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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-0362, 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 statements; 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 15
complaints filed by the Parents Television Council
(``PTC'')2 against various television broadcast licensees
alleging violations of the federal restrictions regarding
the broadcast of indecent material.3 PTC provided
transcripts of the segments it considers indecent and
provided videotapes of each of the 15 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.''4 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.5 Consistent
with a subsequent statute and court case,6 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.7 The Commission may impose a
monetary forfeiture, pursuant to section 503(b)(1) of the
Communications Act of 1934, as amended8 (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 Act, which
prohibit the Commission from interfering with broadcasters'
freedom of expression and from censoring program material.9
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.10
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.11
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.12
None of the broadcasts described below meets the second part
of our standard.13
5. In determining whether material is patently
offensive, the Commission has indicated that the ``full
context in which the material appeared is critically
important,''14 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.''15 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.''16 In particular cases, one or two of the
factors may outweigh the others, either rendering the
broadcast material patently offensive and consequently
indecent,17 or, alternatively, removing the broadcast
material from the realm of indecency.18
6. Outlined below is a description of the
allegedly indecent material cited in PTC's
complaints.
a. Boston Public,'' October 29, 2001, 8 p.m. EST: a
student challenges a teacher's
assignment, and the teacher says to the student, ``Did you
know, Mr. Pratt, that you are a big dick? Do we have any
other big dicks with us today?''19 In a subsequent scene,
another character asks the teacher whether he wants to get
fired, and the teacher responds, ``Is this about me calling
a student a dick?''20 The other character admonishes him,
``No more dick talk.''21
b. ``AUSA,'' March 18, 2003, 9:30 p.m. EST: one
scene depicts Adam, a lawyer, lying
on a hotel bed watching an adult movie on the hotel's video
system (no video images are visible).22 Dialogue from one
video, ``Here Comes the Judge,'' is audible: Male voice:
``The defense rests.'' Female voice: ``Not tonight. Now
hand over those briefs.''23 The next scene shows the lawyer
waking up and realizing that the adult channel continued to
play while he slept.24 Remaining scenes contain jokes about
his watching adult entertainment all night, to wit: Adam:
``What's [my boss] going to say when he finds out I spent
nine of my 16 hours here in Arizona watching porn?'' Clerk:
``You're a sad, lonely man with remarkable stamina.''
Another scene depicts a woman asking Adam if ``he's
decent,'' and he remarks: ``I'm buttered from the waist
down.''25 Another scene has a character listing the movies
Adam paid for: ``Jurassic Pork, Laid in Manhattan, Catch Me
in the Can.''
c. Night of Too Many Stars,'' May 31, 2003, 8 p.m.
EDT: comedian Dana Carvey,
reprising his role as the Saturday Night Live character,
``Church Lady,'' says to the actor Macaulay Culkin:
``...then we jumped on the puberty train and got all tingly
. . . we want to fornicate, so we thought it would be nifty
to get married when we were twelve.''26 Dana Carvey later
discusses Michael Jackson and says of him: ``Did he ever
dangle anything in front of you at the sleepovers? . . .
Say, his happy man-loaf? . . . When he moon walked, he
didn't moon you as he walked, did he? . . . Did he ever get
into Billy's jeans?''27 Another character asks whether
``his [Jackson's] shalonthaz [sic] ever rose up to salute
you? You never played hide the toast?''28
d. ``Friends,'' October 23, 2003, 8 p.m. EDT: in an
apparent mix-up, a bakery
inadvertently substitutes a cake shaped like a penis for a
child's birthday cake (the cake is not shown). A female
character exclaims, ``Ahh! They put my baby's face on a
penis!''29 A male character replies, ``Uhh, is it okay that
I still think it looks delicious?''30 Another male
character says: ``I am this close to tugging on my
testicles again.''31 When the mix-up is corrected, a male
character again comments that the cake ``looked more
delicious when it was a penis.''32
e. ``The Next Joe Millionaire,'' October 28, 2003, 8
p.m. EST: the complaint alleges
that a character says ``fuck off.''33 Based on our review
of the tape, however, this description is inaccurate in that
no character appears to utter the quoted language.
