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                           Before the
                Federal Communications Commission
                     Washington, D.C. 20554


In the Matter of                 )
                                )
CLEAR CHANNEL BROADCASTING       )    File No. EB-03-IH-0159
LICENSES, INC.                   )    NAL/Acct. No. 200423080023
                                )    FRN No. 0001587971
Licensee of Stations             )
WBGG-FM, Fort Lauderdale,        )    Facility Id. No. 11965
Florida                          )    Facility Id. No. 53457
WTKS-FM, Cocoa Beach, Florida    )    Facility Id. No. 53593
WTFX-FM, Louisville, Kentucky    )
                                )    FRN No. 0004953659
CITICASTERS LICENSES, L.P.       )
                                )
Licensee of Stations             )    Facility Id. No. 13504
KIOZ(FM), San Diego, California  )    Facility Id. No. 24958
WNVE(FM), Honeoye Falls, New     )
York                             )    FRN No.  0003474905
                                )
CAPSTAR TX LIMITED PARTNERSHIP   )
                                )    Facility Id. No. 60153
Licensee of Station
WXDX-FM, Pittsburgh, 
Pennsylvania
               
           NOTICE OF APPARENT LIABILITY FOR FORFEITURE

   Adopted:  April 7, 2004              Released:  April 8, 2004

By the Commission:  Commissioners Copps and Adelstein issuing 
separate statements. 

I.  INTRODUCTION

     1.   In this  Notice of  Apparent Liability  For  Forfeiture 
(``NAL''),   issued   pursuant   to   section   503(b)   of   the 
Communications Act of 1934, as amended (the ``Act''), and section 
1.80 of  the  Commission's rules,1  we  find that  the  captioned 
licensees,  all  of  which  are  subsidiaries  of  Clear  Channel 
Communications, Inc. (``Clear Channel''), apparently violated  18 
U.S.C.  §  1464  and  47  C.F.R.  §  73.3999,  by  willfully  and 
repeatedly airing  program material  during two  segments of  the 
``Howard Stern Show'' on April  9, 2003, that apparently  violate 
the federal  restrictions  regarding the  broadcast  of  indecent 
material.2  Based upon the totality of the evidence before us and 
Clear  Channel's  history  of  repeated  broadcasts  of  indecent 
material over stations licensed to its subsidiaries, we  conclude 
that these Clear Channel  subsidiaries are apparently liable  for 
forfeitures totaling  Four Hundred  Ninety-Five Thousand  Dollars 
($495,000.00).   Clear   Channel  Broadcasting   Licenses,   Inc. 
(``CCBL'') is apparently liable for a monetary forfeiture in  the 
amount of Two Hundred  Forty-Seven Thousand Five Hundred  Dollars 
($247,500.00) for nine (9)  apparent indecency violations on  its 
captioned stations.  Citicasters Licenses, L.P. (``Citicasters'') 
is apparently liable for a monetary for forfeiture in the  amount 
of One Hundred Sixty-five Thousand Dollars ($165,000.00) for  six 
(6) apparent  indecency  violations on  its  captioned  stations. 
Capstar TX Limited Partnership (``Capstar'') is apparently liable 
for a monetary  forfeiture in the  amount of Eighty-Two  Thousand 
Five  Hundred  Dollars  ($82,500.00)  for  three  (3)   indecency 
violations on its captioned station.  

II.  BACKGROUND


     2.   The Enforcement  Bureau received  a complaint  alleging 
that Station WBGG-FM aired indecent material during the  ``Howard 
Stern Show,'' on  April 9, 2003,  between approximately 7:25  and 
7:45  a.m.  The  complainant  submitted  a  transcript  of   this 
broadcast.3  The material at issue includes dialogue between cast 
members regarding the  sexual practices of  certain program  cast 
members and a discussion with a guest regarding ``Sphincterine,'' 
a purported personal  hygiene product designed  for use prior  to 
sexual activity. 4 

     3.   The Enforcement Bureau sent Clear Channel  Broadcasting 
Licenses, Inc., the licensee of the station, a letter of inquiry, 
and attached the transcript submitted by the complainant.5 In its 
response, Clear Channel, as the ultimate parent of the  licensee, 
acknowledges that on April 9, 2003, between 6:00 and 11:00  a.m., 
WBGG-FM broadcast the  ``Howard Stern Show,''  which it  receives 
via a  satellite  feed.  6  Clear  Channel  further  states  that 
because the station does not  receive transcriptions of the  show 
or  make  recordings  of  the  show,  it  cannot  ``confirm  with 
certainty'' that  the  material  provided  in  the  complainant's 
transcription was  included in  the  station's broadcast  of  the 
``Howard Stern Show'' on  the date and at  the time indicated  in 
the complaint.7  Clear Channel submitted the Declaration of WBGG-
FM's producer, however, who stated that he recalled the  material 
at issue and that his records do not indicate that he deleted  or 
``flushed'' any of the material aired during the station's  April 
9 broadcast of the Howard Stern Show.8  

     4.   Clear Channel also states that, in addition to WBGG-FM, 
five other stations licensed to its subsidiaries air the ``Howard 
Stern Show,'' and  presumably aired  the complained-of  program.9  
Clear Channel further  states that  none of  these five  stations 
make permanent  recordings  of  the ``Howard  Stern  Show,''  and 
therefore cannot confirm the date and time of their broadcasts.10  
Clear Channel admits however, that there is no specific reason to 
question that each of these five stations broadcast the April  9, 
2003, ``Howard Stern Show'' on that day and in its entirety.11 

III.   DISCUSSION

     5.   The Federal Communications Commission is authorized  to 
license  radio   and  television   broadcast  stations   and   is 
responsible for enforcing the  Commission's rules and  applicable 
statutory provisions concerning the operation of those  stations.  
The Commission's  role  in  overseeing program  content  is  very 
limited.  The First Amendment  to the United States  Constitution 
and section 326 of the Act prohibit the Commission from censoring 
program material and from interfering with broadcasters'  freedom 
of  expression.12   The  Commission   does,  however,  have   the 
authority  to   enforce  statutory   and  regulatory   provisions 
restricting indecency  and  obscenity.   Specifically,  it  is  a 
violation  of  federal  law  to  broadcast  obscene  or  indecent 
programming.  Title 18  of the United  States Code, section  1464 
prohibits the  utterance of  ``any obscene,  indecent or  profane 
language by  means  of  radio  communication.''13   In  addition, 
section 73.3999 of the Commission's rules provides that radio and 
television stations shall not  broadcast obscene material at  any 
time, and shall not broadcast indecent material during the period 
6 a.m. through 10 p.m.  

     6.   Under section 503(b)(1) of the  Act, any person who  is 
determined by  the Commission  to  have willfully  or  repeatedly 
failed to  comply with  any provision  of the  Act or  any  rule, 
regulation, or order issued by the Commission shall be liable  to 
the United States for a forfeiture penalty.14  In order to impose 
such a forfeiture penalty, the Commission must issue a notice  of 
apparent liability, the notice must  be received, and the  person 
against whom the notice has been issued must have an  opportunity 
to show, in  writing, why  no such forfeiture  penalty should  be 
imposed.15  The Commission  will then  issue a  forfeiture if  it 
finds by  a preponderance  of the  evidence that  the person  has 
violated the Act  or a  Commission rule.16   As we  set forth  in 
greater detail below, we conclude under this standard that  Clear 
Channel is apparently  liable for a  forfeiture for its  apparent 
willful violation of 18 U.S.C. § 1464 and section 73.3999 of  the 
Commission's rules.

