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Before the
Federal Communications Commission
Washington, D.C. 20554
)
)
File No. EB-08-SE-559
In the Matter of )
NAL/Acct. No. 200832100078
Hannspree North America, Inc. )
FRN # 0018065409
)
)
Notice of apparent Liability for forfeiture
Adopted: August 26, 2008 Released: August 28, 2008
By the Chief, Enforcement Bureau:
I. introduction
1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
Hannspree North America, Inc. ("Hannspree") apparently liable for a
forfeiture in the amount of $12,450 for its willful and repeated
violation of Section 15.117(i)(1)(iii) of the Commission's Rules
("Rules"). These apparent violations involve Hannspree's interstate
shipment of television receivers that do not comply with the
Commission's rules regarding digital television ("DTV") reception
capability.
II. Background
2. The Commission adopted the DTV reception capability requirement in
2002. This requirement, which is often termed the "DTV tuner
requirement," requires that all new television broadcast receivers
that are imported into the United States or shipped in interstate
commerce be capable of receiving the signals of DTV broadcast stations
over-the-air. The DTV tuner requirement was intended to facilitate the
transition to digital television by promoting the availability of DTV
reception equipment and to protect consumers by ensuring that their
television receivers will provide over-the-air television reception of
digital signals just as they have provided over-the-air television
reception of analog signals.
3. Section 15.117(i)(1) of the Rules provides, "[r]esponsible parties, as
defined in S: 2.909 of this chapter, are required to equip new TV
broadcast receivers that are shipped in interstate commerce or
imported from any foreign country into the United States and for which
they are responsible to comply with the provisions of this section" in
accordance with the specified phase-in schedule. As modified by the
Commission in 2005, this phase-in schedule is as follows:
Receivers with screen sizes 36" and above -- 50% of units imported or
shipped interstate by responsible parties were required to include DTV
tuners effective July 1, 2004; 100% of such units were required to include
DTV tuners effective July 1, 2005;
Receivers with screen sizes 25" to 35" -- 50% of units imported or shipped
interstate by responsible parties were required to include DTV tuners
effective July 1, 2005; 100% of such units were required to include DTV
tuners effective March 1, 2006;
Receivers with screen sizes less than 25" - 100% of units imported or
shipped interstate by responsible parties were required to include DTV
tuners effective March 1, 2007; and
Other video devices (videocassette recorders (VCRs), digital video
recorders such as hard drive and DVD recorders, etc.) that receive
television signals - 100% of units imported or shipped interstate by
responsible parties were required to include DTV tuners effective March 1,
2007.
4. The Commission's 2005 DTV Tuner Second Report and Order amended the
rules to apply the DTV tuner requirement to new receivers with screen
sizes smaller than 13" on this same schedule (i.e., March 1, 2007).
Although the Commission adopted this requirement for receivers with
screen sizes smaller than 13" through the appropriate notice and
comment procedures, and modified the rules to show March 1, 2007, as
the accelerated deadline, the Commission inadvertently failed to
delete the exception in Section 15.117(i)(2) for "units with
integrated tuners/displays that have screen sizes measuring less than
7.8 inches vertically, i.e., the vertical measurement of a screen in
the 4:3 aspect ratio that measures 13' [sic] diagonally across the
picture viewing area." The Commission subsequently corrected Section
15.117(i)(2) by striking the inappropriate language, and the DTV tuner
requirements for receivers with screen sizes less than 13" became
effective on January 30, 2008.
5. Hannspree North America, a subsidiary of Hannstar Display Corporation,
is a California-based importer and retailer of television broadcast
receivers. In April 2008, the Enforcement Bureau ("Bureau") received a
complaint which alleged that Hannspree was marketing television
receivers that were inconsistent with Commission regulations. The
Bureau issued a letter of inquiry ("LOI") to Hannspree on July 8, 2008
regarding the company's importation and interstate shipment of
television receivers. Hannspree filed its response to the LOI on
August 6, 2008.
