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   Before the


   Washington, D.C. 20554

   In the Matter of )

   ) File No. ENF-98-06

   ConQuest Operator Services Corp. )

   ) NAL/Acct. No. 816EF0004

   Apparent Liability for Forfeiture )


   Adopted: July 22, 1999 Released: July 26, 1999

   By the Commission:


      1. With this order, we impose a forfeiture against a carrier that has
         repeatedly failed to make its required universal service support
         contributions. In the 1996 Telecommunications Act, Congress
         expressed the importance of achieving universal service for all
         consumers of telecommunications and information services. However,
         since the Commission's implementation of universal service support
         mechanisms, certain carriers have continually refused to contribute
         to the program. This creates a variety of difficulties that the
         Commission will no longer countenance. First, delinquent carriers
         deprive the universal service support mechanisms of the funds
         necessary to carry out the goals of this important statutory
         program. The support mechanisms cannot be fully effective if,
         because of carrier delinquencies, they are only partially funded.
         Second, by withholding their universal service payments, delinquent
         carriers likely enjoy a competitive advantage over those carriers
         that are complying with the law and our regulations and making their
         payments on a timely basis. We view contribution to the universal
         service support mechanisms as the obligation of all responsible
         carriers, and we will not permit carriers to shirk their
         responsibilities in an attempt to gain an advantage over their
         law-abiding competitors. Accordingly, with this and subsequent
         orders, we demonstrate our intention to move aggressively to ensure
         the full and timely funding of the universal service support


      2. On August 14, 1998, we released a Notice of Apparent Liability (NAL)
         in this proceeding. In the NAL, we concluded that, by failing to pay
         its universal service contribution for January 1998, ConQuest
         Operator Services Corp. appeared to have willfully or repeatedly
         violated section 254 of the Communications Act of 1934, as amended,
         (the Act) and Commission rules and orders issued pursuant thereto.
         We found that ConQuest was apparently liable for a forfeiture in the
         amount of seventy thousand and thirty-three dollars ($70,033) for
         non-payment of the January 1998 contribution and allowed ConQuest to
         respond either by paying the forfeiture, or by presenting evidence
         and argument showing why no forfeiture should be imposed or some
         lesser amount should be assessed. On September 18, 1998, ConQuest
         filed its response to the NAL asking that we either decline entirely
         to impose a forfeiture or impose one smaller than that initially
         proposed. We have reviewed ConQuest's response and, for the reasons
         discussed more fully below, find that it does not justify a
         reduction in the proposed forfeiture.

      3. As we discussed in the NAL, section 254 of the Act states that
         "[e]very telecommunications carrier that provides interstate
         telecommunications services shall contribute, on an equitable and
         nondiscriminatory basis, to the . . . mechanisms established by the
         Commission to preserve and advance universal service." Our
         regulations restate the statutory requirement that telecommunication
         carriers "must contribute to the universal service support
         programs." To this end, we have directed that the Universal Service
         Administrative Company (USAC) distribute, receive, and process the
         Universal Service Worksheet on which carriers are required to report
         the categories of revenue used to calculate their universal service
         contribution; from the information in the worksheet, USAC is
         required to adjust carriers' contributions in accordance with
         contribution factors established by the Commission. In light of the
         importance of ensuring universal service, our regulations provide
         that the failure "to submit the required . . . contributions may
         subject the contributor to the enforcement provisions of the Act and
         any other applicable law."

      4. As we noted in the NAL, on January 15, 1998, USAC sent ConQuest an
         invoice for its January universal service contribution. The invoice
         stated that the contribution was due by February 16, 1998. When
         ConQuest failed to make payment by the date specified in the
         invoice, USAC personnel contacted ConQuest both by telephone and by
         mail on several different occasions. Despite these numerous
         communications, however, ConQuest declined to comply with its
         statutory obligation and pay its assessed contribution for January.
         Indeed, on August 14, 1998, when we issued the NAL, ConQuest had
         also failed to pay its universal service contributions for the
         months of February through June.


