Click here for Adobe Acrobat version
Click here for Microsoft Word version

******************************************************** 
                      NOTICE
********************************************************

This document was converted from Microsoft Word.

Content from the original version of the document such as
headers, footers, footnotes, endnotes, graphics, and page numbers
will not show up in this text version.

All text attributes such as bold, italic, underlining, etc. from the
original document will not show up in this text version.

Features of the original document layout such as
columns, tables, line and letter spacing, pagination, and margins
will not be preserved in the text version.

If you need the complete document, download the
Microsoft Word or Adobe Acrobat version.

*****************************************************************



               Federal Communications Commission      DA 04-3834


6
                                
                           Before the
                Federal Communications Commission
                     Washington, D.C. 20554
                                

In the Matter of                )    
                                )    
                                )    
WARRIOR CUSTOM GOLF, INC.       )    File No. EB-03-TC-036
a.k.a. WARRIOR GOLF             )    NAL/Acct. No. 200432170004
                                )    FRN 0012264933
                                )    
Apparent Liability for          )
Forfeiture                      )
                                

           NOTICE OF APPARENT LIABILITY FOR FORFEITURE

   Adopted: December 7, 2004            Released: December 8,
2004

By the Chief, Enforcement Bureau:

I.   INTRODUCTION

     1.    In  this  Notice of Apparent Liability For  Forfeiture
(“NAL”)1, we find that Warrior Custom Golf, Inc., a.k.a. Warrior Golf
(“WCG”),2 apparently willfully or repeatedly violated section 227
of  the  Communications Act of 1934, as amended (the “Act”),  and
the  Commission's rules and orders, by delivering at  least  four
unsolicited, prerecorded advertising messages to at  least  three
consumers.3   Based  on  the facts and circumstances  surrounding
these  apparent violations, we find that WCG is apparently liable
for forfeiture in the amount of $23,500.

II.  BACKGROUND
     
     2.    On April 29, 2003, in response to a consumer complaint
alleging  that  WCG  had  left  three,  unsolicited,  prerecorded
advertisement   messages   on  the  consumer’s   voicemail,   the
Commission  staff issued a citation4 to WCG, pursuant to  section
503(b)(5) of the Act.5  The staff cited WCG for delivering one or
more  prerecorded, unsolicited advertisements  to  a  residential
telephone  line, in violation of section 227 of the Act  and  the
Commission's  rules and orders.6  According to the consumer,  the
unsolicited advertisements offered the opportunity to try  custom
golf clubs without charge and requested that the consumer call  a
toll-free  number to take advantage of the special  offer.7   The
citation,  which  the  staff  served by  certified  mail,  return
receipt requested, informed WCG that subsequent violations  could
result in the imposition of monetary forfeitures of up to $11,000
per  violation, and included a copy of the consumer  letter  that
formed the basis of the citation.  The citation informed WCG that
within  21  days  of the date of the citation,  it  could  either
request  a  personal  interview at the nearest  Commission  field
office,  or could provide a written statement responding  to  the
citation.  The  Commission  received  a  signed  return   receipt
evidencing WCG's receipt of the citation on May 20, 2003.

     3.   WCG responded to the citation, apologizing to the consumer
for  any  inconvenience  caused by the telephonic  messages,  but
     denying any violations, claiming mistake or inadvertence.8  WCG
stated:

          At  the outset, by copy of this letter to Mr.
          Pollard,  WCG  apologizes  to  him  for   any
          inconveniences caused by telephonic  messages
          [sic]  he  may have received.   And,  to  the
          extent  WCG may have violated FCC  rules  and
          regulations  pertaining  to  the  sending  of
          prerecorded messages, which event WCG denies,
          any such purported violation was done through
          mistake or inadvertence.9
          
WCG  also  stated that it had reorganized its marketing  strategy
and  telephone  communications systems to ensure compliance  with
FCC  rules  and  regulations  regarding  unsolicited  prerecorded
messages  and  “to ensure that unwanted prerecorded messages  are
not  sent to anyone except to those customers with whom [sic] WCG
has a pre-existing relationship.”10

     4.   Despite the citation's warning that subsequent violations
could  result  in  the  imposition of monetary  forfeitures,  the
Commission has received additional consumer complaints indicating
that  WCG  apparently  continued  to  send  illegal  prerecorded,
unsolicited  advertisements after receiving the citation.11   The
complaints   indicate   that   the  prerecorded   messages   were
substantially the same as those described in the citation.12

