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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                          )                               
                                                          
                          )                               
                                                          
     In the Matter of     )   File Number EB-07-RK-002    
                                                          
     Target Corporation   )   NAL/Acct. No. 200732460002  
                                                          
     Minneapolis, MN      )   FRN 0004912705              
                                                          
                          )                               
                                                          
                          )                               


                  NOTICE OF APPARENT LIABILITY FOR FORFEITURE

   Adopted: April 9, 2008 Released: April 10, 2008

   By the Commission:

   I. INTRODUCTION

    1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
       that Target Corporation ("Target") apparently willfully and repeatedly
       violated Section 15.117(k)  of the Commission's Rules ("Rules") by
       failing to place the required Consumer Alert label immediately
       adjacent to and clearly associated with television receiving equipment
       that contains an analog broadcast television tuner but does not
       contain a digital broadcast television tuner (hereinafter "analog-only
       tuner") that it displayed or offered for sale or rent. We conclude,
       pursuant to Section 503(b) of the Communications Act of 1934, as
       amended ("Act"), that Target is apparently liable for a forfeiture in
       the amount of two hundred ninety-six thousand dollars  ($296,000).

   II. BACKGROUND

    2. Congress has established February 17, 2009 as the deadline for the end
       of analog transmissions for full power television stations. The
       Commission is statutorily obligated to promote the orderly transition
       to digital television, "a critical step in the evolution of broadcast
       television." As we stated previously, "[w]e are committed to ensuring
       the rapid completion of that transition in a way that delivers the
       greatest possible benefits to the viewing public." As part of that
       commitment and in light of the upcoming deadline, we recently
       announced that "it is necessary and appropriate to require retailers
       to provide consumers with information regarding this transition date
       at the point of sale." We reached this conclusion after determining
       that consumer electronics industry efforts had not adequately informed
       consumers how analog-only television equipment purchased now will
       function when the transition to digital broadcasting ends.

    3. To ensure that consumers do not inadvertently buy analog-only
       television equipment without understanding that such devices will not
       be capable of receiving off-the-air television reception of digital
       signals after analog broadcasting ends unless connected to a
       digital-to-analog converter or a digital subscription service, we
       adopted rules requiring anyone that sells, offers for sale, or rents
       television receiving equipment that does not contain a digital
       television ("DTV") tuner to display a Consumer Alert at the point of
       sale. This requirement also applies to the sale or rent of analog-only
       television receiving equipment via direct mail, catalog, or electronic
       means (e.g., the Internet). These requirements are contained in
       Section 15.117(k) of the Rules, which became effective on May 25,
       2007.

    4. Section 15.117(k)(3) of the Rules requires that the Consumer Alert
       contain the following language:


                                   CONSUMER ALERT                            
                                                                             
         This television receiver has only an analog broadcast tuner and     
         will require a converter box after February 17, 2009, to receive    
         over-the-air broadcasts with an antenna because of the Nation's     
         transition to digital broadcasting. Analog-only TVs should          
         continue to work as before with cable and satellite TV services,    
         gaming consoles, VCRs, DVD players, and similar products. For more  
         information, call the Federal Communications Commission at          
         1-888-225-5322 (TTY: 1-888-835-5322) or visit the Commission's      
         digital television website at: www.dtv.gov.                         


       The Consumer Alert must be in a size of type large enough to be clear,
       conspicuous and readily legible, consistent with the dimensions of the
       equipment and the label. The alert either must be printed on a
       transparent material and affixed to the screen, in a manner that is
       removable by the consumer and does not obscure the picture when
       displayed for sale, or displayed separately immediately adjacent to
       each television receiver offered for sale and clearly associated with
       the analog-only model to which it pertains. In the case of other
       analog-only video devices that do not include a display (e.g., VCRs,
       DVD players), the Consumer Alert must be in a prominent location on
       the device, such as on the top or front, or displayed separately
       immediately adjacent to and clearly associated with the analog-only
       model to which it pertains. To the extent that any persons display or
       offer for sale or rent via direct mail, catalog, or electronic means
       analog-only television receiving equipment, they must prominently
       display the Consumer Alert as part of all advertisements or
       descriptions of such television receiving equipment, in clear and
       conspicuous print, and in close proximity to any images or
       descriptions of such equipment.

