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KM0 K2."i~'^ %,77\V%%%7>%7777777777>>>0eOIIOD>OO%*ODaOO>OI>DOOgOOD%%37%07070%777V7777%*77O77055;%;3%%%%%%%%%7%7O0O0O0O0O0aHI0D0D0D0D0%%%%O7O7O7O7O7O7O7O7O7O7O0O7O6O7O7O7>7O0O0O0I0I0I;I0OED0D0D0D0O7O7O7O;O7O;O7%%7%%%7M>;;O7DD,D%D%DO7AO7O7O7O7aOI%I%I%>*>*>*>;D.DD3O7O7O7O7O7O7gOO;D0D0D0O7D%O7>*D%O7E77%%WMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN(BB(37%07777j7#TT7!#TT7T!%%007n&&Bn77lBTn(nBB(AZZ>>n%07\n!"IIIITTenn7TnB@;7>lBBn7"i~'^"(22TN"""28"2222222222888,\HBBH>8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""2"2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d""7jC:,y Xj\  P6G;XP$ 2~CC,=X~ps7X&7nC:,T {O"-ԍId., p. 8.8 Of that amount, however, Lone Star was only required to pay $598,545.00 Lone Star was given various credits for the remainder of the purchase price, representing either monies it had paid or its release of  S-claims against KO.8,T {O(&-ԍId., p. 8.8 "b,,))qq"Ԍ S-x 10. The settlement agreement was principally negotiated between Lone Star and McCaw.F-T yOh-ԍKO September 3 Response, p. 1.F KO has represented to the Bureau that it "is simply not in a position" to provide a history of the settlement negotiations because it was not principally involved in the negotiations and because it  S-changed communications counsel shortly after the settlement agreement was approved.;.XT {O-ԍId., pp. 12.;  S8-x 11. At the time the settlement agreement was entered into, "Lone Star continued to believe  S-that [KO] did not possess the qualifications to be, and remain, a Commission licensee."K/T yO -ԍLone Star August 4 Response, p. 13.K Lone Star offers the following reasons for entering into a settlement agreement: Xx(i) the parties and the Commission would not be required to further deplete their already limited resources on this litigation; (ii) [KO] would no longer control the License and the facilities authorized thereunder; and (iii) cellular service in the Texas  S -7 market would be provided by a carrier whose character was not in doubt.90 zT {O:-ԍId., p. 15.9  As noted above, Lone Star represented "that grant of the instant request, withdrawal of Lone Star's Petition and grant of the abovecaptioned Application complies with the Commission's Section  S -22.29(b) policy favoring settlements and will directly serve the public interest."r1 T yO,-ԍ"Request for Approval of Withdrawal of Petition to Dismiss or Deny", p. 3.r When the settlement agreement was submitted, Lone Star did not inform the Commission that Lone Star still believed KO was not qualified to be a Commission licensee. Lone Star denies that there is any inconsistency between its advocacy of the grant of the transfer of control application and its belief that KO was not  S-qualified to be a Commission licensee.M2T yO-ԍLone Star September 3 Response, p. 4.M Specifically, it cites several cases where it contends that assignment applications were granted although unresolved questions were raised concerning the  S-assignor's qualifications.3(, T {O\-ԍThe cases Lone Star cites include Spanish International Communications Corp., 2 FCC Rcd 3336, 3339  {O&-(1987) (subsequent history omitted), Grayson Enterprises, Inc., 77 FCC 2d 156, 163 (1980), Grayson  {O-Enterprises, Inc., 79 FCC 2d 936, 941 (1980), Second Thursday Corp., 22 FCC 2d 515, 516 (1970), and Harry  {O -O'Connor, 2 FCC 2d 45 (Rev. Bd. 1965). Lone Star September 3 Response, p. 4 n.4. Lone Star also argues that "the Commission had the continuing authority to  Sh-address the substantive allegations against [KO] at any time, sua sponte. . ."S4hT yO$#-ԍLone Star September 3 Response, p. 4.S  S-x 12. On February 24, 1995, the Wireless Telecommunications Bureau released a public notice announcing its approval of the withdrawal of the petition to deny and the grant of the transfer of  S-control application.n5T {O(-ԍPublic Notice, Report No. LB9501 (released February 24, 1995).n The public notice reads as follows:">5,))qq3"ԌXxOn November 5, 1993, the following assignment application was filed and appeared on Public Notice, Report No. CL9418, released 12/02/93. A Petition to Deny was filed by Lone Star Communications, Inc., but was subsequently withdrawn. The request for approval of the withdrawal of the pleadings, the copy of the written agreement and affidavits have been reviewed and are hereby approved pursuant to Section 22.129 of the Commission's Rules. Pursuant to an amendment filed by counsel, dated 2/10/95, the proposed transaction has been restructured from an assignment to a transfer of control and the transferee's name changed to "McCaw Unrestricted Holdings, Inc." The Commission has found the application to be in the public interest and has granted the application effective February 21, 1995.  