III. DISCUSSION

     A.     Violations  of  the  Commission’s  Rules  Restricting
     Prerecorded Messages
     
     5.    Section 227(b)(B) of the Act prohibits any person from
initiating "any telephone call to any residential telephone  line
using  an  artificial or prerecorded voice to deliver  a  message
without the prior express consent of the called party, unless the
call  is initiated for emergency purposes or is exempted by  rule
or  order  by  the Commission.”13  Section 64.1200(a)(2)  of  the
Commission’s  rules provides exemptions for calls  made  for:  1)
emergency  purposes;  2) non-commercial purposes;  3)  commercial
purposes  that  do  “not  include  or  introduce  an  unsolicited
advertisement14 or constitute a telephone solicitation”;15 4) calls
to  persons  “with  whom the caller has an  established  business
relationship16 at the time the call is made;” and 5) calls  “made
by or on behalf of a tax-exempt nonprofit organization.”17

     6.   As noted above, WCG initiated prerecorded messages that
invited  customers to try, without charge, custom golf clubs  and
requested  that  the  consumer call a toll-free  number  to  take
advantage  of  the special offer.  We find that  the  prerecorded
messages  at  issue  here were not made for any  emergency,  non-
commercial, or non-profit purposes, but were commercial in nature
and  included  or  introduced  “unsolicited  advertisements”   or
constituted “telephone solicitations.”  We have previously  found
that “prerecorded messages containing free offers and information
about  goods  and  services that are commercially  available  are
     prohibited to residential telephone subscribers, if not otherwise
exempt.18   The Commission’s rationale was based on a finding  by
Congress  that  consumers  considered the  prerecorded  telephone
calls to be “‘a nuisance and an invasion of privacy.’”19

     7.   The record also indicates that WCG did not have the prior
express consent of the consumers here to deliver this unsolicited
advertisement or telephone solicitation.  In fact, WCG  continued
to  deliver the messages to one consumer even after a request  to
refrain.20   The  record also indicates that  WCG  did  not  have
established  business  relationships  with  any  of   the   three
consumers  whose  complaints form the  basis  of  this  action.21
Despite conversations with counsel for WCG regarding the consumer
complaints  at issue, WCG has provided no argument nor  submitted
evidence  to prove an established business relationship,  a  tax-
exempt status, or any other evidence to provide a defense to  the
allegations at issue here.22  Therefore, based on the evidence in
the record, including the consumers’ affidavits, we find that the
prerecorded messages were unsolicited advertisements or telephone
solicitations  that were prohibited by section 227(b)(B)  of  the
Act23 or section 64.1200 (a)(2)24 of the Commission’s rules.

     B.   Proposed Forfeiture

     8.   We conclude that WCG apparently willfully or repeatedly
violated  the  Act  and  the Commission's  rules  and  orders  by
delivering unsolicited, prerecorded advertisement messages.   WCG
apparently  did  not cease its unlawful conduct  even  after  the
Commission  staff issued a citation warning that it was  engaging
in unlawful conduct and could be subject to monetary forfeitures.
Accordingly, a proposed forfeiture is warranted against  WCG  for
its apparent willful or repeated violations of section 227 of the
Act   and   of  the  Commission's  rules  and  orders   regarding
restrictions on telephone solicitations.

     9.    Section 503(b) of the Act authorizes the Commission to
assess  a forfeiture of up to $11,000 for each 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.25    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."26
     
     10.   Although the Commission's Forfeiture Policy  Statement
does  not  establish a base forfeiture amount for  violating  the
prohibition  on delivering unsolicited, prerecorded advertisement
messages  to  a  residential telephone  line,  we  believe  these
violations are similar in nature to violating the prohibition  on
delivering  unsolicited  advertisements  to  telephone  facsimile
machines.   The Commission has previously considered  $4,500  per
unsolicited fax advertisement as an appropriate base amount27 and
we  apply  that amount here to each of three of the four apparent
unsolicited, prerecorded advertisement violations.  We find  that
the  other  apparent violation at issue here justifies  a  higher
     proposed forfeiture because WCG continued to deliver the messages
to  this consumer even after repeated requests to refrain.  Where
a  party  has delivered unsolicited advertisements to a telephone
facsimile  machine  after a request to stop, the  Commission  has
increased the forfeiture to $10,000 per violation.28  Accordingly,
we  find  WCG apparently liable in the amount of $10,000 for  the
violation  where  WCG ignored the specific consumer  requests  to
discontinue  the  calls.29   This results  in  a  proposed  total
forfeiture of $23,500.  WCG shall have the opportunity to  submit
evidence  and arguments in response to this NAL to show  that  no
forfeiture should be imposed or that some lesser amount should be
assessed.30
     
IV.  CONCLUSION AND ORDERING CLAUSES

     11.  We have determined that WCG apparently violated section
227  of  the  Act  and  the  Commission's  rules  and  orders  by
delivering  at  least four unsolicited, prerecorded advertisement
messages  as  identified above.  We have further determined  that
WCG  is  apparently  liable  for forfeitures  in  the  amount  of
$23,500.
     
