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Federal Communications Commission
Washington, DC 20554
In the Matter of FTTH Communications, LLC ) ) ) ) ) File No.:
EB-10-IH-4243 Acct. No.: 201332080009 FRN: 0007719230
Adopted: May 14, 2013 Released: May 14, 2013
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered into
between the Enforcement Bureau (Bureau) of the Federal Communications
Commission (Commission) and FTTH Communications, LLC (FTTH). The
Consent Decree resolves and terminates the Bureau's investigation into
FTTH's compliance with Section 214 of the Communications Act of 1934,
as amended (Act),^ and Section 63.18 of the Commission's rules
(Rules)^ pertaining to authorization to provide facilities-based and
resold international common carrier communications services.
2. A copy of the Consent Decree that the Bureau and FTTH negotiated is
attached hereto and incorporated herein by reference.
3. After reviewing the terms of the Consent Decree and evaluating the
facts before us, we find that the public interest would be served by
adopting the Consent Decree and terminating the investigation.
4. In the absence of material new evidence relating to this matter, we
conclude that our investigation raises no substantial or material
questions of fact as to whether FTTH possesses the basic
qualifications, including those related to character, to hold or
obtain any Commission license or authorization.
5. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i) and 503(b)
of the Act,^ and Sections 0.111 and 0.311 of the Rules,^ the Consent
Decree attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS
7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
shall be sent by first class mail and certified mail, return receipt
requested, to Jeffrey Feldman, Chief Executive Officer, FTTH
Communications, LLC, 2930 146^th Street W, Rosemount, MN 55068.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Federal Communications Commission
Washington, D.C. 20554
In the Matter of FTTH Communications, LLC ) ) ) ) ) File No.:
EB-10-IH-4243 Acct. No.: 201332080009 FRN: 0007719230
1. The Enforcement Bureau of the Federal Communications Commission and
FTTH Communications, LLC, by their authorized representatives, hereby
enter into this Consent Decree for the purpose of terminating the
Enforcement Bureau's investigation into possible violations of Section
214 of the Communications Act of 1934, as amended,^ and Section 63.18
of the Commission's rules^ concerning authorization to provide
facilities-based and resold international common carrier
2. For the purposes of this Consent Decree, the following definitions
a. "Act" means the Communications Act of 1934, as amended, 47 U.S.C. S
151 et seq.
b. "Adopting Order" means an Order of the Bureau adopting the terms of
this Consent Decree without change, addition, deletion, or
c. "Bureau" means the Enforcement Bureau of the Federal Communications
d. "Commission" and "FCC" mean the Federal Communications Commission and
all of its bureaus and offices.
e. "Communications Laws" means collectively, the Act, the Rules, and the
published and promulgated orders and decisions of the Commission to
which FTTH is subject by virtue of its business activities.
f. "Compliance Plan" means the compliance obligations and program
described in this Consent Decree at paragraph 12.
g. "Covered Employees" means all employees and agents of FTTH who
perform, or supervise, oversee, or manage the performance of, duties
that relate to FTTH's responsibilities under the Communications Laws,
including Section 214 of the Act and the Rules that implement this
h. "Effective Date" means the date on which the Commission releases the
i. "FTTH" or the "Company" means FTTH Communications, LLC and its
predecessors-in-interest and successors-in-interest.
j. "Investigation" means the investigation commenced by the Bureau
regarding the Company's compliance with Section 214 of the Act and
Part 63 of the Rules concerning FTTH's obligation to obtain Commission
authorization before providing facilities-based or resold
international common carrier services.^
k. "Operating Procedures" means the standard, internal operating
procedures and compliance policies established by FTTH to implement
the Compliance Plan.
l. "Parties" means FTTH and the Bureau, each of which is a "Party."
m. "Rules" means the Commission's regulations found in Title 47 of the
Code of Federal Regulations.
n. "Section 214 Rules" means Section 214 of the Act and other
Communications Laws governing the construction, acquisition,
operation, or transmission of lines of communication, including any
Rules implementing Section 214 and any related Commission orders.
