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Statement of Chairman Martin
Statement of Commissioner Copps
Statement of Commissioner Adelstein
Statement of Commissioner Tate
Statement of Commissioner McDowell
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Before the
Federal Communications Commission
Washington, D.C. 20554
)
In the Matter of
)
1st Source Information Specialists,
Inc. ) File No. EB-05-TC-059
d/b/a ) NAL/Acct. No. 200632170005
LocateCell.com ) FRN: 0014762439
Apparent Liability for Forfeiture )
)
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: July 13, 2006 Released: July 13, 2006
By the Commission: Chairman Martin, Commissioners Copps, Adelstein, Tate,
and McDowell issuing separate statements.
I. introduction
1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
that 1st Source Information Specialists, Inc. d/b/a LocateCell.com
(hereafter "LocateCell") apparently willfully or repeatedly violated a
Commission order by failing to respond to the directive of the
Enforcement Bureau ("Bureau") to provide certain information and
documents. Based upon our review of the facts and circumstances
surrounding this apparent violation, we find that LocateCell is
apparently liable for a forfeiture in the amount of $97,500.
II. Background
2. On November 29, 2005, the Bureau served LocateCell with a subpoena
requesting documents and information. The subpoena, issued pursuant to
the authority set forth in sections 151, 403 and 409 of the
Communications Act of 1934, as amended ("the Act"), concerned call
detail and other customer proprietary network information ("CPNI")
that LocateCell may have obtained from telecommunications carriers,
despite the requirements of section 222 of the Act, which imposes a
general duty on all carriers to ensure the confidentiality of their
subscribers' CPNI.
3. The Bureau issued its subpoena to LocateCell as part of its
investigation into whether carriers have taken adequate steps to
ensure that their subscribers' CPNI is protected from unauthorized
disclosure. Significantly, it appeared that LocateCell was operating
as a third party "data broker" by advertising, on its website, the
availability of records of wireless subscribers' incoming and outgoing
telephone calls for a fee. In issuing a subpoena to LocateCell, we
sought to determine how LocateCell was able to access sensitive,
personal subscriber information that telecommunications carriers are
obligated to protect under section 222 of the Act.
4. The subpoena required LocateCell to produce information and documents
responsive to twelve specific requests within 10 days of service of
the subpoena. On December 16, 2005, LocateCell provided a partial
response to the subpoena, delivering basic corporate documents in
response to specifications one through five of the subpoena.
LocateCell indicated that it would provide additional responses to
questions six through twelve of the subpoena during the week of
December 26, 2005. These questions included the most significant data
requests of the subpoena. In particular, the Bureau sought documents
and information concerning how LocateCell obtained CPNI from carriers,
despite the carriers' obligation to protect these sensitive data.
However, LocateCell failed to produce these additional documents.
5. On January 20, 2006, pursuant to section 503(b)(5) of the Act, the
Bureau issued a Citation to LocateCell for failure to respond fully to
a Commission Order, and required LocateCell to provide complete
answers to the subpoena within seven calendar days. In its Citation,
the Bureau warned LocateCell that, "[i]f, after receipt of the
Citation, you continue to refuse to comply with the Commission's
orders in any manner described herein, the Commission may impose
monetary forfeitures not to exceed $11,000 for each such violation or
each day of a continuing violation, up to a maximum of $97,500 for a
continuing violation.
6. On January 27, 2006, LocateCell filed a Motion for Enlargement of Time
to respond to the subpoena, requesting an extension of time until
February 3, 2006. In its Motion, LocateCell also questioned the
jurisdiction of the Commission over LocateCell, and stated that it
anticipated filing a motion to quash and/or for a protective order.
LocateCell recognized, however, that the Commission is not "confined
to issuing subpoenas to just those over whom we have jurisdiction."
LocateCell did not provide any additional documents or information on
February 3, 2006, and still has not provided any additional responses
to the subpoena. LocateCell also has not filed a motion to quash
and/or for a protective order.
III. Discussion
A. LocateCell Is Apparently Liable for a Forfeiture for Failing to
Comply with an Order of the Commission
7. Section 503(b) of the Act provides in pertinent part that "[a]ny
person who is determined by the Commission . . . to have . . .
willfully or repeatedly failed to comply with any of the provisions of
this Act or of any. . . order issued by the Commission under this Act
. . . shall be liable to the United States for a forfeiture penalty."