     12.    ACCORDINGLY,  IT  IS  ORDERED,  pursuant  to  section
503(b)(5)  of  the  Communications Act of 1934,  as  amended,  47
U.S.C.  § 503(b)(5), and section 1.80 of the Commission's  rules,
47  C.F.R.  § 1.80, and under the authority delegated by  section
0.11  and  0.311  of the Commission’s rules, 47 C.F.R.  §§  0.11,
0.311, that WCG, Inc. IS HEREBY NOTIFIED of an Apparent Liability
for  Forfeiture in the amount of $23,500 for willful or  repeated
violations  of  section 227(b)(1)(B) of  the  Act,  47  U.S.C.  §
227(b)(1)(B), section 64.1200(a)(2) of the Commission's rules, 47
C.F.R. §§ 64.1200(a)(2), and the related orders described in  the
paragraphs above.
     
     13.      The  Commission  will  not  consider  reducing   or
canceling a forfeiture in response to a claim of inability to pay
unless  the petitioner 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 petitioner’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.
          
             14.      Requests for payment of the full amount  of
this  Notice  of  Apparent Liability under  an  installment  plan
should  be  sent  to:  Chief, Revenue and Receivables  Operations
Group, 445 12th Street, S.W., Washington, D.C. 20554.31
     
     15.   IT IS FURTHER ORDERED, pursuant to section 1.80 of the
Commission's  rules, 47 C.F.R. § 1.80, that  within  thirty  (30)
days  of the release of this Notice, WCG, Inc. SHALL PAY the full
amount  of  the  proposed forfeiture32 OR SHALL FILE  a  response
showing  why  the proposed forfeiture should not  be  imposed  or
should be reduced.
     
     16.   IT  IS  FURTHER ORDERED that a copy of this Notice  of
Apparent Liability for Forfeiture SHALL BE SENT by certified mail
to  Brendan  Flaherty,  President, and H. Peter  Wheelahan,  Vice
President,  15 Mason, Suite A, Irvine, California  92618  and  to
Joseph  R. Donahue, Esq., 4621 Teller Avenue, Suite 200,  Newport
Beach, California 92660.
                    