3. Section 214(a) of the Act prohibits any carrier from constructing,
extending, acquiring, or operating any line, and from engaging in
transmission through any such line, without first obtaining a
certificate of authorization from the Commission.^ While the
Commission has granted "blanket" Section 214 authority to carriers
providing domestic service,^ meaning that such carriers need not apply
to the Commission before providing domestic service, the Commission
has not done the same for providers of international
telecommunications services.^ Section 63.18 of the Rules requires any
carrier that seeks Section 214 authority "for provision of common
carrier communication services between the United States, its
territories or possessions, and a foreign point" to request such
authority by application.^ This application requirement applies to
carriers that resell the international services of another authorized
carrier, as well as to facilities-based international service
4. FTTH is a Minnesota limited liability company that provides
telecommunications services.^ FTTH is owned by Everest FTTH
Acquisition, LLC (Everest), a Delaware limited liability company based
in New Jersey. ^ ^ In 2010, Everest acquired FTTH from Rudder Capital
Corporation (Rudder), a Minnesota corporation.^ During the course of
the acquisition process, but prior to consummation of the transfer of
control of FTTH from Rudder to Everest, Everest and FTTH discovered
that FTTH had provided international telecommunications services to
its customers in Minnesota without having obtained Commission
authority to do so, as required by Section 214(a) of the Act and
Section 63.18 of the Rules.^ On January 29, 2010, FTTH filed an
application with the Commission's International Bureau (IB) for
authority to provide facilities-based and resale international
telecommunications services.^ On the same day, FTTH and Everest
jointly filed applications with the Wireline Competition Bureau and IB
for Special Temporary Authority (STA) that would permit FTTH to
provide international Section 214 services and for the transfer of
control of international Section 214 authority from FTTH to Everest.^
5. On February 2, 2010, IB granted an STA providing FTTH with
international Section 214 authority. On that same day, IB granted an
STA allowing the transfer of FTTH's international Section 214
authority from Rudder to Everest.^ On March 5, 2010, IB granted FTTH's
application for permanent authority to provide international Section
214 facilities-based and resale services, and the application for
Rudder to transfer control of Section 214 authority held by FTTH to
Everest.^ IB granted FTTH international Section 214 authority "without
prejudice to any enforcement action by the Commission for
non-compliance" with the Act or the Rules.^ Thereafter, the matter was
referred to the Bureau, which commenced its investigation. On November
1, 2010, the Bureau issued a Letter of Inquiry to Everest regarding
the matters recited above.^
6. On September 14, 2011, the Bureau issued a Notice of Apparent
Liability for Forfeiture to FTTH (FTTH NAL) for failing to obtain an
international Section 214 authorization before providing international
telecommunications service.^ The FTTH NAL proposed a $100,000
forfeiture.^ FTTH submitted financial data documenting its inability
to pay the proposed forfeiture.^
III. TERMS OF AGREEMENT
7. Adopting Order. The Parties agree that the provisions of this Consent
Decree shall be subject to final approval by the Bureau by
incorporation of such provisions by reference in the Adopting Order.
8. Jurisdiction. FTTH agrees that the Bureau has jurisdiction over it
and the matters contained in this Consent Decree and that the Bureau
has the authority to enter into and adopt this Consent Decree.
9. Effective Date; Violations. The Parties agree that this Consent Decree
shall become effective on the Effective Date as defined herein. As of
the Effective Date, the Adopting Order and this Consent Decree shall
have the same force and effect as any other Order of the Commission.
Any violation of the Adopting Order or of the terms of this Consent
Decree shall constitute a separate violation of a Commission Order,
entitling the Bureau to exercise any rights and remedies attendant to
the enforcement of a Commission Order.
10. Termination of Investigation. In express reliance on the covenants and
representations in this Consent Decree and to avoid further
expenditure of public resources, the Bureau agrees to terminate the
Investigation. In consideration for the termination of said
Investigation, FTTH agrees to the terms, conditions, and procedures
contained herein. The Bureau further agrees that in the absence of new
material evidence, the Bureau will not use the facts developed in this
Investigation through the Effective Date, or the existence of this
Consent Decree, to institute, on its own motion, any new proceeding,
formal or informal, or take any action on its own motion against FTTH
concerning the matter that was the subject of the Investigation. The
Bureau also agrees that in the absence of new material evidence it
will not use the facts developed in this Investigation through the
Effective Date, or the existence of this Consent Decree, to institute
on its own motion any proceeding, formal or informal, or take any
action on its own motion against FTTH with respect to FTTH's basic
qualifications, including its character qualifications, to be a
Commission licensee or hold Commission authorizations.