             A.     Indecency Analysis

     7.   Any  consideration   of   government   action   against 
allegedly indecent programming  must take into  account the  fact 
that such speech is protected  under the First Amendment.17   The 
federal courts consistently have  upheld Congress's authority  to 
regulate  the  broadcast  of  indecent  material,  as  well   the 
Commission's interpretation and  implementation of the  governing 
statute.18  Nevertheless,  the  First  Amendment  is  a  critical 
constitutional  limitation  that   demands  that,  in   indecency 
determinations,  we  proceed  cautiously  and  with   appropriate 
restraint.19  

     8.   The Commission  defines  indecent  speech  as  language 
that, in  context,  depicts  or  describes  sexual  or  excretory 
activities or organs in terms  patently offensive as measured  by 
contemporary community standards for the broadcast medium.20  

           Indecency findings  involve  at  least  two 
           fundamental  determinations.   First,   the 
           material alleged to  be indecent must  fall 
           within the  subject  matter  scope  of  our 
           indecency definition¾that is, the  material 
           must describe or depict sexual or excretory 
           organs or  activities. .  . .  Second,  the 
           broadcast must  be  patently  offensive  as 
           measured    by    contemporary    community 
           standards for the broadcast medium.21

     9.   As an initial matter,  the material at issue  described 
sexual and  excretory activities  and organs,  and Clear  Channel 
does not  dispute  this.22   The  material,  therefore,  warrants 
further scrutiny  to determine  whether or  not it  was  patently 
offensive as measured by contemporary community standards for the 
broadcast medium.23  

     10.  In our  assessment  of whether  broadcast  material  is 
patently offensive,  ``the full  context  in which  the  material 
appeared is  critically important.''24   Three principal  factors 
are significant to this contextual analysis: (1) the explicitness 
or graphic nature  of the description;  (2) whether the  material 
dwells  on  or  repeats  at  length  descriptions  of  sexual  or 
excretory organs  or activities;  and  (3) whether  the  material 
appears to  pander  or  is  used to  titillate  or  shock.25   In 
examining these three factors, we must weigh and balance them  to 
determine whether the  broadcast material  is patently  offensive 
because ``[e]ach indecency case  presents its own particular  mix 
of these, and possibly, other factors.''26  In particular  cases, 
one or  two  of  the  factors may  outweigh  the  others,  either 
rendering  the   broadcast   material  patently   offensive   and 
consequently  indecent,27   or,   alternatively,   removing   the 
broadcast material from the realm of indecency.28  We now turn to 
an analysis of these  factors as they relate  to each segment  to 
determine whether the  material that was  broadcast, in  context, 
was patently  offensive  as measured  by  contemporary  community 
standards.

     11.  First, we find  that the  segment in  which the  show's 
host discusses the sexual practices of certain cast members to be 
patently offensive.  Specifically,  the host,  in discussing  the 
sex life of John,  a fellow cast member,  and John's wife,  notes 
that they ``have  anal every  other time  they do  it'' and  that 
John's wife ``loves anal.''29  The host further discusses  John's 
wife's embarrassment that intimate details of their sex life  are 
a topic of public discussion.30   This segment also includes  the 
host's comments regarding his  personal revulsion at the  thought 
of  a  naked,  sweaty,  obese  man  engaging  in   cunnilingus.31  
Finally, during  this entire  segment, the  host's discussion  of 
anal sex and  his commentary on  oral sex are  punctuated by  the 
sound of someone passing gas  or evacuating.  Given the  explicit 
description of oral sex  and the sustained  discussion of a  cast 
member's anal-sex  practices, all  of which  were accompanied  by 
sound effects of flatulence and evacuation, it is clear that  the 
material was  designed  to shock  and  pander.  This  segment  is 
similar  to  material   found  to   contain  patently   offensive 
descriptions of  sexual activities.32  Accordingly, we  find  the 
material in this segment  of the April 9,  2003, broadcast to  be 
patently  offensive   as  measured   by  contemporary   community 
standards for the broadcast medium, and thus indecent.

     12.  Based on our  finding that this  segment appears to  be 
actionably indecent, we disagree with Clear Channel's  contention 
that this material is not patently offensive because it was  less 
explicit than other material found to be not actionably  indecent 
in various unpublished staff  decisions.33  Some of the  material 
at issue in  these unpublished decisions  was less explicit  than 
the material at issue here.34  To  the extent that the staff,  in 
other unpublished decisions,35 may have erred by determining that 
the material in those cases  was not indecent, those  unpublished 
decisions  are  not  binding   on  the  Commission.36   That   is 
particularly the case here, where published decisions,  including 
those cited  in  the  Commission's  Indecency  Policy  Statement, 
provide guidance indicating that material such as that  contained 
in this case is indecent.  In the instant case, we find that  the 
complained-of material  in this  segment included  references  to 
sexual activity through  both direct  references and/or  innuendo 
that we  deem  patently  offensive as  measured  by  contemporary 
community standards for the broadcast medium.37  This material is 
similar to other material found to contain sufficiently  explicit 
and graphic references to sexual activity, and thus satisfies the 
first  factor  of  our  contextual  analysis.38   Moreover,   the 
references  to  sexual  activity  are  repeated  throughout   the 
segment, and the entire segment  dwells on the sexual  activities 
of certain cast members.  The  manner in which this material  was 
presented establishes, under the  third factor, that the  segment 
was used to pander, titillate and shock listeners.

     13.  In the other relevant segment, there is a discussion of 
``Sphincterine,'' a purported personal hygiene product.  We  also 
find that this segment is patently offensive.  Specifically,  the 
show's host  interviewed  the inventor  of  ``Sphincterine''  and 
promoted the  sale of  the product.   During the  course of  this 
interview, the host  and guest made  repeated references to  oral 
sex and  to the  olfactory aspects  of excretory  activity.   For 
instance,  the   host  noted   that   the  guest   had   invented 
``Sphincterine'' because ``a  chick was giving  you oral and  you 
had `swamp  ass'.''39   The host  elicited  specific  information 
about the encounter  that lead  to the creation  of the  product, 
namely that  odors emanating  from  the inventor's  genital  area 
repelled his  girlfriend  when  she  had  attempted  to  initiate 
fellatio.40   Finally,  this  segment,   like  the  earlier   one 
involving discussions involving anal  sex, was interspersed  with 
the sound of  flatulence.  Given the  detailed discussion of  the 
sounds and  smells associated  with excretory  activity and  oral 
sex, which were  accompanied by the  sound effects of  flatulence 
and were dwelled upon, it is clear that the material was used  to 
shock and pander.  Accordingly, we also find the material in this 
segment of the April 9, 2003, broadcast to be patently  offensive 
as measured by contemporary community standards for the broadcast 
medium.  