Xx00679CLTC194 Transfer of Control K.O. Communications, Inc., Station KNKN665 from K.O. Communications, Inc. to McCaw Unrestricted Holdings, Inc., Market 658A TX 7 Fannin RSA.   S -D. Wilson Petition for Reconsideration and Dismissal of Transfer of Control Application  SX-x 13. On March 27, 1995, Nicholas R.Wilson ("Wilson") filed a "Petition for Reconsideration" of the Public Notice. Wilson's petition incorporated the basic allegations contained in the Lone Star  S-petition to deny.V6T yOp-ԍWilson Petition for Reconsideration, pp. 612.V Wilson also alleged that Lone Star had filed its petition to deny "as a 'strike  S-pleading' scheme to obtain money from the Kozel interests and the McCaw interests"S7XT yO-ԍWilson Petition for Reconsideration, p. 14.S and that the  S-settlement violated Section 22.129 of the Commission's Rules.W8T yO@-ԍWilson Petition for Reconsideration, pp. 1317.W KO, McCaw, and Lone Star each filed pleadings opposing or seeking summary dismissal of Wilson's petition for reconsideration.  S@-x 14. Three days before Wilson filed his petition with the Commission, he had instituted a civil lawsuit in the United States District Court for the Northern District of Ohio, Eastern Division, against KO, its partners/shareholders, McCaw, Sedmak, and related corporate entities. Wilson's civil complaint alleged that he had an agreement with KO under which he would design and construct the system and be responsible for selling the system in return for receiving ten percent of the proceeds of  Sx-any sale of the system.9xxT {O-ԍComplaint in Nicholas Wilson v. Paul L. Kozel, et al. (Lone Star Revocation Petition, Exhibit 9), p. 89 32. Wilson also alleged that he had a separate agreement with Sedmak under which Sedmak agreed to pay Wilson a commission if any transaction between KO and Sedmak was  S(-consummated concerning the cellular system in the Texas 7 RSA.@:(T {O#-ԍId., p. 15 48.@  S-x15. Before action was taken on the petition for reconsideration, however, the parties to the transfer of control application terminated their agreements and, on May 17, 1996, requested dismissal"d :,))qq-"  S-of the application.;T {Oh-ԍSee letter dated May 17, 1996 from Bell, Boyd & Lloyd to the Secretary, Federal Communications Commission (Lone Star Revocation Petition, Exhibit 8). There was no further activity concerning KO at the Commission until the Lone Star Revocation Petition was filed on September 30, 1997.  S-E. Lone Star's Revocation Petition  S8-x16. On September 30, 1997, Lone Star filed its Revocation Petition. Most of the arguments Lone Star made in its Revocation Petition were arguments it made in its 1994 petition to deny the  S-assignment application.N<"T {O -ԍSee Investigation Order, 13.N Lone Star's Revocation Petition also made the new argument that Wilson was an undisclosed realpartyininterest in the KO Partnership application and that Wilson later  S-acquired de facto control over KO.W=T yO -ԍLone Star Revocation Petition, pp. 4349.W KO opposed the Lone Star Revocation Petition on October 15, 1997, and Lone Star filed a reply on November 14, 1997.  S" -x17. In its opposition, KO argued that Lone Star's filing of the Revocation Petition was an abuse of the Commission's processes. KO specifically alleged that "Lone Star's Sole Motivation in Filing its Petition is to Obstruct [KO] From Conducting Its Business and Extract a 'Greenmail'  S -Payment."M> DT yO-ԍKO Revocation Opposition, p. 9.M It offered the following "evidence" of Lone Star's improper motive: (1) KO's belief that Lone Star could gain nothing from revocation but could benefit from pressuring KO to withdraw the petition in return for a payment; (2) the similarity of Lone Star's current charges to the charges Lone Star first made and then withdrew in connection with the assignment application; (3) Sedmak's failure to bring the pertinent facts to the Commission's attention in 1991, when he became aware of many of the facts he alleges; (4) KO's belief that Lone Star's petition was motivated by its discovery that a KO principal attended a PCIA conference and the belief that KO was about to conduct a major business transaction; and (5) KO's claim that the Lone Star Revocation Petition "contains numerous deliberate misrepresentations of fact" and "is completely bereft of any supported allegations which could lead to  SB-a finding adverse to [KO]."