      5. In its response to the NAL, ConQuest concedes that it, like "all
         telecommunications carriers," is "required to pay the [universal
         service] fees calculated and assessed by" USAC. In opposing the
         imposition of a forfeiture, ConQuest argues primarily that its "new
         management" was unaware of the corporation's long-standing
         delinquency in its payments to the universal service fund. ConQuest
         asserts that this claimed ignorance of its obligations, and its
         consequent, "inadvertent failure to pay" its universal service
         assessment, grew out of the confusion surrounding the January 1,
         1998, acquisition of ConQuest by SmarTalk Teleservices, Inc.
         Additionally, ConQuest's response states that its officer
         responsible for universal service compliance has left the company
         and that, eight months after SmarTalk acquired ConQuest, both
         companies relocated their headquarters.

      6. Given the confusion that ConQuest claims surrounded its operations
         in 1998, "including SmarTalk's lack of knowledge of ConQuest's
         failure to pay [and] the logistical confusion resulting from the
         acquisition," ConQuest asserts that its violation of the statute and
         our rules was merely "inadvertent." Thus, ConQuest argues, its
         violation was neither willful nor repeated, as is necessary to
         support a forfeiture under section 503(b) of the Act. ConQuest's
         response also asserts its good faith in attempting to make good on
         its universal service obligations since receiving the NAL. We find
         none of ConQuest's arguments to be persuasive.


   A. ConQuest's Claimed Lack of Knowledge

      7. As a basis for avoiding forfeiture in this proceeding, the claimed
         ignorance of ConQuest's or SmarTalk's current management is both
         legally insufficient and factually suspect. At the outset, we note
         that ConQuest has not argued that it has ceased operation as a
         corporate entity. The NAL response states that ConQuest is a wholly
         owned subsidiary of SmarTalk, but nowhere does it appear that
         ConQuest has ceased to exist. Indeed, we note that ConQuest, rather
         than SmarTalk or some other entity, responded to the NAL. Given
         ConQuest's continued corporate existence, it does not appear that
         the claimed ignorance of its parent company (or some other corporate
         affiliate) regarding ConQuest's universal service obligations has
         any relevance to our assessment of a forfeiture. As an ongoing
         entity that provides interstate telecommunications services,
         ConQuest is responsible for ensuring its compliance with its
         statutory and regulatory obligations, regardless of what knowledge
         any parent corporation may have of those obligations.

      8. Moreover, a review of the record in this case raises serious
         questions about ConQuest's representations that its management was
         unaware of its universal service obligations. Before we adopted the
         NAL, USAC personnel contacted ConQuest, several times both by phone
         and in writing, to discuss its obligation to the universal service
         fund. During one of these conversations, on March 9, 1998, Marianne
         Townsend, ConQuest's vice president and secretary, stated that
         payment of the company's contribution would be sent shortly. On
         March 24, 1998, Ms. Townsend stated that the payment had been mailed
         on March 16, 1998. On at least three other occasions between May and
         August 1998, USAC personnel spoke with representatives of either
         ConQuest or SmarTalk about the carrier's delinquent status. On
         February 24, 1998, Ed Kincaide, who identified himself as an
         employee of SmarTalk, asked for and received by facsimile a copy of
         ConQuest's universal service account statement. On August 6, 1998,
         Nicole Evans, who identified herself as an employee of New
         Millennium, apparently also a ConQuest affiliate, asked for and
         received a copy of ConQuest's account statement after describing to
         USAC personnel SmarTalk's acquisition of ConQuest and stating that
         she would attempt to address ConQuest's delinquent status.

      9. This record of USAC's repeated contact with personnel at both
         SmarTalk and ConQuest demonstrates more than adequate notice of
         ConQuest's universal service obligation. On at least two occasions,
         USAC sent statements of ConQuest's account to employees of ConQuest
         or its affiliates. These statements were sent at the specific
         request of the individuals receiving them and were in addition to
         the regular invoices that USAC continued to send ConQuest on a
         monthly basis. Moreover, Ms. Townsend, a vice president of ConQuest,
         spoke on at least two occasions with USAC and acknowledged the
         carrier's delinquency. The record shows more than adequate notice to
         both SmarTalk and ConQuest of the substantial delinquency to the
         universal service fund.