11. Compliance Officer. Within thirty (30) calendar days after the
Effective Date, FTTH shall designate a senior corporate manager with
the requisite corporate and organizational authority to serve as a
Compliance Officer and to discharge the duties set forth below. The
person designated as the Compliance Officer shall be responsible for
developing, implementing, and administering the Compliance Plan and
ensuring that FTTH complies with the terms and conditions of the
Compliance Plan and this Consent Decree. In addition to the general
knowledge of the Communications Laws necessary to discharge his/her
duties under this Consent Decree, the Compliance Officer shall have
specific knowledge of the Section 214 Rules prior to assuming his/her
12. Compliance Plan. For purposes of settling the matters set forth
herein, FTTH agrees that it shall, within sixty (60) calendar days
after the Effective Date, develop and implement a Compliance Plan
designed to ensure future compliance with the Communications Laws and
with the terms and conditions of this Consent Decree. With respect to
the Section 214 Rules, FTTH shall implement the following procedures:
a. Operating Procedures. Within sixty (60) calendar days after the
Effective Date, FTTH shall establish Operating Procedures that all
Covered Employees must follow to help ensure FTTH's compliance with
the Section 214 Rules. FTTH shall include internal procedures and
policies specifically designed to ensure that FTTH complies with the
Section 214 Rules. FTTH shall also develop a Compliance Checklist
that describes the steps that a Covered Employee must follow to
ensure compliance with the Section 214 Rules.
b. Compliance Manual. Within sixty (60) calendar days after the
Effective Date, the Compliance Officer shall develop and distribute a
Compliance Manual to all Covered Employees. The Compliance Manual
shall explain the Section 214 Rules, and set forth the Operating
Procedures that Covered Employees shall follow to help ensure FTTH's
compliance with the Section 214 Rules. FTTH shall periodically review
and revise the Compliance Manual as necessary to ensure that the
information set forth therein remains current and accurate. FTTH
shall distribute any revisions to the Compliance Manual promptly to
c. Compliance Training Program. FTTH shall establish and implement a
Compliance Training Program on compliance with the Section 214 Rules
and the Operating Procedures. As part of the Compliance Training
Program, Covered Employees shall be advised of FTTH's obligation to
report any noncompliance with the Section 214 Rules under paragraph
13 of this Consent Decree and shall be instructed on how to disclose
noncompliance to the Compliance Officer. All Covered Employees shall
be trained pursuant to the Compliance Training Program within ninety
(90) calendar days after the Effective Date. Any person who becomes a
Covered Employee at any time after the Initial Training Program shall
be trained within thirty (30) calendar days after the date such
person becomes a Covered Employee. FTTH shall repeat the compliance
training on an annual basis, and shall periodically review and revise
the Compliance Training Program as necessary to ensure that it
remains current and complete and to enhance its effectiveness.
13. Reporting Noncompliance. FTTH shall report any noncompliance with the
Section 214 Rules and the terms and conditions of this Consent Decree
within fifteen (15) calendar days after discovery of such
noncompliance. Such reports shall include a detailed explanation of
(i) each instance of noncompliance; (ii) the steps that FTTH has taken
or will take to remedy such noncompliance; (iii) the schedule on which
such remedial actions will be taken; and (iv) the steps that FTTH has
taken or will take to prevent the recurrence of any such
noncompliance. All reports of noncompliance shall be submitted to the
Chief, Investigations and Hearings Division, Enforcement Bureau,
Federal Communications Commission, Room 4-C330, 445 12th Street, SW,
Washington, DC 20554, with a copy submitted electronically to Theresa
Z. Cavanaugh at Terry.Cavanaugh@fcc.gov and Robert B. Krinsky at
Robert.Krinsky@fcc.gov. The reporting obligations set forth in this
paragraph shall expire thirty-six (36) months after the Effective
14. Compliance Reports. FTTH shall file Compliance Reports with the
Commission ninety (90) calendar days after the Effective Date, twelve
(12) months after the Effective Date, twenty-four (24) months after
the Effective Date, and thirty-six (36) months after the Effective
a. Each Compliance Report shall include a detailed description of FTTH's
efforts during the relevant period to comply with the terms and
conditions of this Consent Decree and the Section 214 Rules. In
addition, each Compliance Report shall include a certification by the
Compliance Officer, as an agent of and on behalf of FTTH, stating that
the Compliance Officer has personal knowledge that FTTH (i) has
established and implemented the Compliance Plan; (ii) has utilized the
Operating Procedures since the implementation of the Compliance Plan;
and (iii) is not aware of any instances of noncompliance with the
terms and conditions of this Consent Decree, including the reporting
obligations set forth in paragraph 13 of this Consent Decree.