6. In its LOI Response, Hannspree stated that, since March 1, 2007, it
had imported into the United States only two models of television
receivers, both of which are equipped with DTV tuners, but had shipped
interstate more than three dozen models that are not equipped with DTV
tuners, with screen sizes of 10, 12, 15, or 23 inches, measured
diagonally. Hannspree stated that it shipped interstate a total of
3,735 such receivers after March 1, 2007. Hannspree further stated
that it presently holds inventory of 2,949 television receivers that
are not equipped with DTV tuners.
7. Hannspree asserted its belief that the non-DTV-compliant television
receivers may lawfully be imported and shipped interstate because, on
each of its retail tables that displays an analog television, the
company places a sign that both identifies the set as an analog
television and displays the FCC Consumer Alert. The company also
states that it displays an additional FCC Consumer Alert sign at each
point-of-sale cash register.
III. DISCUSSION
A. Failure to Comply with DTV Tuner Requirement
8. We conclude that Hannspree apparently willfully and repeatedly shipped
television receivers in interstate commerce in violation of Section
15.117(i)(1)(iii) of the Rules. Section 15.117(i) applies to all "new
television broadcast receivers that are shipped in interstate commerce
or imported from any foreign country into the United States," and
mandates that such receivers with screen sizes less than 25 inches
"include a DTV tuner effective March 1, 2007." Hannspree admits that,
after March 1, 2007, it shipped interstate 3,375 television broadcast
receivers that were not equipped with DTV tuners. Because the DTV
tuner requirement became effective for television receivers with
screen sizes measuring less than 13" only on January 30, 2008, we do
not consider those 2,246 receivers with screen sizes less than 13"
that Hannspree shipped interstate prior to the effective date.
Accordingly, we find that Hannspree shipped in interstate commerce
1,129 television receivers that fail to comply with the DTV tuner
requirement.
9. Hannspree contends, however, that it could lawfully import and ship
non-DTV-compliant television receivers because it displays the
Consumer Alert notice mandated by Section 15.117(k) beside the
receivers. We find no merit in this contention. Section 15.117(k) is
inapposite to the requirement at issue here. Section 15.117(k)
requires responsible parties to place in close proximity to
non-DTV-compliant television receivers a Consumer Alert sign that
informs the consumer that the receiver will need a converter box to
receive over-the-air broadcasts with an antenna after the digital
transition takes place. The Commission adopted the rule "[t]o ensure
that consumers do not inadvertently buy analog-only television
equipment without understanding that such devices will require some
additional equipment for use after analog broadcasting ends."
10. Hannspree's compliance with Section 15.117(k) is irrelevant to whether
the company has complied with the DTV tuner requirement. That rule --
Section 15.117(i) -- seeks to facilitate an effective transition to
digital by ensuring that "a greater portion of all TV receiver
products that are in use by consumers at the time analog service
ceases will be able to receive broadcasters' digital signals and thus
provide a smooth and orderly completion of the switchover process."
The continued importation and shipment of new analog-only receivers by
responsible parties, even if properly displayed for retail, defeats
this key objective. Section 15.117(k) provides no exemption from the
separate and distinct prohibition on the importation and interstate
shipment of non-DTV-compliant television receivers set forth in
Section 15.117(i).
A. Proposed Forfeiture
11. Under Section 503(b)(1)(B) of the Act, any person who is determined by
the Commission to have willfully or repeatedly failed to comply with
any provision of the Act or any rule, regulation, or order issued by
the Commission shall be liable to the United States for a forfeiture
penalty. To impose such a forfeiture penalty, the Commission must
issue a notice of apparent liability and the person against whom such
notice has been issued must have an opportunity to show, in writing,
why no such forfeiture penalty should be imposed. The Commission will
then issue a forfeiture if it finds by a preponderance of the evidence
that the person has violated the Act or a Commission rule. Based on
the analysis set forth below, we conclude that Hannspree is apparently
liable for a forfeiture in the amount of $12,450 for its willful and
repeated violation of Section 15.117(i)(1)(iii) of the Rules.