=?BT {O-ԍId., pp. 1011.=  S-x18. In the period in between May 17, 1996, when the parties requested dismissal of the transfer of control application, and September 30, 1997, when Lone Star filed its Revocation Petition,  S-the only communications between KO and Lone Star involved the law suit filed by Wilson.i@f T yO"-ԍLone Star August 4 Response, p. 6, KO August 4 Response, pp. 23.i Various transmittal letters and copies of pleadings were exchanged between counsel for KO and counsel for  SR-Lone Star.OAR T yO%-ԍLone Star August 4 Response, Exhibit 1.O No evidence has been offered that Lone Star made any threats against or made any demands upon KO in this time period. " A,))qq"Ԍ S-x19. Lone Star claims that the "Revocation Petition was not filed for the purpose of greenmail or for any other pecuniary or improper motive violative of the Commission's Rules or  S-policies."JBT yO-ԍLone Star August 4 Response, p. 3.J In the same vein, Lone Star earlier claimed that it "filed its Petition with the appropriate federal agency to raise the extremely important issues surrounding the circumstances under which  S`-[KO] obtained the License for the Texas 7 RSA . . . ."SC`XT yOX-ԍLone Star Reply, p. 6 and Exhibit 1, 2.S When asked why it waited until September 1997 to file the Revocation Petition, Lone Star explained that while Lone Star's counsel had drafted the Revocation Petition as early as April 1997, it was advised by its counsel in the Wilson litigation that "filing the Revocation Petition would have a negative impact on" Lone Star's position in that  S-proceeding.KDT yOH -ԍLone Star August 4 Response, p. 11.K Wilson's law suit was dismissed on July 15, 1997.ExT {O -ԍNicholas Wilson, et al. v. Paul L. Kozel, et al., Memorandum Opinion and Order, issued July 15, 1997. Since Lone Star's Revocation Petition relied in part upon allegations contained in Wilson's complaint, it is apparent that, if the Revocation Petition had been filed while Wilson's law suit was still pending, there would have been a danger that Wilson could have used the Revocation Petition as evidence that Lone Star believed his law suit had merit. Even after the Wilson law suit was dismissed, Lone Star sought counsel from  S -"various sources" which resulted in revisions to the pleading before September 30, 1997.KF T yO-ԍLone Star August 4 Response, p. 12.K  S -x20. Lone Star learned most of the events relating to Paul L. Kozel's role with respect to KO  S -occurred during or before Lone Star's attempt to acquire the construction permit from KO in 1991.KG T yO-ԍLone Star August 4 Response, p. 12.K Lone Star did not bring the facts to the Commission's attention until 1994, when it filed the petition to deny against the assignment application. When asked why it did not bring the facts to the Commission's attention earlier, Lone Star explained that until October 1993, Lone Star was pursuing the acquisition of the construction permit, and "Lone Star had not yet fully sorted out all the details of such actions nor had Lone Star analyzed whether such actions, in fact, violated Commission  S-requirements."1H* T {OZ-ԍId.1  S@-F. The Investigation Order  S-x21. On July 7, 1998, the Bureau released its Investigation Order. With respect to the arguments Lone Star had made in its petition to deny, the Bureau held that when the Bureau granted the transfer of control application, it "determined that Lone Star's allegations concerning Paul L. Kozel's role in the KO Partnership do not raise substantial and material questions concerning KO's  ST-qualifications to be a Commission licensee."JIT T {O&-ԍInvestigation Order, 19.J Since the transfer of control application had been granted in a public notice with no accompanying order, the Bureau explained in detail its reasons for", N I,))qq" concluding that Lone Star's allegations did not raise substantial and material questions of fact  S-concerning KO's qualifications to be a Commission licensee.AJT {O@-ԍId., 2024.A The Bureau then rejected Lone Star's new argument that Wilson was a realpartyininterest in KO's application or that he subsequently  S-acquired de facto control over KO.:KZT {O-ԍId., 25.: The Bureau therefore denied Lone Star's request that revocation  Sb-proceedings be instituted against KO.LbT {O-ԍOn August 7, 1998, Lone Star filed an Application for Review of the Investigation Order. That pleading is pending before the Commission.  