As detailed above, LocateCell has failed to provide all of the
information and documentation that the Bureau ordered it to provide in
the subpoena and subsequent Citation. Therefore, we find that
LocateCell apparently willfully and repeatedly violated a Commission
order.
8. The November 29, 2005 subpoena was properly issued within the
Commission's authority. In sections 4(i), 4(j), and 403 of the Act,
Congress afforded the Commission broad authority to institute an
inquiry, on its own motion, in any case and as to any matter or thing
within its statutory authority. As noted above, the Bureau, on
authority delegated by the Commission, issued the subpoena as part of
the Commission's ongoing investigation into whether carriers are
complying with their obligations under section 222 of the Act. Section
403 also gives the Commission broad authority to "make and enforce
orders" relating to a matter under investigation. Further, sections
4(i) and 4(j) authorize the Commission to "issue such orders ... as
may be necessary in the execution of its functions" and to "conduct
its proceedings in such manner as will best conduce to the proper
dispatch of business and to the ends of justice."
9. Further, the Commission has specific authority under sections 1 and
409(e) of the Act, as well as section 0.111 of the Commission's rules,
to require by subpoena the attendance and testimony of witnesses and
the production of "all books, papers, schedules of charges, contracts,
agreements, and documents relating to any matter under investigation."
Hence, the Bureau was within its authority in requiring LocateCell to
provide information and documents relevant to the Commission's CPNI
investigation. Moreover, we note that parties are required to comply
with Bureau orders even if they believe them to be outside our
authority.
10. As noted supra, prior to issuing a Notice of Apparent Liability
against a non-Commission licensee such as LocateCell, we are obligated
under section 503(b)(5) of the Act to issue a Citation describing the
violation charged. The non-licensee must be "given a reasonable
opportunity for a personal interview with an official of the
Commission, at the field office of the Commission which is nearest to
such person's place of residence." If the non-licensee "subsequently
engages in the conduct of the type described in the citation," a
Notice of Apparent Liability may be issued. These requirements have
been satisfied here. The Bureau issued a Citation to LocateCell on
January 20, 2006. The Bureau noted in the Citation that LocateCell
could contact the Tampa, Florida field office if it wished to discuss
the Citation. The Citation further required LocateCell to respond in
full to the subpoena. Subsequently, LocateCell again failed to comply
with the obligation to produce information as required by the subpoena
and the Citation. Accordingly, we issue this Notice of Apparent
Liability finding that LocateCell has apparently willfully and
repeatedly violated Commission orders requiring the production of
documents and information.
A. Forfeiture Amount
11. Section 503(b) of the Act authorizes the Commission to assess a
forfeiture of up to $11,000 for each violation, or up to $97,500 for a
continuing violation, of the Act or of any rule, regulation or order
issued by the Commission under the Act by a non-common carrier or
other entity not specifically designated in section 503 of the Act.
The Commission may assess this penalty if it determines that the
noncompliance is willful or repeated. In exercising such authority, we
are to take into account "the nature, circumstances, extent, and
gravity of the violation and, with respect to the violator, the degree
of culpability, any history of prior offenses, ability to pay, and
such other matters as justice may require."
12. The Commission's forfeiture guidelines do not address the specific
violation at issue in this proceeding. In determining the proper
forfeiture amount in this case, however, we are guided by the critical
nature of the matter at issue and the importance of the obligation to
protect subscribers' sensitive, proprietary information. Consumers are
increasingly concerned about the security of the personal data that
they must entrust to their various service providers, whether they are
financial institutions or telephone carriers. Given the increasing
concerns about security of this data, and evidence that the data
appears widely available to third parties, such as LocateCell, we must
take aggressive, substantial steps to ensure that this data is
protected. LocateCell's failure to respond fully to the Bureau's
subpoena, requesting information concerning how LocateCell was able to
access sensitive personal, subscriber information that
telecommunications carriers are obligated to protect under section 222
of the Act, directly hinders our investigation into this important
matter.
13. As set forth above, for failure to respond fully to the subpoena, the
Bureau issued a Citation to LocateCell on January 20, 2006, requiring
LocateCell to provide complete answers to the subpoena within seven
calendar days. To date, LocateCell has not provided any additional
responses to the subpoena; nor has LocateCell challenged the relevance
or scope of the subpoena or claimed that it is unduly burdensome.