12. Under Section 503(b)(2)(D) of the Act, the Commission may assess an
entity that is neither a common carrier, broadcast licensee or cable
operator a forfeiture of up to $11,000 for each violation or each day
of a continuing violation, up to a statutory maximum forfeiture of
$97,500 for any single continuing violation. In exercising such
authority, we are required 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."
13. The Commission's Forfeiture Policy Statement and Section 1.80 of the
Rules do not establish a specific base forfeiture for violation of the
DTV tuner requirement. However, the Commission has substantial
discretion in proposing forfeitures and has stressed that digital
signal reception capability is of critical importance to a successful
digital transition for the nation. In its previous DTV tuner cases,
the Commission concluded that applying a proposed forfeiture on a per
model basis would result in forfeiture amounts that are not
commensurate with the seriousness of the violation. Accordingly, the
Commission determined that, in cases involving the interstate shipping
or importation of non-DTV-compliant television receivers, we would
propose a forfeiture based upon each unit shipped or imported within
the statute of limitations, rather than upon the number of models
shipped or imported.
14. We apply the following tiers and per-unit penalties for violation of
the Commission's DTV tuner requirements:
0-1000 units: $50 per unit
1001-2500 units: $75 per unit
2501-5000 units: $100 per unit
5001-10,000 units: $125 per unit
10,001-20,000 units: $150 per unit
20,001-30,000 units: $175 per unit
30,001-40,000 units: $200 per unit
40,001-50,000 units: $225 per unit
50,001+ units: $250 per unit
Consistent with the Commission's other DTV tuner NALs, we will use the
tier-by-tier, per-unit methodology articulated in those decisions to
assess the forfeiture here.
15. Although Hannspree imported 1,129 non-DTV-compliant television
receivers between March 1, 2007 and the August 6, 2008 date of its LOI
Response, 880 of those receivers were shipped more than one year prior
to the date of this NAL. Section 503(b)(6)(B) of the Act prohibits the
Commission from imposing a forfeiture penalty against a person that
does not hold a broadcast license "if the violation occurred more than
1 year prior to the date of issuance of the required notice or notice
of apparent liability." This section does not, however, bar the
Commission from considering conduct which occurred before the one-year
period in its determination of the appropriate forfeiture amount for
violations that occurred within that period. Therefore, we consider
Hannspree's conduct which occurred outside of the one-year statute of
limitations but propose a forfeiture here only for those 249
non-DTV-compliant receivers shipped interstate within the one-year
period.
16. Applying the forfeiture calculation methodology outlined above, we
propose a forfeiture of $12,450 for Hannspree's willful and repeated
interstate shipment of television receivers that do not comply with
the DTV tuner requirement in violation of Section 15.117(i)(1)(iii) of
the Rules.
IV. ordering clauses
17. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the
Act, and Section 1.80 of the Rules, Hannspree North America,
Incorporated is NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE in
the amount of twelve thousand four hundred and fifty dollars ($12,450)
for willful and repeated violation of Section 15.117(i)(1)(iii).
18. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Rules,
within thirty days of the release date of this Notice of Apparent
Liability for Forfeiture, Hannspree SHALL PAY the full amount of the
proposed forfeiture or SHALL FILE a written statement seeking
reduction or cancellation of the proposed forfeiture.
19. 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/Account Number and FRN Number referenced
above. Payment by check or money order may be mailed to Federal
Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.
Payment by overnight mail may be sent to U.S. Bank - Government
Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
63101. Payment by wire transfer may be made to ABA Number 021030004,
receiving bank TREAS/NYC, and account number 27000001. For payment by
credit card, an FCC Form 159 (Remittance Advice) must be submitted.