                         FEDERAL COMMUNICATIONS COMMISSION



                         David H. Solomon
                         Chief, Enforcement Bureau
_______________________________
1  See  47  U.S.C. § 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 ...."  See also  47
U.S.C. § 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 does not fall within certain  categories
(e.g.,   common  carrier,  broadcaster,  cable  operator,   radio
licensee), so long as such person (a) 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  resident; and (c) subsequently engages in conduct of the type
described in the citation).
2 WCG is headquartered at 15 Mason, Suite A, Irvine, CA 92618.
3  See 47 U.S.C. § 227(b)(1)(B) and  section 64.1200(a)(2) of the
Commission's  rules, 47 C.F.R. §§ 64.1200(a)(2); see  also  Rules
and  Regulations  Implementing the Telephone Consumer  Protection
Act  of 1991, CG Docket No. 02-278, Report and Order, 18 FCC  Rcd
14014 (2003) (TCPA Revisions Report and Order).
4   See   Citation   from  Kurt  A.  Schroeder,   Deputy   Chief,
Telecommunications Consumers Division, Enforcement Bureau, issued
to WCG on April 29, 2003 (“April 29, 2003 Citation”).
5  See  47 U.S.C. § 503(b)(5) (requiring the Commission to  issue
citations to non-common carriers for violations of the Act or  of
the Commission's rules and orders).
6 See 47 U.S.C. § 227; 47 C.F.R. § 64.1200.
7  See  consumer  complaint from Todd Pollard, dated  August  15,
2002, which was attached to the citation.
8  See  Letter from Joseph R. Donahue, Law Offices of  Joseph  R.
Donahue  &  Associates, dated May 27, 2003, to Kurt A. Schroeder,
Deputy  Chief, Telecommunications Consumers Division, Enforcement
Bureau  (“WCG Response”).  The WCG Response was misdated as  2002
on  the  first  page.  Additionally, a previous response  letter,
also misdated as May 19, 2002, was not signed.
9 Id.
10 Id.
11 See the following consumer complaints: 1) Monte J. Dye, IC No.
04-W7795243, received February 16, 2004 (stating that prerecorded
message  was received on February 15, 2004); 2) Andrew  Pong,  IC
No.   04-W7875742,  received  February  27,  2004  (stating  that
prerecorded  message was received on February 15, 2004);  and  3)
Mark  James, received February 20, 2004 (stating that prerecorded
messages were received November 13, 2003 and February 13,  2004).
All  complainants signed declarations stating that they  did  not
have established business relationships with WCG.  With regard to
the  prerecorded message received by Mark James on  November  13,
2003, WCG entered into a Tolling Agreement (the “Agreement”) with
the Bureau, whereby the one-year statute of limitations set forth
in  47 U.S.C. § 503(b)(6) is tolled from September 10, 2004 until
the earlier of: (a) the date the FCC releases a NAL regarding any
of  the  alleged violations described in the Agreement;  (b)  the
date  the  FCC informs WCG in writing that it has terminated  the
investigation;  or (c) 180 days after the date of the  Agreement.
See  the  Agreement, signed on behalf of Kurt  Schroeder  of  the
Bureau on September 2, 2004 and by Brendan Flaherty, President of
WCG, on September 10, 2004.
12  See  the Declarations of Monte J. Dye, Andrew Pong, and  Mark
James,  all declaring under penalty of perjury that the  messages
advertised golf products offered by Warrior Custom Golf, Inc.
13 47 U.S.C. § 227(b)(1)(B).
14 “Unsolicited advertisement” means “any material advertising the
commercial  availability or quality of any  property,  goods,  or
services which is transmitted to any person without that person’s
prior   express   invitation  or  permission.”    47   C.F.R.   §
64.1200(f)(10).
15  “Telephone solicitation” means “the initiation of a telephone
call  or  message for the purpose of encouraging the purchase  or
rental of, or investment in, property, goods, or services,  which
is transmitted to any person.”  47 C.F.R. § 64.1200(f)(9).
16  An “established business relationship” is defined as “a prior
or   existing   relationship  formed  by  a   voluntary   two-way
communication  between  a  person or  entity  and  a  residential
subscriber with or without an exchange of consideration,  on  the
basis  of the subscribers purchase or transaction with the entity
within the eighteen (18) months immediately preceding the date of
the telephone call or on the basis of the subscriber’s inquiry or
application regarding products or services offered by the  entity
within  the  three months immediately preceding the date  of  the
call,  which  relationship has not been previously terminated  by
either party.”  47 C.F.R. § 64.1200(f)(3).
17 47 C.F.R. § 64.1200(a)(2).
18 TCPA Revisions Report and Order, 18 FCC Rcd at 14097-98 (2003).
19  Id.  at 14,097.  The Commission also noted that Congress  had
determined that the prerecorded messages “cause greater  harm  to
consumers’   privacy   than  telephone  solicitations   by   live