     10. At certain points in its NAL response, ConQuest also appears to
         contend that, in assessing a forfeiture, we should be guided by the
         actual knowledge of its current management regarding the company's
         universal service obligations. It thus appears to contend that the
         repeated communications that USAC had with ConQuest employees did
         not provide the corporation with effective notice of its universal
         service obligations because the company's "new management" allegedly
         was unaware of them. This argument wholly disregards fundamental
         principles of the law of agency. It is well established that notice
         to a corporation's employee of matters actually or apparently within
         that employee's area of responsibility serves as notification of the
         corporation. Regardless of the actual knowledge of "new management"
         on the issue, USAC's records unquestionably reflect contact with the
         carrier's employees -- discussed at length above -- that is
         sufficient to place the carrier on constructive notice of its
         universal service delinquency.

     11. We note with some concern the portion of ConQuest's response that
         offers Ms. Townsend's departure from the company as a justification
         for its alleged ignorance of its universal service obligations.
         Shortly after we issued the NAL, Ms. Townsend contacted the
         Commission staff responsible for this matter to discuss the NAL,
         stating that she was working on the matter as a consultant. It thus
         appears that ConQuest's statement regarding Ms. Townsend's departure
         from its employ was, although possibly technically accurate, also
         disingenuous. We remind ConQuest that, under our rules, the parties
         and their lawyers appearing in Commission proceedings are under the
         obligation to be truthful and forthright in their written
         submissions. In appropriate cases, violation of the duties imposed
         in these sections of our rules may serve as an independent basis for
         the issuance of a notice of apparent liability or other sanction by
         the Commission.

   B. ConQuest's Claim of Good-Faith Response to the NAL

     12. As an additional factor in its defense, ConQuest points to its
         alleged good faith in attempting to bring itself current in its
         universal service obligations after receiving the NAL. Thus, it
         states that it "has proposed a payment schedule to resolve the
         past-due ConQuest payments." The proposal to which ConQuest refers
         appears in a September 1, 1998, letter from Thaddeus Bereday,
         SmarTalk's vice president and general counsel. That letter proposes
         "an immediate 25% downpayment of the current balance owed, as
         calculated by USAC, with payment of the remaining balance . . . in
         pro rata installments over the next 12 months." The letter further
         states that "SmarTalk will commit to paying all additional
         [universal service] payment obligations accruing during that
         12-month period in a timely manner."

     13. ConQuest's subsequent actions fall far short of the optimistic
         representations in Mr. Bereday's letter and in the NAL response. On
         September 23, 1998, USAC received a payment on ConQuest's account in
         the amount of $50,000. At the time, the carrier's outstanding
         universal service liability was in excess of $800,000. Indeed, the
         payment was less than half of ConQuest's liability for the month of
         January alone, $100,067.83. Rather than the promised "immediate 25%
         downpayment of the current balance owed," ConQuest has paid less
         than 7 percent of its outstanding liability. Furthermore, before its
         bankruptcy filing, ConQuest appears to have made little effort to
         live up to Mr. Bereday's commitment to make monthly payments on the
         delinquency as well as timely paying its newly accruing liability.
         Apart from the one-time payment in late September, ConQuest has made
         no further universal service payments -- on either its new or its
         delinquent obligations. We are therefore doubtful of ConQuest's
         professed good-faith desire to bring itself current.

   C. Willful and Repeated Nature of ConQuest's Violation

     14. Under section 503(b) of the Act, the Commission is empowered to
         impose a forfeiture when it has determined that a carrier has
         "willfully or repeatedly failed to comply with any of the provisions
         of this Act or of any rule, regulation or order issued by the
         Commission under this Act." Based on our review of the record in
         this proceeding, as described below, we conclude ConQuest's actions
         violate section 254(d) and section 54.703(a) of our rules, both of
         which impose on interstate carriers the obligation to contribute to
         universal service support programs.

     15. ConQuest's refusal to make the required contribution for January
         continued despite repeated communications from USAC, the
         administrator of the universal service program. In at least two
         separate letters, USAC informed ConQuest that its universal service
         contributions were required both by statute and by the Commission's
         rules. USAC also repeatedly contacted ConQuest regarding its
         delinquent status. In the face of these repeated communications
         regarding its universal service obligation, the carrier's persistent
         refusal to make the required payment rises to the level of a willful
         failure to comply with section 254 and our rules.

     16. We also find that ConQuest's violation of the Act and our rules is a
         repeated one within the meaning of section 503(b). As we noted in
         the NAL, ConQuest's failure to pay its January universal service
         contribution first became a violation of the statute and our
         regulations on February 17, 1998, the day after its payment was due.
         Each subsequent day on which ConQuest failed to make the required
         payment continued the violation and amounted to an additional,
         repeated violation of the statute and our rules.