When completing the FCC Form 159, enter the NAL/Account number in
block number 23A (call sign/other ID), and enter the letters "FORF" in
block number 24A (payment type code). Requests for full payment under
an installment plan should be sent to: Chief Financial Officer --
Financial Operations, 445 12th Street, S.W., Room 1-A625, Washington,
D.C. 20554. Please contact the Financial Operations Group Help Desk
at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov with any questions
regarding payment procedures. Hannspree will also send electronic
notification on the date said payment is made to JoAnn Lucanik at
JoAnnLucanik@fcc.gov and to Kevin M. Pittman at Kevin.Pittman@fcc.gov.
20. The response, if any, must be mailed to the Office of the Secretary,
Federal Communications Commission, 445 12th Street, S.W., Washington,
D.C. 20554, ATTN: Enforcement Bureau - Spectrum Enforcement Division,
and must include the NAL/Acct. No. referenced in the caption. The
response should also be emailed to JoAnn Lucanik at
JoAnnLucanik@fcc.gov and to Kevin M. Pittman at Kevin.Pittman@fcc.gov.
21. 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; 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.
22. 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 Eric Hsu, Vice-President of Operations,
Hannspree North America, Inc., 14450 Myford Road, Irvine, California
92606-1001.
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief, Enforcement Bureau
47 C.F.R. S: 15.117(i)(1)(iii).
See 47 C.F.R. S: 15.3(w) (defining a television broadcast receiver as "a
device designed to receive television pictures that are broadcast
simultaneously with sound on the television channels authorized under part
73 of this chapter").
Review of the Commission's Rules and Policies Affecting the Conversion to
Digital Television, Second Report and Order and Second Memorandum Opinion
and Order, 17 FCC Rcd 15978 (2002) ("DTV Review Second Report and Order").
DTV reception capability involves more circuitry than just a tuner. To
provide this capability requires a tuner to receive the digital signal, an
MPEG decoder/formatter, and associated processing capability and memory.
See Requirements for Digital Television Receiving Capability, Report and
Order and Further Notice of Proposed Rulemaking, 20 FCC Rcd 11196 n.2
(2005) ("DTV Tuner Report and Order").
DTV Review Second Report and Order, 17 FCC Rcd at 15996. The DTV tuner
requirement also applies to other devices such as television interface
devices that do not include a viewing screen, e.g., devices such as VCRs
and DVD players that are intended to provide audio-video signals to a
video monitor with an antenna or antenna terminals that can be used for
over-the-air television reception. See 47 C.F.R. S: 15.117(i)(1)(iv).
Id. at 15979. In this latter regard, the DTV tuner requirement ensures
that the intent of the All Channel Receiver Act of 1962 ("ACRA"), P.L. No.
87-529, 76 Stat. 150, is fulfilled. The ACRA, which is codified at 47
U.S.C. S: 303(s), states that the Commission shall "[h]ave authority to
require that apparatus designed to receive television pictures broadcast
simultaneously with sound be capable of adequately receiving all
frequencies allocated by the Commission to television broadcasting ...."
See DTV Review Second Report and Order, 17 FCC Rcd at 15589-91.
47 C.F.R. S: 15.117(i)(1).
In June 2005, the Commission modified the rules to advance the date on
which 100% of new television receivers with screen sizes 25-36" that are
imported or shipped interstate must include DTV tuners from July 1, 2006
to March 1, 2006. DTV Tuner Report and Order, 20 FCC Rcd at 11203.
Subsequently, in November 2005, the Commission modified the rules to
advance the date on which 100% of new television receivers with screen
sizes 13-24" and certain other television receiving devices such as VCRs
and digital video recorders that are imported or shipped interstate must
include DTV tuners from July 1, 2007 to March 1, 2007. See Requirements
for Digital Television Receiving Capability, Second Report and Order, 20
FCC Rcd 18607, 18614-16 (2005) ("DTV Tuner Second Report and Order").
The DTV tuner requirement applies to "responsible parties," as defined in
Section 2.909 of the Rules, 47 C.F.R. S: 2.909. Under Section 2.909(b),
the party responsible for equipment such as television receivers that are
subject to our "verification" equipment authorization procedure is the
manufacturer or, in the case of imported equipment, the importer. If
subsequent to manufacture and importation, the equipment is modified by
any party not working under the authority of the responsible party, the
party performing the modification becomes the new responsible party.