f. ``One Tree Hill,'' October 28, 2003, 9 p.m. EST:
one female character is depicted
putting her lips to a hose that had been inserted into a gas
tank.34 Seeing this, another female character quips, ``Had
a lot of practice? Siphoning gas, what'd you think I
meant?''35
k. ``A Minute with Stan Hooper,'' October 29, 2003,
8:30 p.m. EST: The title character
interviews two men who are married [to each other] and asks
how they decided to use one surname over the other.36 They
respond that, since the surname of one of the pair was
Cockburn, they thought that it would be an inappropriate
married name for two gay men (the man named Cockburn fans
his genital area with his apron).37
l. ``Friends,'' November 6, 2003, 8 p.m. EST:
certain characters use the words ``hell,''
``damn,'' and the phrase ``sons of bitches.''38 There is
also a scene in which one character asks a man to guess
which person had received a grant, and the man answers,
``Well, unless it's the creepy guy with his hand up his
kilt, I'm gonna say congratulations.''39 Later, the
character is wondering aloud how he can get someone to issue
him a grant, and he asks the man, ``Is there anything I can
do to butter him up?'' The man replies, ``He does have a
pretty serious latex fetish.''40
m. ``Will & Grace,'' November 6, 2003, 9 p.m. EST: a
male character with a very strong
attachment to his mother describes the greatest tragedy of
his life as ``the day they yanked me from the breast of that
saint.''41 A female character, Karen, has a grudge against
a woman named Lorraine; when Karen locates her, she says ``I
could do to her what she did to Stan - have sex with her
until she dies. Yep, that's what I'm gonna do.''42 She
then knocks on a door and says, ``Open up, Lorraine, and put
on a condom.''43 There is another scene in which Karen
talks about ``sex[ing] the life out of'' Lorraine. Certain
characters say the words ``bitch,'' ``bosom,'' and
``whore.'' The show also contains several scenes in which
male characters talk about kissing men and female characters
talk about kissing women.
n. ``Scrubs,'' November 6, 2003, 9:30 EST: one
character says the word ``bastards,'' and
another character describes a woman as having ``huge
cans.''44 One scene contains the following dialogue: Dan:
``I heard there's a bed in the on-call room. You ever get
hot and heavy in there? JD: ``No, I usually am there by
myself.'' Dan: ``So yes.''45 In another scene, a male
character takes a pair of boxer shorts from the freezer, and
another male character says ``Make sure you're nice and dry
down there. Otherwise, you could get a tongue-on-the-
flagpole situation.''46 There is another scene in which two
female characters discuss whether they've ever had ``phone
sex'' with their boyfriends. One of the character's
responds that when her boyfriend, Turk, returned home for
Thanksgiving, she called and was surprised by how much
``Turk's eleven year-old nephew sounds like him . . . and
how worldly he is.''47 In a later scene, one of the women
is shown standing alone in a cornfield, at night, talking on
the phone with her boyfriend, and she says: ``Hi sweetie -
are you naked? OK, um, now imagine me taking off my shirt,
kissing down your neck . . . now I am licking your nipples
all over. Your nipples.'' She is then interrupted by a
group of boy scouts hiking through the field and ends her
conversation abruptly by saying, ``I don't care how close
you are. I'll call you later.''
o. ``Friends,'' November 13, 2003, 8 p.m. EST:
certain characters use the words ``hell,''
``crap,'' ``pissed,'' ``bastard,'' and the phrase ``son of a
bitch.''48 One character says he ``didn't say the F-
word.''49 Other characters ponder where a male character
may have hidden ``porn.''50 A male character states, ``You
broke my heart. Do you know how many women I had to sleep
with to get over you?''51
p. ``The Simpsons,'' November 16, 2003, 8 p.m. EST:
in this animated program, a scene
depicts students carrying picket signs that read ``Don't cut
off my pianissimo'' and ``What would Jesus glue?''52 A male
character says ``Well, I guess this story has a happy ending
after all. Just like my last massage.''53
q. ``Run of the House,'' November 20, 2003, 9:30 p.m.