S-x22. With respect to KO's abuse of process claims, the Bureau rejected KO's allegations that  S-the Lone Star Revocation Petition was frivolous.JMFT {O -ԍInvestigation Order, 29.J The Bureau concluded that there was a reasonable basis in fact and in law for Lone Star's allegations, and there was no evidence that Lone Star filed its  S-petition for purposes of delay.1NT {O-ԍId.1 The Bureau noted, however, that the circumstances surrounding the filing of Lone Star's petition to deny, its settlement agreement with KO and McCaw, and the subsequent filing of the Revocation Petition raised questions concerning Lone Star's motivations for filing the Revocation Petition. The Bureau wrote: XxLone Star claims that it filed the petition "to raise the extremely important issues surrounding the circumstances under which [KO] obtained the License for the Texas 7 RSA . . . ." Lone Star knew most of those pertinent facts in 1991, but it did not bring those facts to the Commission's attention until 1994. Lone Star then voluntarily withdrew its petition and other claims in return for a promised payment of over $1,000,000, which was to be applied towards the purchase of an equity interest in the licensee. Moreover, Lone Star represented in the settlement filing that the grant of the transfer of control application would be in the public interest, which appears to have been an implicit representation that KO was qualified to be a Commission licensee. Lone Star then was silent for almost three years after the settlement was approved. It then presented a petition incorporating, for the most part, the same arguments it made in 1994. Under those circumstances, we have difficulty accepting at face value Lone Star's explanation for its motivation because: (1) it did not bring the facts to the Commission's attention when it first learned the facts, and (2) it has not reconciled the statements it made when seeking approval of the settlement with the later filing of its  Sz-revocation petition.JOzj T {O#-ԍInvestigation Order, 30.J   S*- III. DISCUSSION אTP  S-x23. "Abuse of process is a broad concept that includes use of a Commission process to achieve a result that the process was not intended to achieve or use of that process to subvert the" O,))qq<"  S-purpose the process was intended to achieve."hPT {Oh-ԍEvansville Skywave, Inc., 7 FCC Rcd 1699, 1702 n.7 (1992).h It includes conduct such as filing strike applications or pleadings, harassing an opponent, or filing an application or pleading for the purpose of effectuating  S-a settlement.1QZT {O-ԍId.1 "In an adjudicatory proceeding, a conclusion that abuse of process has occurred  S-requires a specific finding, supported by the record, of abusive intent."8RT {O-ԍId., n.10.8 As a result of our investigation, we conclude that there is insufficient evidence of abusive intent to justify either enforcement action or further proceedings against Lone Star.  S-x24. Our primary concern in instituting this investigation was whether Lone Star had filed the Revocation Petition for the purpose of extracting a settlement payment from KO. It is undisputed that Lone Star never made any approach or threat to KO seeking payment prior to filing the Revocation Petition. While KO previously speculated that Lone Star knew that KO was planning a business  SH -transaction around the time the Revocation Petition was filed,HSH ~T yOf-ԍKO Revocation Opposition, p. 11.H Lone Star and Sedmak have  S -specifically denied such knowledge,OT T yO-ԍLone Star August 4 Response, pp. 1617.O and KO has admitted that it has no proof of Lone Star's  S -knowledge.CU T yO6-ԍKO August 4 Response, p. 5.C  S -x25. Nonetheless, even in the absence of a direct approach, circumstantial evidence could be sufficient to prove that a petitioner filed a pleading for the purpose of extracting a settlement. For  SX-example, in WWORTV, Inc., 7 FCC Rcd 636 (1992), the Commission concluded that an