b. The Compliance Officer's certification shall be accompanied by a
statement explaining the basis for such certification and shall comply
with Section 1.16 of the Rules^ and be subscribed to as true under
penalty of perjury in substantially the form set forth in Section
c. If the Compliance Officer cannot provide the requisite certification,
the Compliance Officer, as an agent of and on behalf of FTTH, shall
provide the Commission with a detailed explanation of the reason(s)
why and describe fully (i) each instance of noncompliance; (ii) the
steps that FTTH has taken or will take to remedy such noncompliance,
including the schedule on which proposed remedial actions will be
taken; and (iii) the steps that FTTH has taken or will take to prevent
the recurrence of any such noncompliance, including the schedule on
which such preventive action will be taken.
d. All Compliance Reports shall be submitted to the Chief, Investigations
& Hearings Division, Enforcement Bureau, Federal Communications
Commission, Room 4-C330, 445 12th Street, SW, Washington, DC 20554,
with a copy submitted electronically to Theresa Z. Cavanaugh at
Terry.Cavanaugh@fcc.gov and Robert B. Krinsky at
15. Termination Date. Unless stated otherwise, the requirements set forth
in paragraphs 11 through 14 of this Consent Decree shall expire
thirty-six (36) months after the Effective Date
16. Section 208 Complaints; Subsequent Investigations. Nothing in this
Consent Decree shall prevent the Commission or its delegated authority
from adjudicating complaints filed pursuant to Section 208 of the Act^
against FTTH or its affiliates for alleged violations of the Act, or
for any other type of alleged misconduct, regardless of when such
misconduct took place. The Commission's adjudication of any such
complaint will be based solely on the record developed in that
proceeding. Except as expressly provided in this Consent Decree, this
Consent Decree shall not prevent the Commission from investigating new
evidence of noncompliance by FTTH with the Communications Laws.
17. Voluntary Contribution. FTTH agrees that it will make a voluntary
contribution to the United States Treasury in the amount of fifteen
thousand dollars ($15,000.00) (Voluntary Contribution). Due to FTTH's
inability to make a lump sum payment, such Voluntary Contribution
shall be made in installments (each an Installment Payment). The first
Installment Payment in the amount of two thousand dollars ($2,000.00)
is due on June 1, 2013. The second Installment Payment in the amount
of one thousand dollars ($1,000.00) is due on July 1, 2013.
Thereafter, an Installment Payment of one thousand dollars ($1,000) is
due on the first day of each consecutive succeeding month for twelve
months. The final Installment Payment in the amount of one thousand
dollars ($1,000.00) is due on July 1, 2014 (Maturity Date). FTTH
acknowledges and agrees that upon execution of this Consent Decree,
the Voluntary Contribution and each Installment Payment shall become a
"Claim" or "Debt" as defined in 31 U.S.C. S 3701(b)(1).^ Upon an Event
of Default, all procedures for collection permitted by law may, at the
Commission's discretion, be initiated. In addition, FTTH agrees that
it will make the first and all subsequent Installment Payments in
United States Dollars without further demand or notice by the dates
specified above. FTTH shall also send electronic notification of
payment to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov and Robert
B. Krinsky at Robert.Krinsky@fcc.gov on the date said Installment
Payments are made.
18. Installment Payments must be made by check or similar instrument, wire
transfer, or credit card, and must include the NAL/Account number and
FRN referenced above. Regardless of the form of payment, a completed
FCC Form 159 (Remittance Advice) must be submitted.^ When completing
the FCC Form 159, enter the Account Number in block number 23A (call
sign/other ID) and enter the letters "FORF" in block number 24A
(payment type code). Below are additional instructions regarding the
form of payment:
* Payment by check or money order must be made payable to the order of
the Federal Communications Commission. Such payments (along with the
completed Form 159) must be mailed to Federal Communications
Commission, P.O. Box 979088, St. Louis, MO 63197-9000, or sent
via overnight mail to U.S. Bank - Government Lockbox #979088,
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.