EST: one character, Kirk, says to
a policeman, ``Thanks for stopping by, dick.'' The
policeman remarks that he is a patrolman, not a detective,
and asks why Kirk called him a ``dick.'' Kirk retorts,
``you seem like such a dick to me.''54
r. ``King of the Hill,'' November 23, 2003, 7:30 p.m.
EST: in this animated program, a
cartoon boy is shown about to enter a communal shower at his
school. An off-screen voice emanating from the shower asks,
``Is that a pimple or another nipple?''55 As the cartoon
boy removes his towel and enters the shower, his buttocks
are briefly depicted.56
s. ``Scrubs,'' December 11, 2003, 9:30 p.m. EST: a
female patient emits moans of
pleasure while a female doctor gives her a pelvic exam.57 A
male doctor ribs the female doctor by saying, ``Don't be
embarrassed. You're not the first person to give a patient
an orgasm during a pelvic exam.'' The male doctor
fantasizes about the female doctor's examining an attractive
woman wearing a lacey bra. Another doctor comments that the
other male doctor ``never really satisfied a woman,'' to
which the doctor responds, ``Well, you might want to double
check with your mom.''58
7. To support a finding of indecency, we must
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.
8. Two complaints cite uses of the word ``dick.'' In
context and as used in the complained of broadcasts, these
were epithets intended to denigrate or were a play on words.
Their use in these contexts was not sufficiently explicit or
graphic and/or sustained to be patently offensive.
Similarly, we find that fleeting uses of the words ``hell,''
damn,'' ``orgasm,'' ``penis,'' ``testicles,'' ``breast,''
``nipples,'' ``can,'' ``pissed,'' ``crap,'' ``bastard,'' and
``bitch,'' uttered in the context of the programs cited in a
number of complaints, are not profane and do not represent
graphic descriptions of sexual or excretory organs or
activities such that the material is rendered patently
offensive by contemporary community standards for the
broadcast medium. 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. We also find that the
material containing inaudible or bleeped expletives do not
render the broadcasts patently offensive. In such cases,
the broadcaster has exercised appropriate editorial control
over its programming by deleting or editing out utterances
that might otherwise constitute indecent material. Finally,
we find that none of these words, in context, was profane.
9. One of the complaints cites material that depicts
partial nudity. That complaint involved the animated
program ``King of the Hill,'' which contained a rudimentary
depiction of a cartoon boy's buttocks was fleeting. 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. Several complaints concern material that alludes
to sexual activity or depicts men and women engaging in
physical activity that implies sexual activity. None of the
complained of material was sufficiently graphic or sustained
to rise to the level of being patently offensive for the
broadcast medium, however.
11. 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
12. For the reasons discussed above, we find that
none of the material contained in the 15 complaints is
patently offensive as measured by contemporary community
standards for the broadcast medium. We therefore conclude
that none of the material in the complaints is indecent.
IV. ORDERING CLAUSES
13. Accordingly, IT IS ORDERED, that the 15complaints
listed in the Appendix are hereby DENIED.
14. 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- WTTG(TV) Fox Television Boston Public,