telemarketers”  because  consumers feel  powerless  to  stop  the
messages,  which  are often delivered to answering  machines  and
often  provide  no means to request placement on the  do-not-call
list.  Id.
20 See the complaint of Mark James (stating, “I telephoned Warrior
Custom  Golf regarding the first call at 1-800-600-5113.   I  was
directed  to a ‘Mr. Ross’ who called me back shortly.  .  .  ‘Mr.
Ross’  became rude and informed me that my name and number  would
be  removed  from  their database. . . After  that  conversation,
calls  from  the company ceased for several months.  Recently,  I
received  at  least two more calls, including the  February  13th
call.”).
21  See  the Declarations of Monte J. Dye, Andrew Pong, and  Mark
James, all declaring under penalty of perjury that: “To the  best
of  my knowledge, at no time did I or anyone else in my household
give  Warrior Custom Golf, Inc. prior express consent to  deliver
an   artificial   or  prerecorded  voice  advertisement   to   my
residential  telephone line.  Nor, to the best of  my  knowledge,
did  I  or  anyone else in my household (a) have any  transaction
with,  including  any purchase from, this entity  within  the  18
months  immediately preceding the date(s) of the above-referenced
call(s);  or  (b) make any inquiry or application to this  entity
within the three months immediately preceding the date(s) of  the
above-referenced calls.”
22  On  September 9, 2004, during one of numerous telephone calls
between Bureau staff and WCG counsel, Mr. Joseph R. Donahue,  Mr.
Donahue  requested copies of the consumer complaints at issue  to
ascertain whether WCG had established business relationships with
these  consumers.   The requested consumer complaint  information
was  sent by facsimile to Mr. Donahue on September 10, 2004.   To
date,  however,  despite many more communications between  Bureau
staff  and  Mr.  Donahue by telephone and  email,  no  claims  of
established  business relationships or other defenses  have  been
raised.
23 47 U.S.C. § 227(b)(1)(B).
24 47 C.F.R. § 64.1200(a)(2).
25 Section 503(b)(2)(C) provides for forfeitures up to $10,000 for
each  violation by cases not covered by subparagraph (A) or  (B),
which  address forfeitures for violations by licensees and common
carriers,  among others.  See 47 U.S.C. § 503(b).  In  accordance
with  the inflation adjustment requirements contained in the Debt
Collection Improvement Act of 1996, Pub. L. 104-134, Sec.  31001,
110  Stat.  1321, the Commission implemented an increase  of  the
maximum  statutory  forfeiture  under  section  503(b)(2)(C)   to
$11,000.   See  47  C.F.R. §1.80(b)(3).  The Commission  recently
amended  its rules to increase the maximum penalties  to  account
for  inflation  since the last adjustment of the  penalty  rates.
The new rates will apply to violations that occur after September
7,  2004.  In the Matter of Amendment of Section 1.80(b)  of  the
Commission’s Rules and Adjustment of Forfeiture Maxima to Reflect
Inflation, Order, FCC 04-139 (rel. June 18, 2004).
26  47  U.S.C. § 503(b)(2)(D); The Commission’s Forfeiture Policy
Statement  and  Amendment  of  Section  1.80  of  the  Rules   to
Incorporate the Forfeiture Guidelines, Report and Order,  12  FCC
Rcd  17087,  17100-17101, (1997), recon. denied, 15 FCC  Rcd  303
(1999) (Forfeiture Policy Statement).
27   See  Get-Aways,  Inc.,  Notice  of  Apparent  Liability  For
Forfeiture, 15 FCC Rcd. 1805 (1999); Get-Aways, Inc.,  Forfeiture
Order,  15 FCC Rcd 4843 (2000); Tri-Star Marketing, Inc.,  Notice
of  Apparent  Liability For Forfeiture, 15 FCC Rcd 11,295  (2000)
(Tri-Star  Marketing NAL); Tri-Star Marketing,  Inc.,  Forfeiture
Order,  15  FCC Rcd 23,198 (2000) (Tri-Star Marketing  Forfeiture
Order);  Carolina Liquidators, Inc., Notice of Apparent Liability
for  Forfeiture, 15 FCC Rcd. 16,837 (2000) (Carolina  Liquidators
NAL);  Carolina Liquidators, Inc., Forfeiture Order, 15  FCC  Rcd
21,775  (2000)  (Carolina  Liquidators  Forfeiture  Order);  21st
Century  Fax(es)  Ltd.  a.k.a. 20th Century  Fax(es),  Notice  of
Apparent Liability for Forfeiture, 15 FCC Rcd 24,406 (2000); 21st
Century  Fax(es)  Ltd.  a.k.a. 20th Century  Fax(es),  Forfeiture
Order, 17 FCC Rcd 1384 (2002).
28   See  Tri-Star Marketing NAL, 15 FCC Rcd at 11,300;  Carolina
Liquidators NAL, 15 FCC Rcd at 16,842.
29  See  Tri-Star  Marketing NAL, 15 FCC Rcd at 11,300;  Carolina
Liquidators NAL, 15 FCC Rcd at 16,842.
30 See 47 U.S.C. § 503(b)(4)(C); 47 C.F.R. § 1.80(f)(3).


31 47 C.F.R. § 1.1914.
32  The forfeiture amount should be paid by check or money  order
drawn  to  the  order  of the Federal Communications  Commission.
Reference  should  be  made on WCG's  check  or  money  order  to
"NAL/Acct/ No. 200432170004."  Such remittances must be mailed to
Forfeiture   Collection   Section,   Finance   Branch,    Federal
Communications  Commission,  P.O. Box  73482,  Chicago,  Illinois
60673-7482.