     14.  We disagree  with Clear  Channel's argument  that  this 
material does not dwell  on or repeat  at length descriptions  of 
sexual or  excretory activities  and that  the material  was  not 
intended to pander, nor was  it presented for its shock  value.41  
The  discussion  of  the   use  of  ``Sphincterine,''   including 
references to  sexual and  excretory organs  and activities,  was 
sustained.42  Moreover,  the discussion  included commentary  and 
sound effects such that the tone of the discussion is vulgar  and 
lewd.  There are repeated  flatulence sound effects  interspersed 
in the discussion of the use of  the product prior to sex 43  and 
the show's host  comments on his  own personal hygiene  practices 
such that he would shower before initiating sexual activity  with 
the guest's  girlfriend.44  Thus, unlike  the  unpublished  staff 
decisions cited by Clear Channel,45 the overall context in  which 
the material was presented  appears to have  been used to  pander 
and shock.46

     15.  After reviewing the record,  we believe that these  two 
segments of the April 9, 2003, ``Howard Stern Show'' are patently 
offensive within the meaning of our indecency definition.  As  to 
the  first  segment,  we  find  that  the  material  involving  a 
discussion of the sexual  practices, including anal sex,  between 
certain of the show's cast members, is patently offensive.47   As 
for  the  second  segment,  we   find  that  the  discussion   of 
``Sphincterine,'' a product purportedly developed for maintaining 
anal and genital hygiene, is patently offensive.48  In the second 
segment, two  individuals uttered  apparently indecent  material, 
whereas in the  first segment one  individual uttered  apparently 
indecent material.  The broadcast over Station WBGG-FM took place 
after the  Commission's  notice  that  it  might  treat  separate 
utterances as separate violations.49  We believe that, under  the 
specific circumstances at issue here, it is appropriate to  treat 
the statements  by  each  of  the  individuals  as  two  separate 
utterances and therefore two separate violations, contrary to our 
more traditional  approach  of  treating a  specific  program  or 
program segment as  indecent.50  Consequently,  we conclude  that 
there are  three  (3)  apparent violations  of  the  Commission's 
indecency rules for  each of  the captioned  stations that  aired 
this material.  Three of the  captioned stations are licensed  to 
CCBL, and thus CCBL is apparently liable for a total of nine  (9) 
indecency violations. Citicasters is the  licensee of two of  the 
captioned stations, and thus is apparently liable for a total  of 
six (6) indecency violations, and  Capstar is the license of  one 
captioned station, and thus  is liable for a  total of three  (3) 
indecency violations.  

     16.  It is undisputed  that the  complained-of material  was 
broadcast within the 6 a.m. to 10 p.m. time frame relevant to  an 
indecency determination under section 73.3999 of the Commission's 
rules.  Thus, because there was  a reasonable risk that  children 
may have been in  the audience at the  time that the material  at 
issue was broadcast on April  9, 2003, the material broadcast  is 
legally  actionable.51   By  broadcasting  this  material,  Clear 
Channel apparently violated the prohibitions in 18 U.S.C. §  1464 
and the  Commission's  rule  against  broadcast  indecency.   The 
Commission is aware that the ``Howard Stern Show'' originates and 
is  broadcast  over  stations  owned  by  Infinity   Broadcasting 
Corporation.  We instruct the  Enforcement Bureau to initiate  an 
investigation into  Infinity's broadcast  of the  April 9,  2003, 
``Howard Stern Show'' at issue in this case.     



               B.        Proposed Forfeiture 

     17.  Based upon our review  of the record  in this case,  we 
conclude that  CCBL,  Citicasters and  Capstar,  subsidiaries  of 
Clear Channel, are apparently liable for the willful and repeated 
violation of  our  rules.   The  Commission's  Forfeiture  Policy 
Statement  sets   a  base   forfeiture  amount   of  $7,000   for 
transmission of indecent or obscene materials.52  The  Forfeiture 
Policy Statement also specifies that the Commission shall  adjust 
a forfeiture based upon  consideration of the factors  enumerated 
in section 503(b)(2)(D)  of the  Act, 47  U.S.C. §  503(b)(2)(D), 
such as ``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.''53   In this  case, 
taking all  of these  factors into  consideration, we  find  that 
CCBL, Citicasters  and  Capstar  are apparently  liable  for  the 
maximum statutory forfeiture amount of Twenty-Seven Thousand Five 
Hundred  Dollars   ($27,500.00)  for   each  apparent   indecency 
violation. In particular, there is  a recent history of  indecent 
broadcasts on stations controlled by Clear Channel, the corporate 
parent  of  CCBL,  Citicasters   and  Capstar,  which   justifies 
imposition of the statutory maximum forfeiture amount for each of 
the apparent indecency violations. 54    

     18.  Because we  find  that CCBL,  Citicasters  and  Capstar 
apparently violated 18 U.S.C. §  1464 and Section 73.3999 of  the 
Commission's rules by broadcasting the complained of material and 
that and that each violation is subject to an apparent forfeiture 
in the amount of $27,500, we  conclude that CCBL is liable for  a 
monetary forfeiture  in the  amount  of Two  Hundred  Forty-Seven 
Thousand Five  Hundred  Dollars ($247,500.00),  that  Citicasters 
Licenses, L.P. is apparently liable for a monetary forfeiture  in 
the  amount   of   One  Hundred   Sixty-Five   Thousand   Dollars 
($165,000.00) and  that  Capstar   is  apparently  liable  for  a 
monetary forfeiture  in the  amount of  Eighty-Two Thousand  Five 
Hundred  Dollars  ($82,500.00)   for  willfully  and   repeatedly 
broadcasting indecent material during  the ``Howard Stern  Show'' 
on April 9, 2003.55 Thus, the aggregate forfeiture against  these 
subsidiaries  of  Clear  Channel  is  Four  Hundred   Ninety-Five 
Thousand  Dollars  ($495,000.00).    We  remind  licensees   that 
serious, repeated cases of indecency violations could be  subject 
to license revocation.

IV.        ORDERING CLAUSES

     19.  ACCORDINGLY, IT IS ORDERED, pursuant to section  503(b) 
of the Communications Act of  1934, as amended, and section  1.80 
of the  Commission's  rules,56 that  Clear  Channel  Broadcasting 
Licenses, Inc. is hereby NOTIFIED  of its APPARENT LIABILITY  FOR 
FORFEITURE in the amount of Two Hundred Forty-Seven Thousand Five 
Hundred Dollars ($247,500.00) for willfully violating 18 U.S.C. § 
1464 and section 73.3999 of the Commission's rules.

     20.  IT IS FURTHER  ORDERED, pursuant to  section 503(b)  of 
the Communications Act of 1934,  as amended, and section 1.80  of 
the Commission's  rules,57 that  Citicasters Licenses,  L.P.,  is 
hereby NOTIFIED of its APPARENT  LIABILITY FOR FORFEITURE in  the 
amount of One Hundred  Sixty-Five Thousand Dollars  ($165,000.00) 
for willfully violating 18 U.S.C.  § 1464 and section 73.3999  of 
the Commission's rules.

     21.  IT IS FURTHER ORDERED pursuant to section 503(b) of the 
Communications Act of 1934, as  amended, and section 1.80 of  the 
Commission's rules,58  that  Capstar TX  Limited  Partnership  is 
hereby NOTIFIED of its APPARENT  LIABILITY FOR FORFEITURE in  the 
amount of Eighty-Two Thousand Five Thousand Dollars  ($82,500.00) 
for willfully violating 18 U.S.C.  § 1464 and section 73.3999  of 
the Commission's rules.