0419 Washing- Stations, Inc. October 29, 2001,
ton, DC 8 p.m. EST
EB-03-IH- WRC-TV NBC Telemundo AUSA, March 18,
0363 Washing- License Co. 2003, 9:30 p.m.
ton, DC EST
EB-03-IH- WRC-TV NBC Telemundo Night of Too Many
0362 Washing- License Co. Stars, May 31,
ton, DC 2003, 8 p.m. EDT
EB-03-IH- WRC-TV NBC Telemundo Friends, October
0661 Washing- License Co. 23, 2003, 8 p.m.
ton, DC EDT
EB-03-IH- WTTG(TV) Fox Television The Next Joe
0681 Washing- Stations, Inc. Millionaire,
ton, DC October 28, 2003,
8 p.m. EST
EB-03-IH- WBDC-TV WBDC One Tree Hill,
0668 Washing- Broadcasting, October 28, 2003,
ton, DC Inc. 9 p.m. EST
EB-03-IH- WTTG(TV) Fox Television A Minute with
0678 Washing- Stations, Inc. Stan Hooper,
ton, DC October 29, 2003,
8:30 p.m. EST
EB-03-IH- WRC-TV NBC Telemundo Friends, November
0662 Washing- License Co. 6, 2003, 8 p.m.
ton, DC EST
EB-03-IH- WRC-TV NBC Telemundo Will & Grace,
0664 Washing- License Co. November 6, 2003,
ton, DC 9 p.m. EST
EB-03-IH- WRC-TV NBC Telemundo Scrubs, November
0666 Washing- License Co. 6, 2003, 9:30
ton, DC p.m. EST
EB-03-IH- WRC-TV NBC Telemundo Friends, November
0663 Washing- License Co. 13, 2003, 8 p.m.
ton, DC EST
EB-03-IH- WTTG(TV) Fox Television The Simpsons,
0671 Washing- Stations, Inc. November 16,
ton, DC 2003, 8 p.m. EST
EB-03-IH- WBDC-TV WBDC Run of the House,
0715 Washing- Broadcasting, November 20,
ton, DC Inc. 2003, 9:30 p.m.
EST
EB-03-IH- WTTG(TV) Fox Television King of the Hill,
0714 Washing- Stations, Inc. November 23,
ton, DC 2003, 7:30 p.m.
EST
EB-04-IH- WRC-TV NBCTelemundo Scrubs, December
0087 Washing- License Co. 11, 2003, 9:30
ton, DC p.m. 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 January 22,
2004.
2 Between July 3, 2003, and January 22, 2004, PTC filed 15
separate complaints discussed herein against various
television licensees. Each complaint alleges that each of
the subject licensees broadcast indecent material on
programs aired between October 29, 2001, and December 11,
2003.
3 See 18 U.S.C. § 1464; 47 C.F.R. § 73.3999.
4 18 U.S.C. § 1464.
5 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'').
6 See Public Telecommunications Act of 1992, Pub. L. No.
102-356, 106 Stat. 949 (1992), as modified by ACT III.
7 See 47 C.F.R. § 73.3999.
8 See 47 U.S.C. § 503(b)(1). See also 47 U.S.C. § 312(a)(6)
(authorizing license revocation for indecency violations).
9 U.S. CONST., amend. I; 47 U.S.C. § 326.
10 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.'').
11 Infinity Broadcasting Corporation of Pennsylvania,
Memorandum Opinion & Order, 2 FCC Rcd 2705 (1987)
(subsequent history omitted) (citing Pacifica Foundation,
Memorandum Opinion & Order, 56 FCC 2d 94, 98 (1975), aff'd
sub nom. FCC v. Pacifica Foundation, 438 U.S. 726 (1978)).
12 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).
13 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.
14 Indecency Policy Statement, 16 FCC Rcd at 8002, ¶ 9
(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.
15 Indecency Policy Statement, 16 FCC Rcd at 8003, ¶ 10
(emphasis in original).
16 Id.
17 Id. at 8009, ¶ 19 (citing Tempe Radio, Inc (KUPD-FM),
Notice of Apparent Liability, 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)),
Notice of Apparent Liability, 12 FCC Rcd 4147 (MMB 1997)
(forfeiture paid) (same)).
18 Indecency Policy Statement, 16 FCC Rcd 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'').
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-0419).
20 Id.
21 Id.
22 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-0363).
23 Id.
24 Id.
25 Id.
26 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-0362).
27 Id.
28 Id.
29 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated October 29, 2003 (EB-03-IH-0661).
30 Id.
31 Id.
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-0681).
34 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-0668).
35 Id.
36 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 12, 2003 (EB-03-IH-0678).
37 Id.
38 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 12, 2003 (EB-03-IH-0662).
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 12, 2003 (EB-03-IH-0664).
42 Id.
43 Id.
44 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 17, 2003 (EB-03-IH-0666).
45 Id.
46 Id.
47 Id.
48 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated November 12, 2003 (EB-03-IH-0663).
49 Id.
50 Id.
51 Id.
52 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-0671).
53 Id.
54 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-0715).
55 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-0714).
56 Id.
57 See Letter from Lara Mahaney, Director of Corporate and
Entertainment Affairs, PTC, to David Solomon, Chief,
Enforcement Bureau, dated January 22, 2004 (EB-03-IH-0087).
58 Id.