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Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
Complaints by Parents Television Council ) File No.
EB-03-IH-0357, et al.1
Against Various Broadcast Licensees )
Regarding Their Airing Of )
Allegedly Indecent Material )
MEMORANDUM OPINION AND ORDER
Adopted: December 8, 2004
Released: January 24, 2005
By the Commission: Commissioner Copps approving in part,
dissenting in part and issuing a statement; Commissioner
Martin approving in part, dissenting in part and issuing a
statement at a later date.
I. INTRODUCTION
1. In this Memorandum Opinion and Order, we deny 21
complaints filed by the Parents Television Council (``PTC'')
against various television broadcast licensees alleging
violations of the federal restrictions regarding the
broadcast of indecent material.2 PTC provided a transcript
of the segments it considers indecent and provided
videotapes of each of the programs referenced in the
complaints. PTC asks that, should the Commission find the
material in each complaint indecent, it issue a notice of
apparent liability for forfeiture against the licensee and
every other licensee that aired the material. After
reviewing the material provided by PTC, we conclude that the
complained of material is not patently offensive pursuant to
contemporary community standards for the broadcast medium
and is therefore not indecent.
II. DISCUSSION
2. It is a violation of federal law to broadcast
obscene, indecent or profane programming. Specifically,
title 18 of the United States Code, section 1464 prohibits
the utterance of ``any obscene, indecent or profane language
by means of radio communication.''3 The Federal
Communications Commission, which is authorized to license
radio and television broadcast stations, is responsible for
enforcing the statutory and regulatory provisions
restricting obscenity, indecency and profanity.4 Consistent
with a subsequent statute and court case,5 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 The Commission may impose a
monetary forfeiture, pursuant to section 503(b)(1) of the
Communications Act of 1934, as amended7 (the ``Act''), upon
a finding that a licensee has broadcast obscene, indecent or
profane material in violation of 18 U.S.C. § 1464 and
section 73.3999 of the rules.
3. The Commission's role in overseeing program
content is limited, however, by the First Amendment to the
United States Constitution and section 326 of the Act, which
prohibit the Commission from interfering with broadcasters'
freedom of expression and from censoring program material.8
Thus, any consideration of government action against
allegedly indecent programming must take into account the
fact that such speech is protected under the First
Amendment, and demands that we proceed cautiously and with
appropriate restraint when considering enforcement action in
such matters.9
4. 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.10
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.11
None of the broadcasts described below meets the second part
of our standard.12
5. In determining whether material is patently
offensive, the Commission has indicated that the ``full
context in which the material appeared is critically
important,''13 and has articulated three ``principal
factors'' for its analysis: ``(1) the explicitness or
graphic nature of the description or depiction of sexual or
excretory organs or activities; (2) whether the material
dwells on or repeats at length descriptions of sexual or
excretory organs or activities; (3) whether the material
appears to pander or is used to titillate, or whether the
material appears to have been presented for its shock
value.''14 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.''15 In particular cases, one or two of the
factors may outweigh the others, either rendering the
broadcast material patently offensive and consequently
indecent,16 or, alternatively, removing the broadcast
material from the realm of indecency.17
6. Outlined below is a description of the
allegedly indecent material cited in PTC's
complaints.
