 FCC Rcd at 4388, P: 5; Callais
Cablevision, Inc., 16 FCC Rcd at 1362, P: 9.
47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).
See, e.g., SBC Communications, Inc., Apparent Liability for Forfeiture,
Forfeiture Order, 17 FCC Rcd 7589, 7591, P: 4 (2002) (forfeiture paid).
47 U.S.C. S: 254(d).
47 C.F.R. S:S: 54.706(a).
47 U.S.C. S: 254(d); 47 C.F.R. S: 54.706(a).
47 C.F.R. S: 54.706(a).
See LOI Response at response to Question 9 and pp. 8-9.
LOI Response at Exhibit E, Response to Item No. 9.
The violations continued with each subsequent day on which NTS failed to
make full payment. See Globcom, Inc., Order of Forfeiture, 21 FCC Rcd
4710, 4723, P: 35 n.105 (2006) ("Globcom Forfeiture Order") ("Each failure
to pay the amount due each month constituted a violation that continued
for more than 10 days."). USAC's practice is to apply partial payments to
the oldest debt carried on USAC's books first, and not the current billed
amount. See North American Telephone Network, LLC, Forfeiture Order, 16
FCC Rcd 4836, 4838, P: 8 n.12 (2001); Intellicall Operator Services,
Forfeiture Order, 15 FCC Rcd 21771, 21772, P: 6 n.8. This practice was
codified by the Commission in 2007. See Comprehensive Review of the
Universal Service Fund Management, Administration, and Oversight;
Federal-State Joint Board on Universal Service; Schools and Libraries
Universal Service Support Mechanism; Lifeline and Link Up; Changes to the
Board of Directors for the National Exchange Carrier Association, Inc.,
Report and Order, 22 FCC Rcd 16372, 16380-81, P: 16 (2007); 47 C.F.R. S:
54.713(e). Each violation is considered continuing until cured by full
payment of each monthly obligation, as provided on the corresponding
invoices. See Telrite Corp., Notice of Apparent Liability for Forfeiture
and Order, 23 FCC Rcd 7231, 7238-39, P: 15 (2008) ("Telrite NAL"); Compass
Global, Inc., Notice of Apparent Liability for Forfeiture, 23 FCC Rcd
6125, 6140, P: 33 (2008) ("Compass Global NAL"); Global Crossing North
America, Inc., Notice of Apparent Liability for Forfeiture, 23 FCC Rcd
6110, 6122, P:P: 25-27 (2008) ("Global Crossing NAL"); VCI Company, Notice
of Apparent Liability for Forfeiture and Order, 22 FCC Rcd 15933, 15940,
P: 24 & n.69 (2007) ("VCI NAL"); Matrix Telecom, Inc., Notice of Apparent
Liability, 15 FCC Rcd 13544 (2000); Conquest Operator Services Corp.,
Order of Forfeiture, 14 FCC Rcd 12518, 12525, P: 16 (1999).
See LOI Response at response to Question 9.
47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(2).
47 U.S.C. S: 503(b)(2)(B); see also 47 C.F.R. S: 1.80(b)(2); Amendment of
Section 1.80(b) of the Commission's Rules, Adjustment of Forfeiture Maxima
to Reflect Inflation, Order, 15 FCC Rcd 18221 (2000).
47 C.F.R. S: 1.80(b)(4), Note, Guidelines for Assessing Forfeitures.
See supra para. 10.
See 47 U.S.C. S: 254(d).
See OCMC, Inc., Order of Forfeiture, 21 FCC Rcd 10479, 10482, P: 10 (2006)
("OCMC Forfeiture Order"); Globcom NAL, 18 FCC Rcd at 19903-04, P:P:
25-27; Globcom Forfeiture Order, 21 FCC Rcd at 4721-24, P:P: 31-38.
See, e.g., Globcom Forfeiture Order, 21 FCC Rcd at 4722, P: 33; OCMC
Forfeiture Order, 21 FCC Rcd at 10482, P: 10.
See, e.g. Global Crossing NAL, 23 FCC Rcd at 6120-21, P:P: 21-24
(proposing $10,518,013 forfeiture for, inter alia, the apparent failure to
make required universal service contributions); Telrite NAL, 23 FCC Rcd at
7245-46, P: 36 (proposing $924,212 forfeiture for, inter alia, the
apparent failure to make required universal service contributions);
Compass Global NAL, 23 FCC Rcd at 6140-42, P:P: 34-38 (proposing
$828,613.44 forfeiture for, inter alia, the apparent failure to make
required universal service contributions).
These months consist of February 2009 and December 2009. See supra para.
These months consist of March to November 2009 and January to March 2010.
See supra para. 10.
See supra para. 10.
NTS continues to have an unpaid outstanding balance due to USAC. We note
that payment of the forfeiture proposed in this NAL does not absolve NTS
of its obligation to pay its delinquent balance due to the USF. As
discussed supra at note 8, debt collection procedures may include further
administrative efforts both by the Commission and by the United States
Treasury or, as appropriate, the Commission may refer the delinquent debt
to the Department of Justice for enforced collection action. 47 C.F.R. S:
See Business Options, Inc., Consent Decree, 19 FCC Rcd 2916 (2003); NOS
Communications, Inc., Affinity Network Incorporated and NOSVA Limited
Partnership, Consent Decree, 2003 WL 22439710 (2003).
See 47 C.F.R. S: 1.1914.
Federal Communications Commission FCC 10-78
Federal Communications Commission FCC 99-xx