LocateCell was required to comply with the Citation and produce all
documents and information specified in the subpoena by January 27,
2006. LocateCell failed to produce additional documents or information
on that date and this failure continues. As stated above, section
503(b)(2)(C) provides for forfeitures of up to $11,000 for each
violation or each day of a continuing violation up to a maximum of
$97,500 for each continuing violation. LocateCell's violation is a
continuing one, and based on all the facts and circumstances in this
case, we believe the maximum forfeiture amount for the continuing
violation is warranted. Accordingly, we propose a forfeiture of
$97,500 against LocateCell.
14. LocateCell will have an opportunity to submit further evidence and
arguments in response to this NAL to show that no forfeiture should be
imposed or that some lesser amount should be assessed.
IV. CONCLUSION and ORDERING CLAUSES
15. We conclude that LocateCell apparently willfully or repeatedly
violated a Commission order by failing to provide the information and
documents the Bureau directed it to provide. Accordingly, a proposed
forfeiture in the amount of $97,500 is warranted against LocateCell
for its apparent willful or repeated violations of our directive.
16. ACCORDINGLY, IT IS ORDERED THAT, pursuant to section 503(b) of the
Communications Act of 1934, as amended, section 1.80 of the
Commission's rules, and authority delegated by sections 0.111 and
0.311 of the Commission's rules, LocateCell IS NOTIFIED OF ITS
APPARENT LIABLE FOR A FORFEITURE in the amount of $97,500 for
willfully or repeatedly failing to respond fully to the Bureau's
subpoena, as required by the Citation.
17. IT IS FURTHER ORDERED THAT, pursuant to section 1.80 of the
Commission's Rules, within thirty days of the release date of this
NOTICE OF APPARENT LIABILITY, LocateCell SHALL PAY the full amount of
the proposed forfeiture or SHALL FILE a written statement seeking
reduction or cancellation of the proposed forfeiture.
18. Payment of the forfeiture must be made by check or similar instrument,
payable to the order of the Federal Communications Commission. The
payment must include the NAL/Acct. No. and FRN No. referenced above.
Payment by check or money order may be mailed to Federal
Communications Commission, P.O. Box 358340, Pittsburgh, PA 15251-8340.
Payment by overnight mail may be sent to Mellon Bank/LB 358340, 500
Ross Street, Room 1540670, Pittsburgh, PA 15251. Payment by wire
transfer may be made to ABA Number 043000261, receiving bank Mellon
Bank, and account number 911-6106. Requests for payment of the full
amount of this NAL under an installment plan should be sent to Chief,
Credit and Management Center, 445 12th Street, S.W., Washington, D.C.
19. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability
for Forfeiture shall be sent by first class mail and certified mail
return receipt requested to LocateCell at 7361 Granville Drive,
Tamarac, Florida 33321.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
STATEMENT OF
CHAIRMAN KEVIN J. MARTIN
Re: 1st Source Information Specialists, Inc., d/b/a LocateCell.com,
Apparent Liability for Forfeiture, Notice of Apparent Liability for
Forfeiture, EB File No. EB-05-TC-059; FRN 0014762439; NAL Acct. No.
200632170005.
As I testified to Congress earlier this year, the Commission is taking
numerous steps to protect the privacy of consumers' personal phone
records. One of these steps is our current investigation into whether
telecommunications carriers are complying with their customer privacy
obligations under the Communications Act. Examining how data brokers are
able to access consumer call records from these carriers is an integral
part of this investigation.
Responding to Commission subpoenas is not optional. We expect that
subpoenas, as well as all of our requests for information, will be
responded to completely and promptly. Although we propose the maximum
forfeiture against LocateCell for its failure to adequately respond, I
fear that the amount we propose - $97,500 - is merely a cost of doing
business. As I have said previously, it is my hope that, in the future,
our statutory maximum will be increased. If companies such as LocateCell
have no incentive to comply with our requests for information, our
enforcement processes will be severely compromised.
The Commission remains committed to ensuring that consumers' personal
phone data is kept confidential. Our investigation is ongoing. In addition
to this investigation, we intend to complete the proceeding we began
several months ago that seeks to strengthen the safeguards currently in
place to protect customer phone records. The ability of data brokers, such
as LocateCell, to engage in the trafficking of these records is a practice
that must be stopped.