a. ``Everwood,'' September 16, 2002, 9 p.m. EST: a
character remarks to another:
``I got this black eye because of you, dick.''18
b. ``Fastlane,'' September 18, 2002, 9 p.m. EST: one
character threatens another by stating: ``...in my
next life I'm coming back as a pair of pliers and
pull off your nutsack.''19
c. ``Girls Club,'' October 21, 2002, 9 p.m. EST: a
young female attorney says to an older male attorney:
``. . . those power dicks are going to start giving
me trials.'' The attorney responds: ``Is that what
you call us? Power dicks?''20
d. ````Girls Club,'' October 28, 2002, 9 p.m. EST: a
female character remarks: ``I'm
not feeling too sexual these days . . . . Especially here,
I'm having a little trouble with one of the power dicks.''21
e. ``Dawson's Creek,'' October 30, 2002, 8 p.m. EST:
one character remarks to
another: ``Listen, I know that you're pissed at your dad
for flaking on you. It doesn't mean he's a bad dad, and it
doesn't mean he doesn't love you.22 Another character
responds: ``No, it just means he's a dick.''23
f. ``Dawson's Creek,'' December 11, 2002, 8 p.m. EST:
one character tells another:
``. . . you're being a dick.''24
g. ``Austin Powers: The Spy Who Shagged Me,'' January
8, 2003, 8 p.m. EST: musical
number during which the title character's naked torso and
genital area are blocked by objects, furniture, and, in one
instance, by his hands.25 Later scenes include the use of
the phrase ``fat bastard,'' and the word ``testicles.''26
In another scene from this film, a male and a female
character are in bed together, but no sexual or excretory
organs or activities are depicted or discussed.27
h. ``NYPD Blue,'' April 8, 2003, 9 p.m. CST: a
character states: ``That dickhead in a
wheelchair.''28
i. ``Friends,'' May 1, 2003, 8 p.m. EST: a female
character and her husband encounter
the husband's former girlfriend at a medical office.29
After a conversation concerning fertility treatment, the
female character says that she has to go because she's got
``an invasive vaginal exam to get to.''30
j. ``The Diary of Ellen Rimbauer,'' May 12, 2003, 9
p.m. EST: one scene depicts two
female characters and one male character in bed together;
all three are under the covers and there are no sexual or
excretory organs or activities depicted.31 Another scene
depicts a male character tying a female character to a bed
and then applying ice to her abdomen. The female character
moans and writhes. A third scene depicts a maid undressing
while a male character surreptitiously watches. A portion
of the side of the maid's breast is shown, but her nipple is
not exposed.32
k. ``Jamie Kennedy Experiment,'' October 23, 2003,
8:30 p.m. EST: the title character
Jamie pulls a prank on the mother of one of his friends.
The mother believes that she is participating in a serious
television interview about Jamie.33 The interviewer, who is
in on the prank, mentions that Jamie reported that the
``hottest night of his life'' occurred when he became
``intimate'' with the mother, and that Jamie and the woman's
son used to play a game called ``you show me yours, I'll
show you mine.''34 Later, the woman confronts her son and
tells him that Jamie said he'd ``had sex'' with her. She
asks her son ``you didn't show [Jamie] your penis or
something, did you?''35 When the joke is revealed, the
woman calls Jamie a ``bastard'' and threatens to ``kick his
ass.'' In another scene, involving a fake funeral home,
Jamie says ``it's gonna be my ass.''36
l. ``Run of the House,'' October 23, 2003, 9 p.m.
EST: a female character teases her
brother about dating a woman who looks like his mother and,
after her brother and his girlfriend have been in the hot
tub, tells him ``I know what you're doing.''37
m. ``Scrubs,'' November 13, 2003, 9:30 p.m. EST: in
one scene, there is a discussion
among a male character, his fiancée, and her brother in
which the male character antagonizes the brother by telling
the fiancée he wants to ``love her up and down and all
around,'' and that they should ``go put some more of your
footprints on the ceiling.''38 The brother reacts angrily,
saying ``that's it you son of a bitch.''39 In another
scene, a male doctor tells a female resident that he would
rather listen to her ``go on and on about the joys of
dolphin sex.''40
n. ``Gilmore Girls,'' November 18, 2003, 8 p.m. EST:
in one scene, a character's
grandfather reminisces about college pranks involving
nudity; in another scene, two current college students
discuss the night the male student spent nude in a dorm
hallway.41 There is also another scene in which a female
character listens to a brief message on her answering
machine in which a male caller makes a reference to
``growing a pair.''42
o. ``One Tree Hill,'' November 18, 2003, 9 p.m. EST:
in a school hallway, a male
character tells a female character, ``I've got something for
you,'' and she replies, ``I know you do, gorgeous.''43 He
then gives her a book, telling her she might want to ``check
it out,'' and she replies, ``Oh, I definitely want to check
it out. I suppose I could read the book, too.''44
p. ``Steve Harvey's Big Time,'' November 20, 2003, 8
p.m. EST: a fully clothed
contortionist appears and manipulates his body, including
twisting his upper body around and between his legs, and
stepping through a tennis racquet frame such that he reaches
between his legs to move the racquet so that he can step out
of it.45 The show's host remarks that the contortionist is
a ``skinny-ass little dude'' and grabs his genital area as
the contortionist pushes his body through the tennis racquet
frame.46
q. ``Will & Grace,'' November 20, 2003, 9 p.m. EST:
a male character studying to
become a nurse remarks to a male friend that he's taken his
own blood pressure many times, to which the friend replies,
``yeah, and how many times on your arm?''47 Later, the
nursing student tells his fellow students that ``he can name
all the bones in the human penis.''48
r. ``Scrubs,'' November 20, 2003, 9:30 p.m. EST: a
male character and a female
character is depicted in bed, under the covers.49 The male
character asks the female character if it's ``a good time to
start talking about a nickname for [his] penis.''