applicant had filed its application for the purpose of extracting a settlement based upon the fact that the applicant's "account of its intent" was "at best without credibility and at worst false and misleading," as well as  S-other circumstances which supported a finding that the application was filed for an improper purpose.KV. T {O-ԍId.,  7 FCC Rcd at 638.K Specifically, the applicant had claimed that it filed an application challenging the renewal application of WWORTV because of perceived inadequacies in the service being offered by the owners of WWORTV, but it was later discovered that the applicant was formed only three weeks after the new  SB-owners took over WWORTV.HWB T {O!-ԍId., 7 FCC Rcd at 639640.H Given the implausibility of the applicant being able to judge the performance of the new licensee in such a short period of time, and other circumstantial evidence showing that the applicant's principals were interested in settlement, the Commission concluded that the applicant had filed for purposes of reaching a settlement.  Sz-x26. In contrast, in this case, the circumstances surrounding Lone Star's filings do not allow us to find the "specific evidence" of "abusive intent" which must be present in order to find an abuse of process. Lone Star strenuously denies that it filed the Revocation Petition for the purpose of entering"* R W,))qq" into a settlement agreement. In the absence of an explicit demand or approach by Lone Star, we would only find that Lone Star filed the Revocation Petition for purposes of settlement if the circumstances provided clear evidence of such an intent. In this case, the circumstances do not clearly point in that direction. Lone Star never received an explicit ruling on its allegations. While we  S`-implicitly rejected Lone Star's allegations when we granted the transfer of control application,NX`T {O-ԍSee Investigation Order, 19.N Lone Star could plausibly believe, as it claims, that its filing was appropriate "to ensure that the Commission  S-fully and completely reviewed the circumstances pursuant to which [KO] obtained the License."KYZT yO -ԍLone Star August 4 response, p. 10.K Furthermore, when the settlement was never effectuated, Lone Star's relationship with KO returned to  S-the status quo ante.Z T yOJ -ԍLone Star is incorrect, however, when it suggests that the Commission violated Section 309(d)(2) of the Communications Act, 47 U.S.C. 309(d)(2), by not issuing a written decision on the petition to deny. Lone Star August 4 Response, p. 9. Since Lone Star voluntarily dismissed its petition, Section 309(d)(2), which applies to the denial of a petition to deny, is not applicable. Since there was no longer any application pending before the Commission, the only way Lone Star could bring its allegations back to the Commission's attention was to file the  Sr-Revocation Petition. Accordingly, the circumstances are consistent with Lone Star having a bona fide interest in raising questions concerning KO's qualifications to be a Commission licensee.  S -x27. One of our concerns in commencing the investigation was Lone Star's motive in waiting until September 1997 to file the Revocation Petition, when the settlement was aborted in May 1996. It is now apparent that the cause of that delay was Wilson's law suit. Specifically, Lone Star was advised that its position in the Wilson law suit could be harmed if it filed the Revocation Petition while Wilson's law suit was pending. We do not condone Lone Star's decision to delay filing the Revocation Petition for its own tactical reasons. We expect that petitioners who wish to challenge a licensee's qualifications will bring such facts to the Commission's attention in a reasonably prompt manner. The investigation does not show, however, that the timing of Lone Star's filing evidences a desire to delay any filing or plans of KO or to extract a payment from KO. The record does not support KO's assertion that Lone Star was aware of any business transactions contemplated by KO.  Sl-Accordingly, unlike in WWORTV, Inc., supra, the timing of Lone Star's actions does not provide clear evidence of abusive intent.  