* Payment by wire transfer must be made to ABA Number 021030004,
receiving bank TREAS/NYC, and Account Number 27000001. To complete
the wire transfer and ensure appropriate crediting of the wired funds,
a completed Form 159 must be faxed to U.S. Bank at (314) 418-4232 on
the same business day the wire transfer is initiated.
* Payment by credit card must be made by providing the required credit
card information on FCC Form 159 and signing and dating the Form 159
to authorize the credit card payment. The completed Form 159 must then
be mailed to Federal Communications Commission, P.O. Box 979088, St.
Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank -
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
Louis, MO 63101.
Questions regarding payment procedures should be addressed to the
Financial Operations Group Help Desk by phone, 1-877-480-3201, or by
19. Event of Default. FTTH agrees that an Event of Default shall occur
upon the failure by FTTH to pay the full amount of any Installment
Payment on or before the due date specified in this Consent Decree.
20. Interest, Charges for Collection, and Acceleration of Maturity Date.
After an Event of Default has occurred under this Consent Decree, the
then unpaid amount of the Voluntary Contribution shall accrue
interest, computed using the U.S. Prime Rate in effect on the date of
the Event of Default plus 4.75 percent, from the date of the Event of
Default until payment in full. Upon an Event of Default, the then
unpaid amount of the Voluntary Contribution, together with interest,
as aforesaid, any penalties permitted and/or required by the law,
including but not limited to 31 U.S.C. S 3717 and administrative
charge(s), plus the costs of collection, litigation, and attorneys'
fees, shall become immediately due and payable, without notice,
presentment, demand, protest, or notice of protest of any kind, all of
which are waived by FTTH.
21. Waivers. FTTH waives any and all rights it may have to seek
administrative or judicial reconsideration, review, appeal, or stay,
or to otherwise challenge or contest the validity of this Consent
Decree and the Adopting Order, provided the Bureau issues the Adopting
Order as defined in this Consent Decree. FTTH shall retain the right
to challenge Commission interpretation of the Consent Decree or any
terms contained herein. If either Party (or the United States on
behalf of the Commission) brings a judicial action to enforce the
terms of the Adopting Order, neither FTTH nor the Commission shall
contest the validity of the Consent Decree or the Adopting Order, and
FTTH shall waive any statutory right to a trial de novo. FTTH hereby
agrees to waive any claims it may otherwise have under the Equal
Access to Justice Act,^ relating to the matters addressed in this
22. Invalidity. In the event that this Consent Decree in its entirety is
rendered invalid by any court of competent jurisdiction, it shall
become null and void and may not be used in any manner in any legal
23. Subsequent Rule or Order. The Parties agree that if any provision of
the Consent Decree conflicts with any subsequent rule or order adopted
by the Commission (except an order specifically intended to revise the
terms of this Consent Decree to which FTTH does not expressly consent)
that provision will be superseded by such Commission rule or order.
24. Successors and Assigns. FTTH agrees that the provisions of this
Consent Decree shall be binding on its successors, assigns, and
25. Final Settlement. The Parties agree and acknowledge that this Consent
Decree shall constitute a final settlement between the Parties with
respect to the Investigation. The Parties further agree that this
Consent Decree does not constitute either an adjudication on the
merits or a factual or legal finding or determination regarding any
compliance or noncompliance with the Communications Laws.
26. Modifications. This Consent Decree cannot be modified without the
advance written consent of both Parties.
27. Paragraph Headings. The headings of the paragraphs in this Consent
Decree are inserted for convenience only and are not intended to
affect the meaning or interpretation of this Consent Decree.
28. Authorized Representative. Each Party represents and warrants to the
other that it has full power and authority to enter into this Consent
Decree. The FCC signatory represents that she is signing this Consent
Decree in her official capacity and that she is authorized to execute
this Consent Decree.
29. Counterparts. This Consent Decree may be signed in counterpart
(including by facsimile). Each counterpart, when executed and
delivered, shall be an original, and all of the counterparts together
shall constitute one and the same fully executed instrument.
________________________________ P. Michele Ellison Chief Enforcement
Bureau ________________________________ Date
________________________________ Jeffrey Feldman Chief Executive Officer
FTTH Communications, LLC ________________________________ Date
^ 47 U.S.C. S 214
^ 47 C.F.R. S 63.18.
