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Federal Communications Commission DA 18-417
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Raviís Import Warehouse, Inc.,
Dallas, Texas
)
)
)
)
)
File No.: EB-FIELDSCR-17-00024142
NAL/Acct No.: 201732500001
FRN: 0026514281
FORFEITURE ORDER
Adopted:  April 25, 2018 Released:  April 26, 2018
By the Regional Director, Region Two:
I. INTRODUCTION
1. We impose a penalty of $22,000 against Raviís Import Warehouse, Inc., (Raviís) for 
operating a cellular phone jammer (jammer or signal jammer) in its commercial establishment in Dallas, 
Texas, in willful violation of Sections 301, 302a(b), and 333 of the Communications Act of 1934, as 
amended (Act),
1
 and Sections 2.805(a) and 15.1(c) of the Commissionís rules.
2
  The Enforcement Bureau 
(Bureau) previously proposed a $22,000 forfeiture against Raviís for its use of a signal jammer.
3
  In 
response to the NAL, Raviís asserts that the Bureau incorrectly applied relevant portions of the Act and 
proposed a forfeiture that was inconsistent with precedent.  After reviewing Raviís response to the NAL, 
we disagree and find no reason to cancel, withdraw, or reduce the proposed penalty.  We therefore assess 
the $22,000 forfeiture the Bureau previously proposed. 
II. BACKGROUND
2. On July 26, 2017, the Bureau issued the NAL proposing a $22,000 forfeiture against 
Raviís for its apparent willful violation of Sections 301, 302a(b), and 333 of the Act and Section 2.805(a) 
and 15.1(c) of the Commissionís rules stemming from its operation of a signal jammer.
4
  As discussed in 
the NAL, on April 10, 2017, an agent from the Bureauís Dallas Field Office (Dallas Office) responded to 
a complaint from an AT&T representative asserting that an AT&T base station was receiving interference 
from what appeared to be a signal jammer.
5
  The AT&T representative advised the agent that the 
characteristics of the interference were typical of a signal jammer.  While the agent was en route to the 
general location of the suspected signal jammer, the AT&T representative separately, and using his own 
equipment, determined that the jammer was likely located within Raviís commercial establishment.  
When the agent arrived on the scene, the AT&T representative was already present and stated that shortly 
after Raviís security personnel noticed the AT&T representativeís presence, the jammer ceased operating.  
In the presence of the AT&T representative, the agent spoke with Anita Bhatia, who stated that she was 
1
 47 U.S.C. ßß 301, 302a(b), 333. 
2
 47 CFR ßß 2.805(a), 15.1(c). 
3
 Raviís Import Warehouse, Inc., Dallas Texas, Notice of Apparent Liability for Forfeiture, 32 FCC Rcd 5606 (EB 
2017) (NAL).
4
 The NAL includes a more complete discussion of the facts and history of this case and is incorporated in its entirety 
herein by this reference.
5
 See NAL, 32 FCC Rcd at 5607, para. 3.
Federal Communications Commission DA 18-417
2
the owner of Raviís.
6
  Ms. Bhatia admitted to the agent that Raviís used a signal jammer as a means of 
preventing its employees from using mobile phones while at work.
7
  The agent informed Ms. Bhatia of 
the public safety issues that could be caused by Raviís use of a cell jammer.  Ms. Bhatia acknowledged 
that, in February 2017, the AT&T representative had warned her adult son against the operation of a 
signal jammer.  Ms. Bhatia further stated that she disposed of the jammer shortly before the agentís 
arrival.  Ms. Bhatia refused to voluntarily retrieve and surrender the device to the agent, and she also 
refused to identify the specific dumpster in which she disposed of the device.
8
  Instead, Ms. Bhatia 
offered to sell the signal jammer to the agent.
9
  The agent declined the offer and issued a Notice of 
Unlicensed Radio Operation informing Raviís that the operation of a signal jammer is illegal.
10
  The 
following day, the agent contacted the AT&T representative, who confirmed that AT&T was no longer 
receiving interference from equipment operated at Raviís commercial establishment.
11
 
3. On August 21, 2017, Raviís submitted a brief response to the NAL.
12
  In the NAL 
Response, Raviís affirms the core facts establishing that it violated Sections 301, 302a(b), and 333 of the 
Act and Sections 2.805(a) and 15.1(c) of the Commissionís rules but argues that the Bureau misapplied 
relevant law and Commission precedents in proposing a $22,000 monetary forfeiture against Raviís.  
Specifically, Raviís argues that, (i) while Ms. Bhatia used a jammer and discarded it in a dumpster, that 
the FCC agent did not ask her to retrieve it; and (ii) that the Bureau erred in applying Section 
503(b)(2)(D) of the Act and otherwise misapplied the law in determining the proposed forfeiture amount.  
For the reasons set forth below, we find that Raviís has not provided an adequate basis for reducing or 
canceling the forfeiture proposed in the NAL. 
III. DISCUSSION
4. The Bureau proposed a forfeiture in this case in accordance with Section 503(b) of the 
Act,
13
 Section 1.80 of the Commissionís rules,
14
 and the Commissionís Forfeiture Policy Statement.