     22.  IT IS FURTHER ORDERED, pursuant to section 1.80 of  the 
Commission's rules, that within thirty  (30) days of the  release 
of this NAL, Clear Channel Broadcasting Licenses, Inc. SHALL  PAY 
the full amount of the proposed forfeiture ($247,500.00) or SHALL 
FILE a written statement seeking reduction or cancellation of the 
proposed forfeiture.

     23.  IT IS FURTHER ORDERED, pursuant to section 1.80 of  the 
Commission's rules, that within thirty  (30) days of the  release 
of this NAL, Citicasters Licenses, L.P. SHALL PAY the full amount 
of the proposed forfeiture ($165,000.00) or SHALL FILE a  written 
statement seeking  reduction  or  cancellation  of  the  proposed 
forfeiture.

     24.  IT IS FURTHER ORDERED, pursuant to section 1.80 of  the 
Commission's rules, that within thirty  (30) days of the  release 
of this NAL, Capstar  TX Limited Partnership  SHALL PAY the  full 
amount of the  proposed forfeiture ($82,500.00)  or SHALL FILE  a 
written  statement  seeking  reduction  or  cancellation  of  the 
proposed forfeiture.

     25.  Payment of  the forfeiture  may be  made by  mailing  a 
check or similar instrument, payable to the order of the  Federal 
Communications Commission, to the Forfeiture Collection  Section, 
Finance  Branch,  Federal  Communications  Commission,  P.O.  Box 
73482, Chicago, Illinois  60673-7482.  The  payment MUST  INCLUDE 
the FCC Registration Numbers (``FRN'') referenced above and  also 
should note the NAL/Account Number referenced above.

     26.  The  response,  if  any,  must  be  mailed  to  William 
Davenport,   Chief,   Investigations   and   Hearings   Division, 
Enforcement Bureau, Federal  Communications Commission, 445  12th 
Street, S.W, Room 3-B443, Washington D.C. 20554 and MUST  INCLUDE 
the NAL/Account Number referenced above.

     27.  The Commission will not consider reducing or  canceling 
a forfeiture in response  to a claim of  inability to pay  unless 
the respondent  submits: (1)  federal tax  returns for  the  most 
recent  three-year  period;  (2)  financial  statements  prepared 
according to generally accepted accounting practices  (``GAAP''); 
or (3)  some  other  reliable and  objective  documentation  that 
accurately reflects  the respondent's  current financial  status.  
Any claim  of inability  to pay  must specifically  identify  the 
basis for the claim by  reference to the financial  documentation 
submitted.

     28.  Requests for payment  of the  full amount  of this  NAL 
under an installment plan should  be sent to: Chief, Revenue  and 
Receivables Operations Group, 445 12th Street, S.W.,  Washington, 
D.C. 20554.59 

     29.  Under the Small Business Paperwork Relief Act of  2002, 
Pub L. No.  107-198, 116 Stat.  729 (June 28,  2002), the FCC  is 
engaged in  a two-year  tracking process  regarding the  size  of 
entities involved in forfeitures.  If Clear Channel qualifies  as 
a small entity and if it wishes  to be treated as a small  entity 
for tracking purposes, it should  so certify to us within  thirty 
(30) days of this NAL, either in its response to the NAL or in  a 
separate filing to  be sent  to the  Investigations and  Hearings 
Division.   The  certification  should  indicate  whether   Clear 
Channel, including its parent  entity and its subsidiaries,  meet 
one of the  definitions set  forth in  the list  provided by  the 
FCC's Office of Communications Business Opportunities  (``OCBO'') 
set forth in Attachment B of this NAL.  This information will  be 
used for  tracking purposes  only.  Clear  Channel's response  or 
failure to respond to  this question will have  no effect on  its 
rights and  responsibilities pursuant  to Section  503(b) of  the 
Communications Act.  If Clear Channel has questions regarding any 
of the information contained in  Attachment B, it should  contact 
OCBO at (202) 418-0990.

     30.  Accordingly, IT IS  ORDERED, that  the complaint  filed 
against Station WBGG-FM's broadcast of the ``Howard Stern  Show'' 
on April 9, 2003, IS GRANTED to the extent indicated herein,  AND 
IS OTHERWISE  DENIED,  and  the complaint  proceeding  IS  HEREBY 
TERMINATED.60

     31.  IT IS FURTHER ORDERED, that a copy of this NAL shall be 
sent by Certified Mail Return Receipt Requested to Mr. Richard W. 
Wolf, Vice  President, Clear  Channel Communications,  Inc.,  c/o 
Clear Channel Worldwide, 200 East Basse Road, San Antonio,  Texas 
78209-8328,  to  Clear   Channel  Broadcasting  Licenses,   Inc., 
Citicasters Licenses, L.P., and  Capstar TX Limited  Partnership, 
2625 S. Memorial Drive,  Suite A, Tulsa,  Oklahoma 74129, with  a 
copy to Clear  Channel's counsel, John  M. Burgett, Esq.,  Wiley, 
Rein &  Fielding, LLP,  1776 K  Street, N.W.,  Washington,  D.C., 
20006, and to the complainant. 


                         FEDERAL COMMUNICATIONS COMMISSION
                    

     
                         Marlene H. Dortch
                         Secretary                          ATTACHMENT A

                       Program Transcript

EB-03-IH-0159

Radio Station:      WBGG-FM, Fort Lauderdale, Florida
Date/Time Broadcast:     April 9, 2003, between 7:25 and 7:45 
a.m.
Material Broadcast: The Howard Stern Show


Stern:  ...John's anal talk.  John revealed that in his sex life 
with his wife they have anal every other time they do it.,  
[Sound of flatulence or anal evacuation] which seems excessive.  
Some people wrote in.  Here's one:  ``John must have some 
homosexual fantasies based on his need for [flatulence] anal.  
[flatulence]  We all know it doesn't feel nearly as good as 
straight sex.''  I don't know if a man or a woman wrote that.  
[flatulence]

``Jesus H. Christ, just the thought of that [flatulence] obese 
slob Artie on the bed all sweaty, hairy, and naked giving his 
girlfriend [flatulence] a, what do you call that, using his mouth 
in a really dirty place makes we want to friggin' shoot myself.  
Imagining the scene with Bobbabooey was no better.  
[flatulence].''

Robin:  Oh, my God.

Finally, ``if Stuttering John keeps up with his every other time 
[flatulence][at this point you can clearly hear that something is 
deleted or ``dumped'' from Stern's commentary by means of the 
broadcast delay capability] unless of course he's so small that 
it isn't much of a strain on her.''

John: Hey, Howard, I was only kidding about that.

Stern: No you weren't.  Why, your wife came down on you?

John:  Let's just say it wasn't a pleasant day in the Menendez 
household.

Stern:  Really, why?  Is she embarrassed?

John:  Yes, she doesn't, you know, want our sex life out 
[flatulence].

Stern:  Oh please!  So, what, no more anal?

John:  [flatulence] Let's just say it's every once in awhile 
[flatulence].

Stern:  Aye, yi, yi.  You were lying, then, yesterday.

John:  Yeah, I was lying [flatulence].

Stern:  Okay.  What?

Another voice:  You know what?  The in-laws heard.  That's got to 
be tough.

Stern:  Was it the in-laws?

John:  No, no, she just happened to turn it on and goes ``What is 
this?''

Stern:  But I've heard from her [flatulence] that she loves anal.