^ 47 U.S.C. SS 154(i), 503(b).
^ 47 C.F.R. SS 0.111, 0.311.
^ 47 U.S.C. S 214.
^ 47 C.F.R. S 63.18.
^ 47 U.S.C. S 214; 47 C.F.R. Part 63.
^ 47 U.S.C. S 214(a).
^ 47 C.F.R. S 63.01(a) ("Any party that would be a domestic interstate
communications common carrier is authorized to provide domestic,
interstate services to any domestic point and to construct or operate any
domestic transmission line as long as it obtains all necessary
authorizations from the Commission for use of radio frequencies.").
^ See Implementation of Section 402(b)(2)(A) of the Telecomm. Act of 1996,
Report and Order in CC Docket No. 97-11, Second Memorandum Opinion & Order
in AAD File No. 98-43, 14 FCC Rcd 11364, para. 2 & n.8 (1999) (grant of
blanket authority is only for domestic service and does not extend to
^ 47 C.F.R. S 63.18.
^ Id. S 63.18(e)(1)-(2); see Start Wireless Group, Inc. d/b/a/ Page Plus
Cellular, Notice of Apparent Liability for Forfeiture, 27 FCC Rcd 350
(Enf. Bur. 2012).
^ See Application for Global Authority Pursuant to Section 214 of the
Communications Act of 1934, as amended, to Operate as an International
Facilities-Based and Resale Carrier Between the United States and Various
International Points, Int'l. Bur. Filing System (IBFS) Application No.
ITC-214-20100129-00025, at 2 (filed Jan. 29, 2010) (FTTH Section 214
^ See Application of FTTH Communications, LLC and Everest FTTH Acquisition
LLC for Transfer of Control of International Section 214 Authorization,
IBFS Application No. ITC-T/C-20100201-00073, at 2 (filed Feb. 1, 2010).
^ Id. at 3, 6.
^ See FTTH Section 214 Authorization Application at 1 n.1; Letter from
Jean L. Kidoo and Danielle Burt, Bingham McCutchen LLP, Counsel for
Everest Acquisition, LLC and FTTH, LLC, to Marlene H. Dortch, Secretary,
FCC (Jan. 29, 2010).
^ See FTTH Section 214 Authorization Application.
^ See FTTH International Section 214 STA Application, Request for Special
Temporary Authority, IBFS Application No. ITC-STA-20100129-00024 (filed
Jan. 29, 2010).
^ See record of action by Int'l Bur. in FTTH STA Application available
through IBFS at http://licensing.fcc.gov/ myibfs/.
^ See International Authorizations Granted, Section 214 Applications, DA
No. 10-412, Public Notice, 25 FCC Rcd 2337 (Int'l Bur. 2010).
^ See Letter from Hillary S. DeNigro, Chief, Investigations & Hearings
Division, FCC Enforcement Bureau, to Jean L. Kidoo and Danielle Burt,
Bingham McCutchen LLP, Counsel for Everest Acquisition, LLC and FTTH
Communications, LLC (Nov. 1, 2010).
^ See FTTH Communications, LLC, Notice of Apparent Liability for
Forfeiture, 26 FCC Rcd 12890 (Enf. Bur. 2011).
^ Id. at 12894, para. 10.
^ See E-mail from Jeffrey Feldman, Chief Executive Officer, FTTH
Communications, LLC, to Theresa Z. Cavanaugh, Chief, Investigations and
Hearings Div., FCC Enforcement Bureau; Pamela S. Kane, Deputy Chief,
Investigations and Hearings Div., FCC Enforcement Bureau; and Robert B.
Krinsky, Attorney Advisor, Investigations and Hearings Div., FCC
Enforcement Bureau (Feb. 22, 2012, 11:41 EDT).
^ 47 C.F.R. S 1.16.
^ 47 U.S.C. S 208.
^ Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat.
1321, 1358 (Apr. 26, 1996).
^ An FCC Form 159 and detailed instructions for completing the form may be
obtained at http://www.fcc.gov/Forms/Form159/159.pdf.
^ See 5 U.S.C. S 504; 47 C.F.R. Part 1, Subpart K.
Federal Communications Commission DA 13-7
Federal Communications Commission DA 13-7