15
  
When we assess forfeitures, Section 503(b)(2)(E) requires that we take into account the ďnature, 
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.Ē
16
  
We have fully considered Raviís response to the NAL, which includes a variety of legal arguments, but 
we find none of them persuasive.  The Bureau therefore affirms the $22,000 forfeiture proposed in the 
NAL.
6
 NAL, 32 FCC Rcd at 5607, para. 3. 
7
 Id.
8
 Id.
9
 Id.
10
 Id.
11
 Id.
12
 Raviís Import Warehouse, Inc., Response to Notice of Apparent Liability for Forfeiture (Aug. 21, 2017) (on file in 
EB-FIELDSCR-17-00024142) (NAL Response).  The NAL Responses is two pages, see id., and is accompanied by 
a one-page notarized affidavit of Anita Bhatia.  Id., Affidavit of Anita Bhatia (Bhatia Affidavit).
13
 47 U.S.C. ß 503(b).
14
 47 C.F.R. ß 1.80.
15
 The Commissionís Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the 
Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087 (1997) (Forfeiture Policy Statement), recons. denied, 
Memorandum Opinion and Order, 15 FCC Rcd 303 (1999). 
16
 47 U.S.C. ß 503(b)(2)(E).
Federal Communications Commission DA 18-417
3
5. In the NAL Response, Raviís admits to the core ďoperative factsĒ set forth in the NALó
that Raviís operated a signal jammer on April 10, 2017, and that Raviís previously received a warning 
from AT&T in February 2017.
17
  As a result, Raviís conceded the central facts to support a conclusion 
that Raviís violated Sections 301 and 302a(b) of the Act and Sections 2.805(a) and 15.1(c) of the 
Commissionís rules by operating a radiofrequency device without authority from the Commission and 
Section 333 of the Act by willfully causing interference to AT&T.
18
  Thus, we affirm our apparent 
findings of liability.     
6. In the NAL Response, however, Raviís disputes narrow portions of the NALís description 
of the April 10, 2017,
19
 conversation between Ms. Bhatia and the agent from the Dallas Office.  Raviís 
disputes whether the FCC Agent asked her to retrieve the signal jammer from the trash and she declined 
or whether she told the agent that the agent could retrieve it.  Specifically, in the Bhatia Affidavit, Ms. 
Bhatia states that she ďtold [the FCC agent] that [she] had thrown the jammer in the dumpster and that 
they were welcome to retrieve it.  They declined to do so.Ē
20
  Even if we were to accept the version of 
events recounted in the Bhatia Affidavit, the disputed portion of the conversation between Ms. Bhatia and 
the agent is irrelevant to our finding of liability, especially in light of Raviís admissions in the NAL 
Response.
21
  Rather, the only logical purpose of the Bhatia Affidavit would be to argue against the $5,000 
upward adjustment proposed in the NAL for egregious behavior.  Although Raviís does not make such an 
affirmative argument in the NAL Response, even if it had done so, we would not find it persuasive.  
While Raviís disputes the characterization in the NAL that Ms. Bhatia refused to voluntarily surrender the 
jamming device to the agent,
22
 the NAL Response does not deny the Bureauís assertion that Ms. Bhatia 
offered to sell the signal jammer to the agent.
23
  Because the NAL based the $5,000 upward adjustment on 
the egregiousness of Ms. Bhatiaís attempt to sell the jamming device to the agent, we need not address the 
factual question raised in the NAL Response of who told whom that they could retrieve the jammer from 
the trash.
24
  
7. The remainder of the NAL Response asserts that the Bureau misapplied applicable law in 
calculating the NALís proposed forfeiture of $22,000.
25
  Raviís asserts that the NALís use of Section 
503(b)(2)(D) of the Act ďis misplaced.Ē
26
  To the contrary, this is the applicable statutory section to apply 
when the Commission proposes or assesses a forfeiture against an entity that is not a broadcast licensee or 
a common carrier.
27
  And the monetary forfeiture proposed in the NAL is consistent with the 
17
 NAL Response at 1.
18
 47 U.S.C. ßß 301, 302a(b), 333; 47 CFR ßß 2.805(a), 15.1(c).  As noted in the NAL, because the same underlying 
facts here resulted in violations of both Section 301 (operation without an instrument of authorization) ($10,000 base 
forfeiture) and Section 302a(b) (use of unauthorized or illegal equipment) ($5,000 base forfeiture), we imposed only 
one of these two base forfeiture amounts.  NAL at 32 FCC Rcd 5609, n. 22.
19
 NAL Response at 1.
20
 NAL Response, Affidavit of Anita Bhatia.
21
 NAL Response at 1.
22
 Id.
23
 Compare NAL, 32 FCC Rcd at 5607, para. 3, to NAL Response at 1.    
24
 See NAL, 32 FCC Rcd at 5609, para. 8.
25
 NAL Response at 2.
26
 Id.
27
 See 47 U.S.C. 503(b)(2)(D).
Federal Communications Commission DA 18-417
4
Commissionís precedents for enforcement actions involving signal jammers.