   D. Amount of the Forfeiture

     17. Section 503(b) of the Act requires that, in determining the amount
         of a forfeiture, we "take into account 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."
         ConQuest's NAL response contends that the claimed inadvertence of
         the violation "suggests that the extent and gravity of this
         violation is de minimis." As we have set out above, we view the
         record in this proceeding as supporting a finding that the violation
         in the period before the bankruptcy filing was willful, rather than,
         as ConQuest contends, merely inadvertent. We further note that
         ConQuest has not claimed to have been unable, before its bankruptcy
         petition, to pay its universal service obligation; however, apart
         from a payment of $50,000 in late September of 1998, ConQuest has
         done nothing to reduce its outstanding universal service liability,
         which amounted to more than $1.1 million as of December 31, 1998.

     18. The provision of universal service throughout the country
         represented one of the primary goals of the 1996 Telecommunications
         Act. To that end, Congress explicitly provided, in section 254 that:

   Consumers in all regions of the Nation, including low-income consumers and
   those in rural, insular, and high cost areas, should have access to
   telecommunications and information services . . . that are reasonably
   comparable to those services provided in urban areas that are available at
   rates that are reasonably comparable to rates charged for similar services
   in urban areas.

   Naturally, the universal service support mechanisms are necessary to
   effectuate this central statutory goal. Those mechanisms cannot function
   effectively if carriers do not remit their universal service contributions
   on a timely and regular basis. We view ConQuest's violation of the Act and
   our rules as substantially damaging to a program that is both an important
   congressional goal and a primary focus of this Commission. We therefore
   impose a forfeiture of $70,033 for its non-payment of its January 1998
   contribution as proposed in the NAL.

     19. As we discussed in the NAL, this forfeiture consists of two
         components. First, we have assessed a figure of $20,000 as a general
         penalty for failure to pay the assessed universal service
         contribution in an appropriately timely manner. Given the vital
         importance of universal service, it is necessary to set a presumed
         forfeiture figure that will deter delinquencies regardless of their
         amount. The remainder of the forfeiture figure, $50,033, amounts to
         one half of the unpaid universal service contribution for January
         1998, the delinquency on which we base this forfeiture order. We
         have imposed this second component of the forfeiture to recognize
         that a delinquent carrier's culpability, and the consequent damage
         it causes to the goal of universal service, may vary with the amount
         by which it is in arrears. As noted above, the forfeiture imposed in
         this order relates to ConQuest's delinquency that accumulated before
         the carrier filed for bankruptcy. As a general rule, however, if it
         becomes necessary to issue more than one NAL to compel a carrier's
         compliance with its universal service obligations, the subsequent
         notices may well propose substantially greater forfeitures than
         those proposed in this proceeding.

     20. Finally, we note with substantial concern the significant pattern of
         non-compliance that has emerged during the first year of our
         universal service rules. As of February 1, 1999, USAC's records
         reflected more than $27.5 million in unpaid universal service
         contributions. As we noted at the outset, these delinquencies tend
         to undermine the efficiency and effectiveness of the universal
         service support mechanisms. Furthermore, recalcitrant carriers may
         gain a competitive advantage over those industry members that are
         complying with the Act and our rules. Both of these consequences of
         non-compliance are unacceptable, and we are moving aggressively to
         prevent their continuation. Accordingly, the Commission will be
         issuing additional notices of apparent liability and taking other
         enforcement action as necessary to ensure full and timely funding of
         the universal service support mechanisms. Additionally, those
         carriers contemplating continued non-payment should be aware that,
         in light of the accumulating record of non-compliance, we are
         prepared to impose substantially greater forfeitures in the future.
         We originally restricted ourselves to basing the proposed forfeiture
         in this proceeding on ConQuest's first month of non-payment.
         However, our future notices likely will cover greater periods of
         non-payment than a single month; they similarly will be based on
         some variant of the above formula, which includes, as a component of
         the forfeiture, one half of the unpaid contribution amount for the
         period in question.