DTV Tuner Second Report and Order, 20 FCC Rcd at 18614-16.
See Third Periodic Review of the Commission's Rules and Policies Affecting
the Conversion to Digital Television, Report and Order, 23 FCC Rcd 2994,
3081 (2007).
See Third Periodic Review of the Commission's Rules and Policies Affecting
the Conversion to Digital Television, Final Rule, 73 Fed. Reg. 5634 (Jan.
30, 2008).
See Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
Enforcement Bureau, Federal Communications Commission, to Hannspree North
America, Inc., (July 8, 2008) ("LOI").
See Letter from Eric Hsu, Vice-President of Operations, Hannspree North
America, Inc., to Kathryn S. Berthot, Chief, Spectrum Enforcement
Division, Enforcement Bureau, Federal Communications Commission (August 6,
2008) ("LOI Response").
Id. at 1. Specifically, Hannspree shipped interstate the following models
of television receivers that are not equipped with DTV tuners:
DT07-10U1-000; DT12-10U1-000; F001-15U1-000; F609-15U1-0011;
F617-15U1-000; F629-10U1-000; F633-10U1-000; F637-10U1-000; F651-12U1-000;
K206-10U1-005; K206-10U1-010; K209-10U1-000; K212-10U1-000B;
K223-10U1-000; K226-10U1-000; LT09-10U1-000; LT09-10U1-0001;
LT13-23U1-001; ST02-15U1-019; ST02-15U1-030; ST03-15U1-000; ST06-15U1-000;
ST08-10U1-000; ST09-10U1-011; ST23-10U1-000; ST35-15U1-003; ST35-15U1-015;
ST35-15U1-022; ST35-15U1-0071; ST35-15U1-0111; ST35-15U1-0211;
ST35-15U1-0251; ST35-15U1-0261; ST35-15U1-0281; ST35-15U1-0301;
ST43-15U1-000; ST54-10U1-000; ST59-23U1-001.
Id. at 3.
See id. at Exhibit A. In response to a request to provide a list of
non-DTV-compliant receivers shipped in interstate commerce during this
period, Hannspree provided data showing its shipment of 5,518 units. Of
this number, 1,759 units were actually equipped with DTV tuners and an
additional 24 units were in fact exported rather than shipped interstate;
thus, Hannspree shipped in interstate commerce 3,735 receivers that did
not contain DTV tuners. Id.
Id. at Exhibit B.
Id at 2; see generally 47 C.F.R. S: 15.117(k) (requiring responsible
parties to post Consumer Alert in close proximity to a television receiver
that is not capable of receiving, decoding, and tuning digital signals).
LOI Response at 2.
Section 312(f)(1) of the Act defines "willful" as "the conscious and
deliberate commission or omission of [any] act, irrespective of any intent
to violate" the law. 47 U.S.C. S: 312(f)(1). The legislative history of
Section 312(f)(1) of the Act clarifies that this definition of willful
applies to both Sections 312 and 503(b) of the Act, H.R. Rep. No. 97-765,
97th Cong. 2d Sess. 51 (1982), and the Commission has so interpreted the
term in the Section 503(b) context. See Southern California Broadcasting
Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388 (1991), recon.
denied, 7 FCC Rcd 3454 (1992) ("Southern California").
Section 312(f)(2) of the Act, which also applies to forfeitures assessed
pursuant to Section 503(b) of the Act, provides that "[t]he term
`repeated,'... means the commission or omission of such act more than once
or, if such commission or omission is continuous, for more than one day."
47 U.S.C. S: 312(f)(2). See Callais Cablevision, Inc., Notice of Apparent
Liability for Forfeiture, 16 FCC Rcd 1359, 1362 (2001); Southern
California, 6 FCC Rcd at 4388.