SEPARATE STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
Re: 1st Source Information Specialists, Inc., d/b/a LocateCell.com,
Apparent Liability for Forfeiture, Notice of Apparent Liability for
Forfeiture, EB File No. EB-05-TC-059; FRN 0014762439; NAL Acct. No.
200632170005.
Few rights are so fundamental as the right to privacy in our
daily lives - and few are under such constant attack. Americans must have
the security of knowing that their private phone records are not for
sale. I therefore support our decision today to assess the statutorily
maximum forfeiture against a company that has egregiously failed to comply
with our subpoena and that must be called to account.
Even though today's decision is a step in the right direction,
let's be sure we don't lose sight of the bigger picture here. Data
brokers continue to flout the law, invade our privacy, and put each of us
at risk. As the Electronic Privacy Information Center (EPIC) demonstrated
so forcefully in its petition for rulemaking last summer, data brokers are
capable of obtaining a history of calls made to and from a particular
phone number, the customer name associated with that number, and perhaps
even the geographic location of a mobile phone user. This is an
unsettling and entirely intolerable state of affairs. The Commission
simply cannot stop until the root problem has been solved. This company's
failure to respond to our subpoena about how it came to possess private
data underscores just how badly further action is needed.
In order to provide consumers with the level of protection
they expect and deserve, I hope we will move on from here to issue rules
in the Customer Proprietary Network Information (CPNI) docket that we
opened last February. For too long the Commission treated privacy as a
"back-burner" issue. It has been four years since the Arizona Corporation
Commission initiated a petition regarding dissemination of CPNI to
unaffiliated third parties. Last year we reclassified wireline broadband
Internet access services but left for another day the chilling question of
whether privacy protections even apply to this regulatory remix. It is
time to stop putting Americans' digital privacy unnecessarily at risk.
So I hope this decision today signals a commitment to get
privacy right for the digital age. Where breaches of data security become
easier and more common every day, privacy still has to matter. The
Commission's challenge is to catch up with the American people who are
demonstrably tired of unlawful violations of their digital privacy. They
need our help and they need it now.
STATEMENT OF
COMMISSIONER JONATHAN S. ADELSTEIN
Re: 1st Source Information Specialists, Inc., d/b/a LocateCell.com,
Apparent Liability for Forfeiture, Notice of Apparent Liability for
Forfeiture, EB File No. EB-05-TC-059; FRN 0014762439; NAL Acct. No.
200632170005.
Personal privacy is at the heart of our quality of life, as Congress
recognized in requiring telecommunications companies to respect their
customers' privacy. A consumer's telephone call records include some of
the most private personal information about an individual. Not
surprisingly, consumers were alarmed when it came to light over the past
year that their telephone records were widely available for sale on the
Internet, without their knowledge or approval, to anyone with an Internet
connection and a credit card. People felt that having their incoming and
outgoing calls available for public view was like having their personal
diaries exposed. Consumers were outraged to find that others could learn
about calls that might expose their business transactions, doctor
appointments, and personal interactions.
Strong and consistent Commission enforcement of our consumer privacy rules
is critical to restore the protections that consumers expect and that
Congress has mandated. This NAL takes aim at one of the apparent purveyors
of consumers' private telephone call records for failure to comply with an
on-going Commission investigation. LocateCell's willful and repeated
failure to fully cooperate with the Commission's subpoena jeopardizes the
Commission's investigation, and warrants the maximum penalty for repeated
non-compliance with Commission orders. The Commission simply cannot
condone failure to cooperate with an investigation that clearly safeguards
the public interest.
This NAL must also be part of a larger effort to address the widespread
availability of confidential phone records, a phenomenon highlighted in
press reports just a few months back estimating that there were dozens of
such web sites. Shining a light on the unauthorized sale of telephone
records may drive some of these providers off the Internet - a positive
first step. Yet, companies like LocateCell appear to slip underground with
disquieting ease, which may pose a real challenge for our efforts to
assess this forfeiture, and we will need to be vigilant against the
ability of bad actors peddling unauthorized telephone records to disappear
and later resurface.