     21. After reviewing ConQuest's response to the NAL, we find that it has
         failed to identify any facts or circumstances to persuade us that
         there is any basis for reconsidering the NAL. Neither has ConQuest
         shown any mitigating circumstances sufficient to warrant a reduction
         of the $70,033 for which we previously found it apparently liable.


     22. Accordingly, IT IS ORDERED, pursuant to Section 503(b) of the Act,
         47 U.S.C. S: 503(b), and section 1.80(f)(4) of the Commission's
         rules, 47 C.F.R. S:1.80(f)(4), that ConQuest Operator Services,
         Inc., SHALL FORFEIT to the United States Government the sum of
         seventy thousand and thirty-three dollars ($70,033) for violating
         the provisions of the Act and the Commission's rules requiring
         carriers to make payment to the universal service support

     23. IT IS FURTHER ORDERED that a copy of this Order of Forfeiture shall
         be sent by certified United States mail to Thaddeus Bereday, vice
         president and general counsel of SmarTalk at 5080 Tuttle Crossing
         Boulevard, Dublin, Ohio 43016-3566.


   Magalie Roman Salas


   See 47 U.S.C. S: 254(b)(3).

   We note that the carrier to which this order is addressed, ConQuest
   Operator Services Corp., is now in bankruptcy. This order is issued in
   accordance with section 362(b)(4) of the United States Bankruptcy Code, 11
   U.S.C. S: 101-1330, as an exercise of the regulatory power of the
   Commission to determine the appropriateness of ConQuest's conduct before
   its bankruptcy filing. Of course, everything herein shall be subject to
   the provisions of the Bankruptcy Code to the extent that those provisions
   relate to ConQuest.

   ConQuest Operator Services Corp., Notice of Apparent Liability for
   Forfeiture, 13 FCC Rcd. 16075 (1998) (NAL).

   ConQuest is an inter-exchange carrier based in Dublin, Ohio. On its first
   Universal Service Worksheet, it reported total yearly revenues in excess
   of $21 million. See FCC Form 457 in Sealed Appendix to NAL.

   Section 503 of the Act empowers the Commission to impose a forfeiture when
   it has determined that a carrier has "willfully or repeatedly failed to
   comply with any of the provisions of this Act or of any rule, regulation
   or order issued by the Commission under this Act." 47 U.S.C. S:

   47 U.S.C. S: 254(d). See also 47 U.S.C. S: 153(44) (defining
   "telecommunications carrier"); 47 U.S.C. S: 153(46) (defining
   "telecommunications service"); 47 U.S.C. S: 153(43) (defining

   47 C.F.R. S: 54.703(a).

   See FCC Form 457.

   See Changes to the Board of Directors of the National Exchange Carrier
   Association, Inc., Federal-State Joint Board on Universal Service, Report
   & Order and Second Order on Reconsideration, 12 FCC Rcd. 18400, 18424-25,
   P:P: 43-45 (1997) (NECA Governance Order). See also 47 C.F.R. S:

   47 C.F.R. S: 54.713.

   See NAL, 13 FCC Rcd. at 16078.


   ConQuest Response at 2.

   See id. at 3.

   Id. at 1.

   See id. at 4.

   See id. at 3.

   See id. at 4.

   See id. at 3-4.

   See id. at 2.

   See NAL, 13 FCC Rcd. at 16078.

   See id. See also March 9, 1998 Customer History Sheet in Sealed Appendix 1
   to NAL. We issued the NAL with sealed appendices because of
   confidentiality concerns that arose in a related proceeding. We note,
   however, that ConQuest has not requested confidential treatment for any of
   its universal service materials. Accordingly, this order discusses certain
   information in the sealed appendices that accompanied the NAL.

   USAC's records indicate that USAC personnel spoke with employees at
   ConQuest or its affiliates on May 19, July 31 and August 6, 1998. See
   Robert Haga Affidavit at 2.

   See id.

   See id.

   See id.

   See ConQuest Response at 3 (discussing knowledge of "Conquest's new


   See, e.g., Restatement (Second) of Agency S: 268.

   See also 47 U.S.C. S: 217 ("the act omission, or failure of any officer,
   agent, or other person acting for or employed by any common carrier . . .
   acting within the scope of his employment, shall in every case be also
   deemed to be the act, omission, or failure of such carrier").

   See ConQuest Response at 3.