S-x28. Another concern that prompted our investigation was whether Lone Star's arguments in the Revocation Petition were inconsistent with representations it made in connection with the settlement agreement. If a party made allegations to the Commission, repudiated those allegations in connection with a settlement, and then refiled those allegations, we could view such conduct as potentially abusive of our processes. In this case, Lone Star filed a petition to deny against KO, then entered into a settlement agreement and represented that a grant of the transfer of control application would be "in the public interest." As a general matter, the Communications Act requires that the Commission make a finding that a transferor is qualified to be a Commission licensee before the  S-application can be granted.r[T {O(&-ԍJefferson Radio Company, Inc. v. FCC, 340 F.2d 781 (D.C. Cir. 1964).r While Lone Star cites certain exceptions to that policy,R\d T yO'-ԍLone Star September 3 Response, p. 4. n.4.R none of the" \,))qq" exceptions it cites would have been applicable to the KO application. Accordingly, Lone Star's statement could be read as an implicit representation that it believed KO was qualified to be a Commission licensee.  S`-x29. In this case, however, we cannot find that Lone Star's various representations evidence an intent to abuse the Commission's processes. When it submitted the settlement agreement, Lone Star did not explicitly repudiate the allegations in its petition. If it had done so, and then filed the Revocation Petition, such conduct would raise very serious questions as to Lone Star's intent. Lone Star, however, in fact said that it believed a grant of the transfer of control application "will directly serve the public interest." While that statement could easily be read as a representation that KO is qualified to be a Commission licensee, it could also be read more generally as a request to approve the  SH -settlement agreement because it "reasonably effectuated Lone Star's intentions . . . ."K]H T yO -ԍLone Star August 4 Response, p. 15.K We caution Lone Star and its counsel to be more precise in the future when making representations to the Commission. Under these circumstances, however, we cannot find enough of an inconsistency in Lone Star's statements to constitute an abuse of process.  S -x30. We reject KO's other arguments supporting its assertion that KO has abused the Commission's processes. Given Lone Star's prior demonstrated interest in acquiring ownership of the license for the Texas 7 RSA, we disagree that Lone Star had nothing to gain from revocation of KO's license. If KO's license was revoked, the Commission would have established some sort of procedure for selecting another licensee, and Lone Star would have had the opportunity to apply for that  S-license.p^ZXT yO-ԍThe United States Court of Appeals for the District of Columbia Circuit has recognized that the ability to file an application if another applicant is disqualified can confer standing to challenge the grant of the earlier  {O@-application. Orange Park Florida TV, Inc. v. FCC, 811 F.2d 664 (D.C. Cir. 1987).p While it is true that Lone Star did not bring these facts to the Commission's attention when it learned of the facts, we have concluded that the timing of Lone Star's filings does not evidence an  Sh-intent to file for an improper purpose.F_hzT {O-ԍSee 27, supra.F Finally, we have previously rejected KO's argument that the  S@-Revocation Petition was frivolous.P`@ T {O-ԍInvestigation Order, 29.P  S-Z  IV. CONCLUSION AND ORDERING CLAUSE  T  S-TPx31. The Bureau will not tolerate frivolous pleadings or pleadings filed for the purpose of extracting settlements from our licensees and applicants. If the circumstances surrounding the filing of a pleading raise questions concerning abuse of process, we will, as we have done in this case, investigate thoroughly. The Bureau will vigorously follow the Commission's directive to take  S-appropriate enforcement action against frivolous and improper pleadings.aT {O>%-ԍCommission Takes Tough Measures Against Frivolous Pleadings, 11 FCC Rcd 3030 (1996). In this case, however, based upon our investigation, we conclude that the record does not support a conclusion that Lone Star has abused our processes. "0 a,))qq"Ԍ S-x32. ACCORDINGLY, IT IS ORDERED that the investigation to determine whether Lone Star abused the Commission's processes and this proceeding IS TERMINATED.  S`-x` `  hh FEDERAL COMMUNICATIONS COMMISSION x` `  hhGerald P. Vaughan x` `  hhActing Chief, Wireless Telecommunications Bureau