Indeed, we have a lot more work to do to ensure that consumers private
call records are adequately safeguarded. It is essential that we move
ahead with our pending rulemaking on our consumer privacy rules for
telephone companies. The mere fact that these records have been so readily
available, even though telephone companies are required to have firewalls
in place to protect consumers' private information, has raised serious
questions about the mechanisms that are in place to safeguard the
confidentiality of their consumers' information. So, our pending
rulemaking proceeding gives us an important opportunity to find ways to
tighten our rules, to ensure that phone companies are employing adequate
safeguards, and to provide greater security for these sensitive consumer
records. Every provider should be on notice that we are watching closely
and will take the action necessary to protect consumers' privacy, and we
expect them to do the same.
STATEMENT OF
COMMISSIONER DEBORAH TAYLOR TATE
Re: 1st Source Information Specialists, Inc., d/b/a LocateCell.com,
Apparent Liability for Forfeiture, Notice of Apparent Liability for
Forfeiture, EB File No. EB-05-TC-059; FRN 0014762439; NAL Acct. No.
200632170005.
The brokerage of personal information - whether it be personal identity,
financial records, or a list of your phone calls - is intolerable. Six
months ago we pledged to do our part to keep consumer's personal phone
data confidential. Today, we keep that promise.
LocateCell was subpoenaed in an effort to determine how it was able to
access sensitive, personal subscriber information that telecommunications
carriers are obligated to protect. But instead of responding with full
candor, LocateCell has willfully and repeatedly ignored the Commission's
most significant data requests. Accordingly, we issue this Notice of
Apparent Liability, and propose the maximum forfeiture amount against
LocateCell.
The action we take today should reinforce our message to any and all
information snatchers - we will continue to be vigilant in enforcing our
obligation to protect consumers' most personal information. The personal
records of American consumers are not for sale.
STATEMENT OF
COMMISSIONER ROBERT M. McDOWELL
Re: 1st Source Information Specialists, Inc., d/b/a LocateCell.com,
Apparent Liability for Forfeiture, Notice of Apparent Liability for
Forfeiture, EB File No. EB-05-TC-059; FRN 0014762439; NAL Acct. No.
200632170005.
Today's action is just one part of a broader effort by this Commission to
ensure the protection of customer proprietary network information ("CPNI")
and address concerns that this information may have been improperly made
available to third parties in violation of our rules. By issuing this
Notice of Apparent Liability, we make clear that we will not tolerate the
refusal of companies such as data broker 1st Source Information
Specialists, Inc., d/b/a/ LocateCell.com ("LocateCell") to cooperate with
lawful requests for information related to alleged violations of our
rules. It is critical that we take a firm stand against those that would
obstruct the Commission's statutory authority to investigate matters
pertaining to CPNI.
LocateCell is not the only company from which the Commission has sought
information. Our Enforcement Bureau has been actively investigating a
number of these data brokers, many of which have advertised the
availability of records of wireless subscribers' incoming and outgoing
telephone calls, as well as certain landline toll call records, for a fee.
The Bureau is also investigating the alleged failure of carriers to
certify compliance with our CPNI rules, and is vigorously pursuing
non-compliant companies. These investigations will continue, and I thank
the Bureau for its work in moving these initiatives forward.
In addition to these investigatory actions, the Commission is actively
engaged in a rulemaking that examines the need for tougher privacy rules,
including an analysis of measures proposed by the Electronic Privacy
Information Center (EPIC) intended to more adequately protect CPNI. I look
forward to closely coordinating with my colleagues on the important issues
under consideration in this related proceeding.
The depth and breadth of these undertakings illustrate the seriousness
with which the Commission views its role in ensuring the security of CPNI.
I commend the Chairman for his steady, reasoned leadership on these
multiple fronts.
Like most Americans, I am deeply troubled by reports of companies
unlawfully obtaining and marketing personal telephone records. The
Commission has a vital obligation to protect the privacy and security of
customer telephone records from those entities that would seek to acquire
that information through unlawful means. Improperly exposing call records
- which indicate who is being called, how long the call lasts, and, in the
wireless context, the physical areas within which a given call is placed
and delivered - is a grievous invasion into the victim's personal life.
We cannot compromise our ability to protect customers' private telephone
records from unauthorized disclosure. We will not tolerate LocateCell's
refusal to cooperate with our investigation. For these reasons, I support
today's decision to issue a Notice of Apparent Liability to and forfeiture
against LocateCell.