   Our Rule 1.17 prohibits the filing of written statements with the
   Commission that contain "any misrepresentation or willful material
   omission bearing on any matter within the jurisdiction of the Commission."
   47 C.F.R. S: 1.17. Similarly, Rule 1.52 provides that counsel's
   subscription of any document filed with the Commission constitutes a
   representation that the lawyer "has read the document; that to the best of
   his knowledge, information and belief there is good ground to support it;
   and that it is not interposed for delay." Id. S: 1.52.

   ConQuest Response at 3.

   Mr. Bereday's letter is attached as Exhibit A to ConQuest's Response.

   ConQuest Response, Exhibit A.


   We recognize that, after its January 19, 1999, bankruptcy petition,
   ConQuest was not in a position to make payments on its universal service
   obligation. Our analysis of ConQuest's payment failures, despite its
   representations that payment would be made, is therefore limited to the
   period before the bankruptcy filing.

   47 U.S.C. S: 503(b)(1)(B).

   See 47 U.S.C. S: 254(d); 47 C.F.R. S: 54.703(a).

   See February 26, 1998 letter of Nancy Thomas to ConQuest in Sealed
   Appendix 1 to NAL; March 6, 1998 letter from USAC Billing and Collection
   Manager to Marianne Townsend in Sealed Appendix 1 to NAL.

   See United States v. Summa Corp., 447 F. Supp. 923, 928 (D. Nev. 1978)
   (continued non-compliance with Act in the face of warning from Commission
   amounts to willful violation under section 503(b)(1)(B)). Indeed, we have
   held that a party need not have known that it was acting unlawfully to
   support a finding of willfulness under section 503(b) of the Act. That
   section requires only a showing that the party knew it was doing the acts
   in question. See The Computer Force, Letter Ruling, 7 FCC Rcd 2687, 2687
   (Field Operations Bur. 1992); Desert Empire Television Corp., Forfeiture
   Order, 88 FCC2d 1413, 1417, P: 11 (1982).

   See NAL, 13 FCC Rcd at 16079.

   See United States v. WIYN Radio, Inc., 614 F.2d 495, 497 (5th Cir. 1980)
   ("continuous violation is made a separate offense each day it occurs and
   so becomes `repeated' on the second day of the violation") (quoting S.
   Rept. No. 95-580, at 24, reprinted in 1978 U.S.C.C.A.N. 109, 132
   (legislative history of amendment and reenactment of 47 U.S.C. S:
   503(b))); United States v. Daniels, 418 F. Supp. 1074, 1081 (D.S.D. 1976)
   (violation of Commission rule for 14 consecutive days qualified as
   "repeated" under section 503(b)(1)(B)). As noted above, these findings as
   to continuing violation relate to the period prior to the bankruptcy
   petition, when ConQuest was under no legal disability from making its

   47 U.S.C. S: 503(b)(2)(D).

   ConQuest Response at 4.

   Pub. L. No. 104-104, 110 Stat. 56 (1996).

   47 U.S.C. S: 254(b)(3).

   On January 19, 1999, during the pendency of this forfeiture proceeding,
   ConQuest declared bankruptcy. This does not, however, affect our decision
   to impose a forfeiture for ConQuest's statutory and rule violations for
   the period prior to the bankruptcy filing. Particularly where, as here, a
   carrier's violation reduces the funds available for a congressionally
   designated purpose, we will impose the forfeiture for the pre-bankruptcy
   conduct notwithstanding the subsequent declaration of bankruptcy.

   See NAL, Appendix 2.

   This figure represents only the unpaid contributions of carriers that have
   filed their Universal Service Worksheets, but then declined to pay some
   portion of the requested funds. We also note that other carriers have
   declined even to file their worksheet. Carriers in this category also will
   be the focus of our future enforcement actions.

   See supra P: .

   Naturally, enforcement of the forfeiture obligation imposed in this order
   will be subject to the appropriate standards associated with ConQuest's
   bankruptcy proceeding.

   In his September 1, 1998, letter to USAC, Mr. Bereday requested that all
   communications regarding either ConQuest or SmarTalk be directed to him.

   Federal Communications Commission FCC 99-194


   Federal Communications Commission FCC 99-194


   Federal Communications Commission FCC 99-194


   Federal Communications Commission FCC 99-194


   Federal Communications Commission FCC 99-194


   Federal Communications Commission FCC 99-194