John:  Yes, but that's at the dinner table with us, not with the 
whole world listening [flatulence].

Another voice, imitating John's mother-in-law:  I saw you telling 
everyone that you give anal to my daughter.  [flatulence]

* * * 

Stern:  So Bruce, I'm going to let you plug your product 
Sphincterine.  Now I even said I'd let you do your jingle.  Give 
them the Sphincterine jingle, first of all.

Bruce:  All right, this is a band called the Dead Beatles.  
[Musical jingle begins]:  Sphincterine makes you tingle, feel so 
clean.  Oh, Sphincterine. Cleans you sphincter and what's 
between.  Ho, hey!

Stern:  What did you pay for that?

Bruce:  Nothing, that's my band the Dead Beatles.

Stern:  The Sphincterine product.  How much money have you 
invested in this so far would you say?

Bruce:  Probably about twenty grand.

Stern:  And it's ...

Robin:  How much have you made?

Bruce:  I probably have tripled that in just about six months, 
nine months.

Robin:  Really?

Stern:  You say you invented Sphincterine because a chick was 
giving you oral and you had a swamp ass?

Bruce:  Yeah, that's basically it, Howard, yeah.  I had a bad 
experience and my girl friend who's in the green room right now 
was in a spontaneous mood and she caught me at a bad time and ...

Stern:  Is you girlfriend good looking?

Bruce:  Yeah, she's cute.

Stern:  Yeah.  So, oh, let me talk to her.  I want to hear what 
swamp ass smells like.

Bruce:  I'm not sure she's going to want to do this.

Stern:  What, describe swamp ass?

Bruce:  She can describe swamp ass, but I'm not so sure she wants 
to go on the air.

Stern:  So, when you develop a product, are you a chemist, that 
you would know how to do it?

Bruce:  Yes.

Stern:  What?

Bruce:  I'm a chemist.  I develop products for a natural product 
company.  And, uh, ...

Stern:  So you decided to branch out on your own.

Bruce:  Yeah.

Stern:  Oh, there's your girlfriend.  She is cute.

Bruce:  Thank you.

Stern:  So you were giving this animal oral, and you said ``Man 
you've got swamp ass''?  Was that how it went down?

Female Guest (Cat):  Actually no, I went close for oral.

Bruce:  How close?  Nine inches away, I think it was.

Cat:  Yeah.

Stern:  Yeah.  And you just said ...

Robin:  You couldn't get any closer.

Stern:  And you said, ``Oh, my God.  You stink.''  [recording of 
flatulence noise] What happened?  Had you gone to the bathroom 
that day and not showered?

Bruce:  Yeah, it was like the end of the day, and Cat is a 
spontaneous woman and she just caught me with my pants down 
[flatulence noise].

Stern:  Okay [flatulence noise] and you're hot by the way.

Cat:  Thank you.

Stern:  Yeah.  What are you doing with a guy with swamp ass?  
[flatulence]

Bruce:  Hey, it was a one shot deal.

Stern:  Honey, before I'd bang you I'd take a nice shower.

Cat:  You would?

Stern:  Yeah, I sure would

Cat:  Oh.  That would be nice.

Stern:  Yeah.  So ...

Bruce:  I go beyond that.  Now I Sphincterine before I bang her.

Stern:  Talk about Sphincterine.  So, you developed this product, 
and let's say I go to the bathroom, and I don't feel fresh.

Bruce:  You were talking recently about when you go to the 
bathroom, you use toilet paper with water on it.  This product is 
really excellent for that particular situation you have.

Stern:  What is it, a spray bottle or a cream?

Bruce:  It's a liquid, and it also comes in towelettes.  So what 
you've got is something that you, the liquid, that you  apply to 
toilet paper like water, as you once said on the air.

Stern:  I see.

Bruce:  You put it on, it's all natural ingredients.

Stern:  Is it like a baby wipe?

Bruce:  It's like a baby wipe, but those wipes are loaded with 
chemicals and bad ingredients.  This is all natural, and it feels 
good.  And you know, I'm going  to let Cat talk about another 
purpose, uh, Cat.

Stern:  I don't know if I want an infomercial.

Bruce:  No, Howard, this is cool.

Stern:  You know your dog was probably going to beat Artie 
anyway.

Bruce:  The bottom line is that Cat uses it on the front as well.

Stern:  Really?  No problems using that?  It doesn't affect you 
in anyway?

Cat:  No.  Actually, but it has a nice effect.  It makes you 
tingle...   

 October 2002
                          ATTACHMENT B


                FCC List of Small Entities

   As described below, a ``small entity'' may be a small 
                       organization,
  a small governmental jurisdiction, or a small business.

(1)  Small Organization 
Any not-for-profit enterprise that is independently owned 
and operated and 
is not dominant in its field.

  
(2)  Small Governmental Jurisdiction
Governments of cities, counties, towns, townships, villages, 
school districts, or 
special districts, with a population of less than fifty 
thousand.


(3)  Small Business
Any business concern that is independently owned and 
operated and 
is not dominant in its field, and meets the pertinent size 
criterion described below.
  

      Industry Type          Description of Small Business 
                                     Size Standards
                 Cable Services or Systems
                            Special Size Standard - 
Cable Systems                Small Cable Company has 400,000 
                            Subscribers Nationwide or Fewer
Cable and Other Program 
Distribution                     $12.5 Million in Annual 
                                    Receipts or Less

Open Video Systems 
       Common Carrier Services and Related Entities
Wireline Carriers and 
Service providers 
                                1,500 Employees or Fewer
Local Exchange Carriers, 
Competitive Access 
Providers, Interexchange 
Carriers, Operator Service 
Providers, Payphone 
Providers, and Resellers


Note:  With the exception of Cable Systems, all size 
standards are expressed in either millions of dollars or 
number of employees and are generally the average annual 
receipts or the average employment of a firm.  Directions 
for calculating average annual receipts and average 
employment of a firm can be found in 
13 CFR 121.104 and 13 CFR 121.106, respectively.





                  International Services
International Broadcast 
Stations






                                $12.5 Million in Annual 
                                    Receipts or Less
International Public Fixed 
Radio (Public and Control 
Stations)
Fixed Satellite 
Transmit/Receive Earth 
Stations
Fixed Satellite Very Small 
Aperture Terminal Systems
Mobile Satellite Earth 
Stations
Radio Determination 
Satellite Earth Stations
Geostationary Space Stations
Non-Geostationary Space 
Stations
Direct Broadcast Satellites
Home Satellite Dish Service
                    Mass Media Services
Television Services

                             $12 Million in Annual Receipts 
                                        or Less
Low Power Television 
Services and Television 
Translator Stations
TV Auxiliary, Special 
Broadcast and Other Program 
Distribution Services
Radio Services
                             $6 Million in Annual Receipts 
                                        or Less
Radio Auxiliary, Special 
Broadcast and Other Program 
Distribution Services
Multipoint Distribution      Auction Special Size Standard -
Service                      Small Business is less than 
                            $40M in annual gross revenues 
                            for three preceding years
          Wireless and Commercial Mobile Services
Cellular Licensees
                                1,500 Employees or Fewer
220 MHz Radio Service - 
Phase I Licensees
220 MHz Radio Service -      Auction special size standard -
Phase II Licensees           Small Business is average gross 
                            revenues of $15M or less for 
                            the preceding three years 
                            (includes affiliates and 
                            controlling principals)
                            Very Small Business is average 
                            gross revenues of $3M or less 
                            for the preceding three years 
                            (includes affiliates and 
                            controlling principals)
700 MHZ Guard Band Licensees