28
  We therefore reject Raviís 
argument for a reduction of the monetary forfeiture.  
8. After considering the relevant statutory factors and the Commissionís Forfeiture Policy 
Statement, we find that Raviís is liable for a total forfeiture of $22,000.  As explained in the NAL, this 
amount represents the sum of (a) the $10,000 base forfeiture for operating a radio without the 
Commissionís authorization, in violation of Sections 301 and 302a(b) of the Act and Sections 2.805(a) 
and 15.1(c) of the Commissionís rules, (b) the $7,000 base forfeiture for causing harmful interference, in 
violation of Section 333 of the Act, and (c) an upward adjustment of $5,000 to address the egregiousness 
of Raviís attempt to generate revenue from the Commissionís efforts to resolve an interference complaint 
(with potential public safety ramifications).
IV. CONCLUSION
9. Based on the record before us, and in light of the applicable statutory factors, we 
conclude that Raviís willfully violated Sections 301, 302a(b) and 333 of the Act and Sections 2.805(a) 
and 15.1(c) of the Commissionís rules by operating a signal jammer from its commercial establishment in 
Dallas, Texas.  We decline to cancel or reduce the $22,000 forfeiture proposed in the NAL.
V. ORDERING CLAUSES
10. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act,
29
 and Section 
1.80 of the Rules,
30
 Raviís Import Warehouse, Inc., IS LIABLE FOR A MONETARY FORFEITURE 
in the amount of Twenty-Two Thousand Dollars ($22,000) for willfully violating Sections 301, 302a(b), 
and 333 of the Act,
31
 and Sections 2.805(a) and 15.1(c) of the Commissionís rules.
32
11. Payment of the forfeiture shall be made in the manner provided for in Section 1.80 of the 
Rules within thirty (30) calendar days after the release of this Forfeiture Order.
33
  If the forfeiture is not 
paid within the period specified, the case may be referred to the U.S. Department of Justice for 
enforcement of the forfeiture pursuant to Section 504(a) of the Act.
34
12. Payment of the forfeiture must be made by check or similar instrument, wire transfer, or 
credit card, and must include the NAL/Account Number and FRN referenced above.  Raviís shall send 
electronic notification of payment to Matthew L. Gibson at matthew.gibson@fcc.gov, with a copy to 
field@fcc.gov, on the date said payment is made.  Regardless of the form of payment, a completed FCC 
Form 159 (Remittance Advice) must be submitted.
35
  When completing Form 159, enter the Account 
Number in block number 23A (call sign/other ID) and enter the letters ďFORFĒ in block number 24A 
28
 See, e.g., R&N Manufacturing, Ltd., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 3332, para. 2 
(2014), cancelled by Order, 31 FCC Rcd 1897 (EB 2016) (adopting a Consent Decree terminating and resolving the 
investigation); The Supply Room, Inc., Notice of Apparent Liability for Forfeiture, 28 FCC Rcd 4981, 85-87, paras. 
11-14 (2013), cancelled by Order, 31 FCC Rcd 2082 (EB 2016) (adopting a Consent Decree terminating and 
resolving the investigation).  In addition, we note that Raviís reliance on U.S. v. Baxter, 841 F. Supp. 2d 378 (D. Me. 
2012), is misplaced.  Unlike the present case, Baxter involved violations of the Commissionís Part 97 rules for 
amateur radio licensees, not the operation of a signal jamming device.  
29
 47 U.S.C. ß 503(b).
30
 47 CFR ß 1.80.
31
 47 U.S.C. ß 301, 302a(b), 333.
32
 47 CFR ßß 2.805(a), 15.1(c). 
33
 Id.
34
 47 U.S.C. ß 504(a).
35
 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf. 
Federal Communications Commission DA 18-417
5
(payment type code).  Below are additional instructions that should be followed based on the form of 
payment selected: 
? Payment by check or money order must be made payable to the order of the Federal 
Communications Commission.  Such payments (along with completed Form 159) must be 
mailed to the Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank Ė Government Lockbox #979088, SL-MO-C2-
GL, 1005 Convention Plaza, St. Luis, 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 Ė 
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.
13. Any request for making full payment over time under an installment plan should be sent 
to: Chief Financial Officer Ė Financial Operations, Federal Communications Commission, 445 12
th
 Street, 
S.W., Room 1-A625, Washington, DC 20554.
36
  Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by telephone, 1-877-480-3201, or by e-mail, 
ARINQUIRES@fcc.gov. 
14. IT IS FURTHER ORDERED that a copy of this Forfeiture Order shall be sent by first 
class mail and certified mail, return receipt requested to Raviís Import Warehouse, Inc., Attn: Anita 
Bhatia, 11029 Harry Hines Boulevard, Dallas, Texas 75229, with a copy to Allen Landerman, Esq., Allen 
Landerman, P.C., 16801 Addison Road, Suite 125, Addison, Texas 75001.
FEDERAL COMMUNICATIONS COMMISSION
Ronald Ramage
Regional Director
Region Two 
Enforcement Bureau
36
 See 47 CFR ß 1.1914.