s. ``Charmed,'' November 23, 2003, 8 p.m. EST: three
female characters are talking, one
remarks that she's late because she was ``tied up,'' and
another asks ``where, at Richard's?''50 Later, one of the
female characters talks about being afraid to ``take it to
the next level'' with her boyfriend, and another character
tells her to ``relax and let it happen.'' She replies:
``That's easy for you to say, you weren't the one sleeping
with an angel for three years.''
t. ``Gilmore Girls,'' February 10, 2004, 9 p.m. EST:
one character says to another:
``you're a dick.'' 51
u. ``Angel,'' February 11, 2004, 9 p.m. EST: one
character says to another: ``you're still a
dick.''52
7. To support a finding of indecency, we must first
determine whether any of the material cited by PTC meets the
Commission's definition of ``patently offensive'' - namely,
does any of the material graphically or explicitly depict or
describe sexual organs or activities, does any of the
material dwell on or repeat depictions or descriptions of
sexual organs or activities, and is any of the material
designed to pander, titillate, or shock. Based on our
review of the programs listed above, we find that none of
the material referenced in PTC's complaints rises to the
level of being patently offensive under our indecency
definition.
8. A number of complaints cite isolated uses of the
word ``dick'' or variations thereof. In context and as used
in the complained of broadcasts, these were epithets
intended to denigrate or criticize their subjects. Their
use in this context was not sufficiently explicit or graphic
and/or sustained to be patently offensive. Although use of
such words may, depending on the nature of the broadcast at
issue, contribute to a finding of indecency, their use here
was not patently offensive and therefore not indecent.
Similarly, we find that the fleeting uses of the words
``penis,'' ``testicle,'' ``vaginal,'' ``ass,'' ``bastard''
and ``bitch,'' uttered in the context of the programs cited
in the complaints, do not render the material patently
offensive under contemporary community standards for the
broadcast medium.
9. Several complaints cited material that depicted
partial nudity. Many of these complaints involved
characters whose sexual and/or excretory organs were covered
by bedclothes, household objects, or pixilation, however,
and none of the material cited in the complaints actually
depicted sexual or excretory organs. In context, we do not
find the material to be sufficiently graphic or explicit, or
sustained, to rise to the level of being patently offensive.
10. The remaining complaints focus on vague references
or innuendo to sexual organs or activities. In context, the
references and innuendos cited in the complaints were not
sufficiently graphic or explicit and were not repeated or
dwelled upon.
III. CONCLUSION
11. For the reasons discussed above, we find that
none of the material contained in the 21 PTC complaints is
patently offensive as measured by contemporary community
standards for the broadcast medium. We therefore conclude
that none of the material in the 21 complaints is indecent.
IV. ORDERING CLAUSES
12. Accordingly, IT IS ORDERED, that the 21 complaints
listed in the Appendix are hereby DENIED.
13. IT IS FURTHER ORDERED that a copy of this
Memorandum Opinion and Order shall be sent by Certified Mail
Return Receipt Requested to The Parents Television Council,
707 Wilshire Boulevard, Los Angeles, California 90017, and
to the licensees that are the subject of the instant
complaints.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary APPENDIX
CASE CALL SIGN/ LICENSEE Program/Air
NUMBER COMMUNITY Date/Time
OF LICENSE
EB-03-IH- WBDC-TV WBDC Everwood,
0463 Washing- Broadcasting, September 16,
ton, DC Inc. 2002, 9 p.m. EST
EB-03-IH- WTTG(TV) Fox Television Fastlane,
0405 Washing- Stations, Inc. September 18,
ton, DC 2002, 9 p.m. EST
EB-03-IH- WTTG(TV) Fox Television Girls Club,
0462 Washing- Stations, Inc. October 21, 2002,
ton, DC 9 p.m. EST
EB-03-IH- WTTG(TV) Fox Television Girls Club,
0461 Washing- Stations, Inc. October 28, 2002,
ton, DC 9 p.m. EST
EB-03-IH- WBDC-TV WBDC Dawson's Creek,
0464 Washing- Broadcasting, October 30, 2002,
ton, DC Inc. 8 p.m. EST
EB-03-IH- WBDC-TV WBDC Dawson's Creek,
0465 Washing- Broadcasting, December 11,
ton, DC Inc. 2002, 8 p.m. EST
EB-03-IH- WTTG(TV) Fox Television Austin Powers:
0406 Washing- Stations, Inc. The Spy Who
ton, DC Shagged Me,
January 8, 2003,
8 p.m. EST
EB-03-IH- KMBC-TV Hearst-Argyle NYPD Blue, April
0357 Kansas Television, 8, 2003, 9 p.m.
City, KS Inc. CST
EB-03-IH- WRC-TV NBC Telemundo Friends, May 1,
0456 Washing- License Co. 2003, 8 p.m. EST
ton, DC
EB-03-IH- WJLA-TV ACC Licensee, The Diary of
0364 Washing- Inc. Ellen Rimbauer,
ton, DC May 12, 2003, 9
p.m. EST
EB-03-IH- WBDC-TV WBDC Jamie Kennedy
0682 Washing- Broadcasting, Experiment,
ton, DC Inc. October 23, 2003,
8:30 p.m. EST
EB-03-IH- WBDC-TV WBDC Run of the House,
0679 Washing- Broadcasting, October 23, 2003,
ton, DC Inc. 9 p.m. EST
EB-03-IH- WRC-TV NBC Telemundo Scrubs, November
0667 Washing- License Co. 13, 2003,
ton, DC 9:30 p.m. EST
EB-03-IH- WBDC-TV WBDC Gilmore Girls,
0680 Washing- Broadcasting, November 18,
ton, DC Inc. 2003, 8 p.m. EST
EB-03-IH- WBDC-TV WBDC One Tree Hill,
0669 Washing- Broadcasting, November 18,
ton, DC Inc. 2003, 9 p.m. EST
EB-03-IH- WBDC-TV WBDC Steve Harvey's
0711 Washing- Broadcasting, Big Time,
ton, DC Inc. November 20,
2003, 8 p.m. EST
EB-03-IH- WRC-TV NBC Telemundo Will & Grace,
0716 Washing- License Co. November 20,
ton, DC 2003, 9 p.m. EST
EB-03-IH- WRC-TV NBC Telemundo Scrubs, November
0712 Washing- License Co. 20, 2003, 9:30
ton, DC p.m. EST
EB-03-IH- WBDC-TV WBDC Charmed, November
0713 Washing- Broadcasting, 23, 2003, 8 p.m.
ton, DC Inc. EST
EB-04-IH- WBDC-TV WBDC Gilmore Girls,
0167 Washing- Broadcasting, February 10,
ton, DC Inc. 2004, 9 p.m. EST
EB-04-IH- WBDC-TV WBDC Angel, February
0168 Washing- Broadcasting, 11, 2004, 9 p.m.
ton, DC Inc. EST
STATEMENT OF COMMISSIONER MICHAEL J. COPPS,
APPROVING IN PART, DISSENTING IN PART
Re: Complaints by Parents Television Council against
Various Broadcast Licensees Regarding Their Airing of
Allegedly Indecent Material
We continue to hear from citizens who are concerned
about sexually explicit and profane programming on the
airwaves and the potentially detrimental effects of this
programming on our children. As an initial matter, I would
note that this Commission has a solemn obligation to respond
to consumer complaints. These complaints are increasing
exponentially from a few hundred only a couple of years ago
to over 1 million in 2004. And in the last few years,
complaints about television broadcasts have equaled or
exceeded those about radio broadcasts. Yet, although the
Commission recently has begun to take action against
indecency on television, some citizens remain concerned that
the FCC summarily dismisses their complaints. At the same
time, some broadcasters contend that the Commission has not
been adequately clear about how it determines whether a
broadcast is indecent. Today's rather cursory decisions do
little to address any of these concerns.
In these two Orders, the Commission combines 36
unrelated complaints with no apparent rhyme or reason other
than that they concern television broadcasts. The
Commission then denies these complaints with hardly any
analysis of each individual broadcast, relying instead on
generalized pronouncements that none of these broadcasts
violates the statutory prohibition against indecency on the
airwaves. I believe that some of these broadcasts present a
much closer call. Exemplary of the complaints that should
not have been summarily denied is one concerning The Diary
of Ellen Rimbauer, which I believe may very well violate the
statutory prohibition against indecency.