Private and Common Carrier 
Paging
Broadband Personal 
Communications Services          1,500 Employees or Fewer
(Blocks A, B, D, and E)
Broadband Personal           Auction special size standard -
Communications Services      Small Business is $40M or less 
(Block C)                    in annual gross revenues for 
                            three previous calendar years
                            Very Small Business is average 
                            gross revenues of $15M or less 
                            for the preceding three 
                            calendar years (includes 
                            affiliates and persons or 
                            entities that hold interest in 
                            such entity and their 
                            affiliates)
Broadband Personal 
Communications Services 
(Block F)
Narrowband Personal 
Communications Services


Rural Radiotelephone Service     1,500 Employees or Fewer
Air-Ground Radiotelephone 
Service
800 MHz Specialized Mobile   Auction special size standard -
Radio                        Small Business is $15M or less 
                            average annual gross revenues 
                            for three preceding calendar 
                            years
900 MHz Specialized Mobile 
Radio
Private Land Mobile Radio        1,500 Employees or Fewer
Amateur Radio Service                      N/A
Aviation and Marine Radio 
Service                          1,500 Employees or Fewer
Fixed Microwave Services
                            Small Business is 1,500 
Public Safety Radio Services employees or less
                            Small Government Entities has 
                            population of less than 50,000 
                            persons
Wireless Telephony and 
Paging and Messaging             1,500 Employees or Fewer
Personal Radio Services                    N/A
Offshore Radiotelephone          1,500 Employees or Fewer
Service
Wireless Communications      Small Business is $40M or less 
Services                     average annual gross revenues 
                            for three preceding years
                            Very Small Business is average 
                            gross revenues of $15M or less 
                            for the preceding three years 

39 GHz Service
                            Auction special size standard 
                            (1996) -
Multipoint Distribution      Small Business is $40M or less 
Service                      average annual gross revenues 
                            for three preceding calendar 
                            years
                            Prior to Auction -
                            Small Business has annual 
                            revenue of $12.5M or less
Multichannel Multipoint 
Distribution Service             $12.5 Million in Annual 
                                    Receipts or Less
Instructional Television 
Fixed Service
                            Auction special size standard 
                            (1998) -
Local Multipoint             Small Business is $40M or less 
Distribution Service         average annual gross revenues 
                            for three preceding years
                            Very Small Business is average 
                            gross revenues of $15M or less 
                            for the preceding three years 
                            First Auction special size 
                            standard (1994) -
                            Small Business is an entity 
                            that, together with its 
                            affiliates, has no more than a 
218-219 MHZ Service          $6M net worth and, after 
                            federal income taxes (excluding 
                            carryover losses) has no more 
                            than $2M in annual profits each 
                            year for the previous two years
                            New Standard - 
                            Small Business is average gross 
                            revenues of $15M or less for 
                            the preceding three years 
                            (includes affiliates and 
                            persons or entities that hold 
                            interest in such entity and 
                            their affiliates)
                            Very Small Business is average 
                            gross revenues of $3M or less 
                            for the preceding three years 
                            (includes affiliates and 
                            persons or entities that hold 
                            interest in such entity and 
                            their affiliates)
Satellite Master Antenna 
Television Systems               $12.5 Million in Annual 
                                    Receipts or Less
24 GHz - Incumbent Licensees     1,500 Employees or Fewer
24 GHz - Future Licensees    Small Business is average gross 
                            revenues of $15M or less for 
                            the preceding three years 
                            (includes affiliates and 
                            persons or entities that hold 
                            interest in such entity and 
                            their affiliates)
                            Very Small Business is average 
                            gross revenues of $3M or less 
                            for the preceding three years 
                            (includes affiliates and 
                            persons or entities that hold 
                            interest in such entity and 
                            their affiliates)
                       Miscellaneous
On-Line Information Services  $18 Million in Annual Receipts 
                                        or Less
Radio and Television 
Broadcasting and Wireless 
Communications Equipment          750 Employees or Fewer
Manufacturers
Audio and Video Equipment 
Manufacturers
Telephone Apparatus 
Manufacturers (Except            1,000 Employees or Fewer
Cellular)
Medical Implant Device            500 Employees or Fewer
Manufacturers
Hospitals                     $29 Million in Annual Receipts 
                                        or Less
Nursing Homes                    $11.5 Million in Annual 
                                    Receipts or Less
Hotels and Motels             $6 Million in Annual Receipts 
                                        or Less
Tower Owners                 (See Lessee's Type of Business)



                          STATEMENT OF
                  COMMISSIONER MICHAEL J. COPPS

Re: Clear Channel Broadcasting Licenses, Inc., Licensee of 
Stations WBGG-FM, Fort Lauderdale, Florida, WTKS-FM, Cocoa Beach, 
Florida, and WTFX-FM, Louisville, Kentucky; Citicasters Licenses, 
L.P., Licensee, Stations KIOZ(FM), San Diego, California, and 
WNVE(FM), Honeoye Falls, New York; and Capstar TX Limited 
Partnership, Licensee of Station WXDX-FM, Pittsburgh, 
Pennsylvania, Notice of Apparent Liability for Forfeiture

     I have long advocated that the Commission use all of the 
tools it has to tackle indecency on the public's airwaves.  
Today's decision is a step forward towards imposing meaningful 
fines.  For the first time, the Commission assesses a fine 
against more than a single utterance, rather than counting an 
entire program as one utterance.  In addition, the Commission 
makes clear that its indecency enforcement will address not only 
the station that is the subject of a complaint, but also any 
other station that aired the same programming.  I therefore vote 
to approve this decision.  



                             STATEMENT OF 
                  COMMISSIONER JONATHAN S. ADELSTEIN


     Re:  Clear Channel Broadcasting Licenses, Inc., Licensee of 
     Stations WBGG-FM, Fort Lauderdale, Florida, WTKS-FM, Cocoa 
     Beach, Florida, WTFX-FM, Louisville, Kentucky; Citicasters 
     Licenses, L.P., Licensee of Stations KIOZ(FM), San Diego, 
     California, WNVE(FM), Honeoye Falls, New York; Capstar TX 
     Limited Partnership, Licensee of Station WXDX-FM, 
     Pittsburgh, Pennsylvania; Notice of Apparent Liability for 
     Forfeiture


     I support this Notice of Apparent Liability for the 
broadcast of indecent material at a time when children may be in 
the audience.  By issuing this NAL, we step up to our 
responsibility to enforce statutory and regulatory provisions 
restricting broadcast indecency.  For the first time, we impose 
fines based upon separate utterances.  While this is not the most 
egregious case that I have seen, the material broadcast is 
indecent under our standards and the fines appropriately account 
for the violation of our rules.  

     Since I arrived at the Commission, we have greatly stepped 
up our enforcement against indecent broadcasts.  I expect that 
stepped-up actions like those we take today will convince 
broadcasters that they cannot ignore their responsibility to 
serve the public interest and to avoid the broadcast of indecent 
material over the public airwaves.    