47 C.F.R. S: 15.117(i)(1)(iii).
See Second Periodic Review of the Commission's Rules and Policies
Affecting the Conversion To Digital Television, Second Report and Order,
22 FCC Rcd 8776, 8783-84 P: 14 (2007) (implementing point of sale
disclosure requirements for analog-only television receivers) ("Second DTV
Periodic Report and Order").
Id. at 8783.
See DTV Tuner Second Report and Order, 20 FCC Rcd at 18613-14.
See supra note 9.
47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(1).
47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).
See, e.g., SBC Communications, 17 FCC Rcd at 7591.
47 U.S.C. S: 503(b)(2)(D). The Commission has amended Section 1.80(b)(3)
of the Rules, 47 C.F.R. S: 1.80(b)(3), three times to increase the maximum
forfeiture amounts, in accordance with the inflation adjustment
requirements contained in the Debt Collection Improvement Act of 1996, 28
U.S.C. S: 2461. See Amendment of Section 1.80 of the Commission's Rules
and Adjustment of Forfeiture Maxima to Reflect Inflation, 23 FCC Rcd 9845
(2008) (adjusting the maximum statutory amounts from $11,000/$97,500 to
$16,000/$112,500); Amendment of Section 1.80 of the Commission's Rules and
Adjustment of Forfeiture Maxima to Reflect Inflation, Order, 19 FCC Rcd
10945 (2004) (adjusting the maximum statutory amounts from $11,000/$87,500
to $11,000/$97,500); Amendment of Section 1.80 of the Commission's Rules
and Adjustment of Forfeiture Maxima to Reflect Inflation, Order, 15 FCC
Rcd 18221 (2000) (adjusting the maximum statutory amounts from
$10,000/$75,000 to $11,000/$87,500). The most recent inflation adjustment
is effective September 2, 2008. See 73 Fed. Reg. 44663-5.
47 U.S.C. S: 503(b)(2)(E). See also 47 C.F.R. S: 1.80(b)(4), Note to
paragraph (b)(4): Section II. Adjustment Criteria for Section 503
Forfeitures.
See 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, 17115 (1997), recon. denied, 15 FCC Rcd 303
(1999) ("Forfeiture Policy Statement").
See, e.g., InPhonic, Inc., Order of Forfeiture and Further Notice of
Apparent Liability, 22 FCC Rcd 8689, 8699 (2007); Globcom, Inc. d/b/a
Globcom Global Commun., Order of Forfeiture, 21 FCC Rcd 4710, 4723-24
(2006).
See DTV Tuner Report and Order, 20 FCC Rcd at 11198; DTV Tuner Second
Report and Order, 20 FCC Rcd at 18609.
Syntax-Brillian Corporation, Notice of Apparent Liability for Forfeiture,
22 FCC Rcd 10530, 10535-36 (2007), forfeiture ordered, 23 FCC Rcd 6323
(2008) ("Syntax-Brillian NAL"); Regent U.S.A., Inc., Notice of Apparent
Liability for Forfeiture, 22 FCC Rcd 10520, 10525 (2007) (forfeiture paid)
("Regent NAL").
See Syntax-Brillian NAL, 22 FCC Rcd at 10535; Regent NAL, 22 FCC Rcd at
10525-26.
See Invision Industries, Inc., Notice of Apparent Liability for Forfeiture
and Order, FCC 08-187 (rel. August 18, 2008); Precor, Inc., Notice of
Apparent Liability for Forfeiture, 23 FCC Rcd 6361, 6367 (2008)
(forfeiture paid) ("Precor NAL"); Syntax-Brillian NAL, 22 FCC Rcd at
10536; Regent NAL, 22 FCC Rcd at 10525.
47 U.S.C. S: 503(b)(6)(B).
See 47 U.S.C. S: 503(b)(2)(D), 47 C.F.R. S: 1.80(b)(4); see also Behringer
USA, Inc., Notice of Apparent Liability, 21 FCC Rcd 1820, 1825(2006),
forfeiture ordered, Forfeiture Order, 22 FCC Rcd. 1051 (2007).
Federal Communications Commission DA 08-1987
6
Federal Communications Commission DA 08-1987