47 U.S.C. S 503(b)(1). The Commission has the authority under this section
of the Act to assess a forfeiture against any person who has "willfully or
repeatedly failed to comply with any of the provisions of this Act or of
any rule, regulation, or order issued by the Commission under this Act
...."
1st Source Information Specialists, Inc. is a Florida state corporation
that owns and operates several websites, including "LocateCell.com."
See Subpoena, LocateCell.com/1st Source Information Specialists, Inc.,
Enf. Bureau, Nov. 29, 2005 (LocateCell Subpoena). Service of the subpoena
was confirmed on that date.
47 U.S.C. SS 151, 403, 409.
CPNI is defined as information that relates to the quantity, technical
configuration, type, destination, and amount of use of a
telecommunications service subscribed to by a customer of a
telecommunications carrier, and that is made available to the carrier by
the customer solely by virtue of the customer-carrier relationship. See 47
U.S.C. S 222; 47 C.F.R. S 64.2003(d).
47 U.S.C. S 222. This section provides that: "Every telecommunications
carrier has a duty to protect the confidentiality of proprietary
information of, and relating to, other telecommunications carriers,
equipment manufacturers, and customers, including telecommunication
carriers reselling telecommunications services provided by a
telecommunications carrier."
See also 47 C.F.R. S 64.2009 et seq., the Commission's rules implementing
section 222 of the Act.
According to a petition for rulemaking filed with the Commission regarding
protection of CPNI, some data brokers have taken advantage of carriers'
inadequate security standards to gain access to CPNI under false
pretenses, such as by posing as the customer and then offering the records
for sale on the Internet. See Electronic Privacy Information Center
("EPIC") Petition for Rulemaking at http://www.epic.org/privacy/iei/.
In specifications one through five of the subpoena, we directed LocateCell
to provide corporate documents, including information concerning the
relationship between 1st Source Information Specialists, Inc. and
LocateCell.com. We also requested information and documents relating to
all websites owned by 1st Source Information Specialists, Inc., and
documents relating to toll-free numbers registered to and/or operated by
1st Source Information Specialists, Inc. and LocateCell.com. See
LocateCell Subpoena at 1.
See 47 U.S.C. S 503(b)(5) (stating that the Commission has the authority
under this section of the Act to assess a forfeiture penalty against any
person who is not a common carrier so long as (A) such person is first
issued a citation of the violation charged; (B) is given a reasonable
opportunity for a personal interview with an official of the Commission,
at the field office of the Commission nearest to the person's place of
residence; and (C) subsequently engages in conduct of the type described
in the citation).
See Citation, LocateCell.com/1st Source Information Specialists, Inc.,
Enf. Bureau, Jan. 20, 2006 (LocateCell Citation).
See LocateCell Citation at 2 (citing 47 U.S.C. S 503(b)(5)).
See 1st Source Information Specialists, Inc. Motion for Enlargement of
Time, filed Jan. 31, 2006.
47 U.S.C. S 503(b).
47 U.S.C. SS 154(i), 154(j), 403.
47 C.F.R. S0.111.
47 U.S.C. SS 151, 409(e).
See SBC Communications, Inc., 17 FCC Rcd 7589, 7591 (2002).
47 U.S.C. S 503(b)(2)(C); see Amendment of Section 1.80 of the
Commission's Rules and Adjustment of Forfeiture Maxima to Reflect
Inflation, 15 FCC Rcd 18221 (2000): Amendment of Section 1.80 of the
Commission's Rules and Adjustment of Forfeiture Maxima to Reflect
Inflation, 19 FCC Rcd 10954 (2004) (increasing maximum forfeiture amounts
to account for inflation).
See Footnote 1, supra; 47 U.S.C SS 503(b)(1)(B), (b)(2)(5).
The Commission's Forfeiture Policy Statement and Amendment of Section 1.80
of the Commission's Rules, 12 FCC Rcd 17087 (1997) ("Forfeiture Policy
Statement"); recon. denied, 15 FCC Rcd 303 (1999).
LocateCell Citation.
47 U.S.C S 503(b)(4)(C); 47 C.F.R. S 1.80(f)(3).
47 U.S.C. S 503(b).
47 U.S.C. S 1.80(f)(4).
47 C.F.R. SS 0.111, 0.311.
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Federal Communications Commission FCC 06-104