_________________________

1 47 U.S.C. § 503(b); 47 C.F.R. § 1.80.
2 See 18  U.S.C. §  1464, 47  C.F.R. §  73.3999 and  47 U.S.C.  § 
503(b).  
3  Letter  from  complainant,  to  Enforcement  Bureau,   Federal 
Communications Commission, dated April 24, 2003.    
4 Attachment A, Program Transcript.  
5 Letter from  the Chief, Investigations  and Hearings  Division, 
Enforcement Bureau, to Clear Channel Broadcasting Licenses, Inc., 
dated July 18, 2003.  
6  See Letter from Richard W. Wolf, Vice President, Clear Channel 
Communications, Inc., to  Marlene H.  Dortch, Secretary,  Federal 
Communications Commission, dated August 18, 2003 (``Clear Channel 
Response''), at 1.
7 Id.  
8 Clear Channel  Response at  1 and Declaration  of Clint  Ferro, 
WBGG-FM producer  for the  ``Howard Stern  Show.'' Clear  Channel 
indicates that WBGG-FM broadcasts the show on a 7.5-second  delay 
so that it can block out  or ``flush'' any material that it  does 
not want to air.
9 Id.  at 2-4.   The  five other  stations are:   WTKS-FM,  Cocoa 
Beach, Florida; WTFX-FM, Louisville, Kentucky; WNVE(FM),  Honeoye 
Falls, New York;  KIOZ(FM), San Diego,  California; and  WXDX-FM, 
Pittsburgh, Pennsylvania.  
10 Clear Channel Response at 2-4.
11 Id.
12 See U.S. CONST., amend. I; 47 U.S.C. § 326.
13 18 U.S.C. § 1464. 
14 47 U.S.C. § 503(b)(1)(B); 47 C.F.R. § 1.80(a)(1); see also  47 
U.S.C. § 503(b)(1)(D)(forfeitures  for violation of  18 U.S.C.  § 
1464).  Section 312(f)(1)  of the  Act defines  willful as  ``the 
conscious and  deliberate commission  or omission  of [any]  act, 
irrespective of any  intent to  violate'' the law.   47 U.S.C.  § 
312(f)(1). The legislative  history to section  312(f)(1) of  the 
Act clarifies that  this definition  of willful  applies to  both 
sections 312 and 503(b)  of the Act, H.R.  Rep. No. 97-765,  97th 
Cong. 2d Sess. 51 (1982),  and the Commission has so  interpreted 
the term in the section  503(b) context.  See, e.g.,  Application 
for Review of  Southern California  Broadcasting Co.,  Memorandum 
Opinion and  Order,  6  FCC Rcd  4387,  4388  (1991)  (``Southern 
California Broadcasting Co.'').  The Commission may also assess a 
forfeiture for  violations  that  are merely  repeated,  and  not 
willful.  See,  e.g.,  Callais  Cablevision,  Inc.,  Grand  Isle, 
Louisiana, Notice of Apparent Liability for Monetary  Forfeiture, 
16 FCC Rcd 1359  (2001) (issuing a  Notice of Apparent  Liability 
for, inter alia,  a cable television  operator's repeated  signal 
leakage).  ``Repeated'' merely means  that the act was  committed 
or omitted more than once, or lasts more than one day.   Southern 
California Broadcasting  Co., 6  FCC Rcd  at 4388,  ¶ 5;  Callais 
Cablevision, Inc., 16 FCC Rcd at 1362, ¶ 9.    
15 47 U.S.C. § 503(b); 47 C.F.R. § 1.80(f).
16 See, e.g.,  SBC Communications, Inc.,  Apparent Liability  for 
Forfeiture,  Forfeiture  Order,  17  FCC  Rcd  7589,  7591,  ¶  4 
(2002)(forfeiture paid). 
17 U.S. CONST., amend. I; see Action for Children's Television v. 
FCC, 852 F.2d 1332, 1344 (D.C. Cir. 1988) (``ACT I'').
18 Title 18 of the United States Code, Section 1464 (18 U.S.C.  § 
1464), prohibits  the utterance  of  ``any  obscene, indecent  or 
profane language  by means  of  radio communication.''   FCC   v. 
Pacifica Foundation, 438 U.S.  726 (1978).  See  also ACT I,  852 
F.2d at 1339; Action for  Children's Television v. FCC, 932  F.2d 
1504, 1508 (D.C. Cir.  1991), cert. denied,  503 U.S. 914  (1992) 
(``ACT II''); Action for Children's  Television v. FCC, 58 F.  3d 
654 (D.C. Cir. 1995), cert.  denied, 516 U.S. 1043 (1996)  (``ACT 
III'').     
19 ACT I, 852 F.2d at 1344 (``Broadcast material that is indecent 
but not obscene is protected by the First Amendment; the FCC  may 
regulate such material only with  due respect for the high  value 
our Constitution places on freedom and choice in what people  may 
say and hear.''), ACT I, 852 F.2d at 1340, n.14 (``the  potential 
chilling effect of the FCC's generic definition of indecency will 
be tempered by the Commission's restrained enforcement policy.'')
20 Infinity Broadcasting Corporation  of Pennsylvania, 2 FCC  Rcd 
2705   (1987)(subsequent    history   omitted)(citing    Pacifica 
Foundation, 56  FCC 2d  94,  98 (1975),  aff'd  sub nom.  FCC  v. 
Pacifica Foundation, 438 U.S. 726 (1978)).  
21 Industry Guidance on the Commission's Case Law Interpreting 18 
U.S.C.  §1464  and   Enforcement  Policies  Regarding   Broadcast 
Indecency (``Indecency  Policy  Statement''), 16  FCC  Rcd  7999, 
8002, ¶¶ 7-8 (2001) (emphasis in original).
22 Clear Channel Response at 5.
23  The  ``contemporary  standards  for  the  broadcast  medium'' 
criterion is  that  of an  average  broadcast listener  and  with 
respect  to  Commission   decisions,  does   not  encompass   any 
particular geographic area.   See Indecency  Policy Statement  at 
8002, ¶ 8 and n. 15.
24 Id. at 8002, ¶ 9 (emphasis in original).  
25 Id. at 8002-15, ¶¶ 8-23.  
26 Id. at 8003, ¶ 10.
27 Id. at 8009, ¶ 19  (citing Tempe Radio, Inc (KUPD-FM), 12  FCC 
Rcd 21828  (MMB 1997)  (forfeiture  paid) (extremely  graphic  or 
explicit nature of references to sex with children outweighed the 
fleeting  nature  of  the  references);  EZ  New  Orleans,   Inc. 
(WEZB(FM)), 12 FCC Rcd 4147 (MMB 1997) (forfeiture paid) (same). 
28 Id. at 8010, ¶ 20 (``the manner and purpose of a  presentation 
may well preclude  an indecency determination  even though  other 
factors, such  as  explicitness,  might  weigh  in  favor  of  an 
indecency finding'').
29 Attachment A at 11-12. Id.
30 Id.  
31 Id. at 11.  There  is a reference to  oral sex as ``using  his 
mouth in  a  really  dirty  place.''   To  the  extent  that  the 
discussion also used innuendo, rather than direct references,  it 
is nonetheless  sufficient  to  render  the  material  actionably 
indecent because  the  sexual  import  of  those  references  was 
``unmistakable.''  See Indecency Policy Statement, 16 FCC Rcd  at 
8002-04, ¶¶ 9-12 (2001).   
32  See,  e.g., Citicasters  Co. (KEGL(FM)),  Notice of  Apparent 
Liability  for  Monetary   Forfeiture,  16  FCC   Rcd  7546   (EB 
2001)(forfeiture paid)(conversation  among hosts  and adult  film 
actors concerning,  among  other  things,  oral  and  anal  sex); 
Infinity Broadcasting Corporation  of Pennsylvania (WYSP(FM)),  3 
FCC Rcd 930, 932-33 ¶ 20 (1987)(subsequent history omitted).  
33 See Clear Channel Response at 4-5, citing various  unpublished 
staff denials.   
34 See Letter from Charles  W. Kelley, Chief, Investigations  and 
Hearings Division, Enforcement Bureau, dated May 3, 2002, EB -01-
IH-0326; Letter from Charles W. Kelley, Chief, Investigations and 
Hearings Division, Enforcement Bureau, dated April. 23, 2002,  EB 
-02-IH-0078; Letter from Charles W. Kelley, Chief, Investigations 
and Hearings Division,  Enforcement Bureau, dated  Feb. 5,  2002, 
EB-01-IH-0357.  
35 See  Clear Channel  Response  at 4-5,  citing Memo  from  Thom 
Winkler to WIOD(AM) Complaint File, dated Apr. 21, 1997, FCC Ref. 
No. 91010196; Letter from Norman Goldstein, Chief, Complaints and 
Political Programming  Branch, Enforcement  Division, Mass  Media 
Bureau, dated May 15,  1997, FCC Ref.  No. 94069521; Letter  from 
Norman Goldstein,  Chief,  Complaints and  Political  Programming 
Branch, Enforcement Division, Mass  Media Bureau, dated Jan.  23, 
1997, FCC Ref. No. 94110410.
36 See, e.g., Amor Family Broadcasting Group v. FCC, 918 F. 2d 
960, 962 (D.C. Cir. 1990), citing Homemakers North Shore, Inc. v. 
Bowen, 832 F.2d 408, 413 (7th  Cir. 1987).  See also Lorenzo 
Jelks v. FCC, 146 F.3d 878, 881 (D.C. Cir. 1998).    