Although it may never be possible to provide 100
percent certainty because we must always take into account
the specific context, developing guidance and establishing
precedents are critically important Commission
responsibilities. We serve neither concerned consumers nor
the broadcast industry with the approach adopted in today's
item.
_________________________
1 See Appendix for a listing of the complaints addressed in
this Order, filed between July 3, 2003, and February 17,
2004. Other pending PTC complaints will be addressed
separately.
2 See 18 U.S.C. § 1464 (2002); 47 C.F.R. § 73.3999 (2002).
3 18 U.S.C. § 1464.
4 Federal courts consistently have upheld Congress's
authority to regulate the broadcast of indecent speech, as
well the Commission's interpretation and implementation of
the governing statute. FCC v. Pacifica Foundation, 438 U.S.
726 (1978). See also Action for Children's Television v.
FCC, 852 F.2d 1332, 1339 (D.C. Cir. 1988) (``ACT I'');
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) (en banc), cert. denied, 516 U.S. 1043
(1996) (``ACT III'').
5 Public Telecommunications Act of 1992, Pub. L. No. 102-
356, 106 Stat. 949 (1992), as modified by ACT III, 58 F.3d
654.
6 See 47 C.F.R. § 73.3999.
7 See 47 U.S.C. § 503(b)(1). See also 47 U.S.C. § 312(a)(6)
(authorizing license revocation for indecency violations).
8 U.S. CONST., amend. I; 47 U.S.C. § 326.
9 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.''); id.
at 1340 n.14 (``the potentially chilling effect of the FCC's
generic definition of indecency will be tempered by the
Commission's restrained enforcement policy.'').
10 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)).
11 Industry Guidance on the Commission's Case Law
Interpreting 18 U.S.C. §1464 and Enforcement Policies
Regarding Broadcast Indecency, Policy Statement, 16 FCC Rcd
7999, 8002 (2001) (``Indecency Policy Statement'') (emphasis
in original).
12 Because we deny the complaints due to their failure to
meet the ``patently offensive'' factor in our indecency
analysis, we need not address whether any of the complaints
fail to depict or describe sexual or excretory organs or
activities.
13 Indecency Policy Statement (emphasis in original). In
Pacifica, the Court ``emphasize[d] the narrowness of [its]
holding and noted that under the Commission rationale that
it upheld, ``context is all-important.'' 438 U.S. at 750.
14 Indecency Policy Statement at 8003 (emphasis in
original).
15 Id.
16 Id. at 8009 (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)).
17 Indecency Policy Statement at 8010 (``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'').
18 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated August 22, 2003 (EB-03-IH-0463).
19 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated August 22, 2003 (EB-03-IH-0405).
20 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated August 22, 2003 (EB-03-IH-0462).
21 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated August 22, 2003 (EB-03-IH-0461).
22 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated August 22, 2003 (EB-03-IH-0464).
23 Id.
24 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated August 22, 2003 (EB-03-IH-0465).
25 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated August 22, 2003 (EB-03-IH-0406).
26 Id.
27 Id.
28 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated July 3, 2003 (EB-03-IH-0357).
29 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated August 27, 2003 (EB-03-IH-0456).
30 Id.
31 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated July 3, 2003 (EB-03-IH-0364).
32 Id
33 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 3, 2003 (EB-03-IH-0682).
34 Id.
35 Id.
36 Id.
37 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 3, 2003 (EB-03-IH-0679).
38 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 24, 2003 (EB-03-IH-0667).
39 Id.
40 Id.
41 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 24, 2003 (EB-03-IH-0680).
42 Id.
43 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 24, 2003 (EB-03-IH-0669).
44 Id.
45 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated December 4, 2003 (EB-03-IH-0711).
46 Id.
47 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated December 4, 2003 (EB-03-IH-0716).
48 Id.
49 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated December 4, 2003 (EB-03-IH-0712).
50 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated December 4, 2003 (EB-03-IH-0713).
51 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated February 17, 2004 (EB-04-IH-0167).
52 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated February 17, 2004 (EB-04-IH-0168).