37 See Attachment A, Program Transcript at 11-12.
38  See  Clear  Channel  Broadcasting  Licenses,   Inc.(WPLA(FM), 
WCKT(FM)), Notice of Apparent Liability for Monetary  Forfeiture, 
19 FCC Rcd 1768, ¶ 9 (2004). 
39 Attachment A, Program Transcript at 12.  
40 Id. at 13.
41 Clear Channel Response at 6.
42 See, e.g., Emmis Radio License Corporation (WKQX(FM)),  Notice 
of Apparent Liability for Monetary  Forfeiture, 17 FCC Rcd  5263, 
5266 ¶¶  10-11  (EB  2002); Apparent  Liability  for  Forfeiture, 
Forfeiture Order, 17 FCC Rcd 21697,  21699 ¶ 9 (EB 2002),  recon. 
denied, Memorandum Opinion and Order, 19 FCC Rcd 2697 (EB 2004).  
43 Attachment A, Program Transcript, at 12-14.  
44  Id. at 12.
45 Clear Channel  Response at  6, citing Letter  from Charles  W. 
Kelley, Chief, Investigations and Hearings Division,  Enforcement 
Bureau, dated Feb. 5, 2002, EB-01-IH-0315; Letter from Charles W. 
Kelley, Chief, Investigations and Hearings Division,  Enforcement 
Bureau, dated April 22, 2002, EB-02-IH-0040.
46 See,  e.g.,  Citicasters  Co (KSJO(FM)),  Notice  of  Apparent 
Liability for  Monetary Forfeiture, 15  FCC Rcd 19095, 19096,  ¶6 
(EB  2000)(forfeiture  paid)  (discussion  of  sexual  techniques 
featuring  nationally  recognized  sex  therapist  and  certified 
clinical  sexologist  presented  in  pandering  and   titillating 
manner).  
47 Attachment A, Program Transcript at 11-12, ending at ``***.''
48 Id. at 12-14, beginning after ``***.''
49 Infinity Broadcasting Operations,  Inc., (WKRK-FM), Notice  of 
Apparent Liability  for Monetary  Forfeiture,  18 FCC  Rcd  6915, 
6918-19,  ¶  12  (2003),   Apparent  Liability  for   Forfeiture, 
Forfeiture Order, 18 FCC 26360 (2003), recon. denied, 19 FCC  Rcd 
____,  FCC 04-34 (rel. Mar. 5, 2004).
50 In  this regard,  we  note that,  depending  on the  facts  in 
specific cases, we may also treat  some of the specific words  or 
phrases spoken  by  one  individual  to  be  separate  utterances 
themselves and therefore separate violations.
51 See ACT III, 58 F.3d at 660-63.    
52 The Commission's Forfeiture Policy Statement and Amendment  of 
Section  1.80  of  the   Rules  to  Incorporate  the   Forfeiture 
Guidelines, 12 FCC Rcd 17087, 17113 (1997), recon. denied 15  FCC 
Rcd 303  (1999) (``Forfeiture  Policy Statement'');  47 C.F.R.  § 
1.80(b).  The  Commission  amended  its  rules  to  increase  the 
maximum  penalties  to  account  for  inflation  since  the  last 
adjustment  of  the  penalty  rates.   The  new  rates  apply  to 
violations that occur or continue  after November 13, 2000.   See 
Order, In  the Matter  of  Amendment of  Section 1.80(b)  of  the 
Commission's Rules and Adjustment of Forfeiture Maxima to Reflect 
Inflation, 15 FCC Rcd 18221 (2000).
53 Forfeiture Policy Statement, 12 FCC Rcd at 17100-01, ¶ 27.
54 AMFM  Radio  Licenses,  LLC  (WWDC(FM)),  Notice  of  Apparent 
Liability for  Monetary  Forfeiture,  18  FCC  Rcd  19917  (2003) 
(forfeiture paid); Citicasters Co. (KEGL(FM)), Notice of Apparent 
Liability for  Monetary  Forfeiture 16  FCC  Rcd 7546  (EB  2001) 
(forfeiture paid); Citicasters Co. (KSJO(FM)), Notice of Apparent 
Liability for Monetary  Forfeiture, 15  FCC Rcd  19095 (EB  2000) 
(forfeiture paid); Citicasters Co. (KSJO(FM)), Notice of Apparent 
Liability for Monetary  Forfeiture, 15  FCC Rcd  19091 (EB  2000) 
(forfeiture paid).  
55 The forfeiture  amount proposed against  each station of  each 
Clear Channel  subsidiary  is allocated  on  the basis  of  three 
indecency violations per station,  and $27,500.00 per  violation, 
for a total of $82,500.00 (3 x $27,500.00) per station.  
56 47 C.F.R. § 1.80.
57 47 C.F.R. § 1.80.
58 47 C.F.R. § 1.80.
59 See 47 C.F.R. § 1.1914.
60 Consistent  with  section 503(b)  of  the Act  and  consistent 
Commission  practice,  for   the  purposes   of  the   forfeiture 
proceeding  initiated  by  this   NAL,  Clear  Channel  and   its 
subsidiaries   Clear   Channel   Broadcasting   Licenses,   Inc., 
Citicasters Licenses, L.P.  and Capstar  TX Limited  Partnership,  
shall be the only parties to this proceeding.