         5. Immediately after the rule became effective, the Commission's
            Enforcement Bureau began inspecting hundreds of stores throughout
            the country, as well as dozens of popular retailer websites, and
            observed many models of analog-only television receiving
            equipment on display without the required Consumer Alert labels.
            On June 1, 2007, the Enforcement Bureau issued a Citation to
            Target for offering for sale television receiving equipment
            having an analog-only tuner without displaying the required
            Consumer Alert in close proximity. Between May 31 and June 11,
            2007, the Enforcement Bureau conducted inspections at numerous
            stores and, based on those inspections, issued additional 
            Citations to Target for violations at its stores and its website.
            After affording Target a reasonable opportunity to respond to the
            first Citation, agents from the Enforcement Bureau began
            inspecting numerous additional Target stores on June 12, 2007 in
            various states  and once again observed television receiving
            equipment with analog-only tuners on display without the required
            Consumer Alert labels in twenty-three Target stores.

         6. Under Section 503(b)(1) 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. 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. The legislative history to Section 312(f)(1) of the Act
            clarifies that this definition of willful applies to both
            Sections 312 and 503(b) of the Act and the Commission has so
            interpreted the term in imposing forfeitures pursuant to Section
            503(b). The Commission may also assess a forfeiture for
            violations that are merely repeated, and not willful.  "Repeated"
            means that the act was committed or omitted more than once, or
            lasts more than one day. To impose such a forfeiture penalty, the
            Commission must issue a notice of apparent liability and the
            person against whom the 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. As we set forth below, we
            conclude under this standard that Target is apparently liable for
            forfeiture for its apparent willful and repeated violations of
            Section 15.117(k) of the Commission's rules.

        III. DISCUSSION

         7. Based on the evidence before us, we find that Target  apparently
            willfully and repeatedly violated Section 15.117(k) of the Rules
            by failing to display conspicuously and in close proximity to
            equipment with an analog-only tuner, in clear and conspicuous
            print, the required Consumer Alert label. Specifically, as
            detailed in Attachment C,  agents and investigators from the
            Enforcement Bureau observed a number of different models of
            television receiving equipment having only an analog-only tuner
            on display in twenty-three Target stores without the required
            Consumer Alert labels. Target previously received fourteen
            Citations for this same type of conduct prior to the agents'
            inspections.

         8. Under Section 503(b)(2)(D) of the Act, we 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 must 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."

         9. The Commission's Forfeiture Policy Statement and Section 1.80 of
            the Rules do not establish a specific base forfeiture for
            violation of the analog-only tuner labeling requirements. In
            adopting the Consumer Alert labeling requirements, the Commission
            stated that "[a]ccurate communication of this impending change is
            a highly material disclosure for consumers contemplating the
            purchase of a television."  We also noted that it is a matter of
            public safety for consumers who rely on analog-only televisions
            to obtain critical emergency information.

        10. Similar issues arose regarding labeling requirements for wireless
            hearing aid-compatible handsets. In those cases, the Enforcement
            Bureau established a base forfeiture amount of $8,000 per handset
            model that failed to comply with the labeling requirements. The
            labeling requirements for wireless hearing aid-compatible
            handsets and the analog-only tuner labeling requirements both
            serve the important goal of ensuring that consumers have access
            to necessary information. In light of the similarities in these
            labeling requirements, we conclude that a $8,000 base forfeiture
            amount per unlabeled model or device in each store where Bureau
            agents and investigators observed a violation is appropriate for
            apparent violations of Section 15.117(k).

        11. We find that, beginning on June 19, 2007, as detailed in
            Attachment C, even after receiving the Citations warning of
            violations in its stores across the country, Target displayed
            numerous different models of equipment with an analog-only tuner
            in twenty-three stores without the required Consumer Alert label.
            As a result, Target  continued to market television receiving
            equipment to consumers without adequately warning that the
            equipment contained an analog-only television receiver. Those
            consumers may not learn of their equipment's limitations until
            the analog-only devices cease to receive over-the-air television
            signals, long after any period for returning the equipment has
            expired. This scenario is precisely the outcome that our rule was
            intended to prevent. Applying the analysis set forth above to the
            facts of this case, we conclude that Target  is apparently liable
            for a $296,000 base forfeiture.

        IV. ORDERING CLAUSES

        12. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of
            the Communications Act of 1934, as amended, and Section 1.80 of
            the Commission's Rules, Target Corporation is hereby NOTIFIED of
            this APPARENT LIABILITY FOR A FORFEITURE in the amount of two
            hundred ninety-six thousand dollars  ($296,000) for violations of
            Section 15.117(k) of the Rules.

        13. 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 for Forfeiture, Target Corporation
            SHALL PAY the full amount of the proposed forfeiture or SHALL
            FILE a written statement seeking reduction or cancellation of the
            proposed forfeiture.

        14. 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[s] 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.

        15. The response, if any, must be mailed to Federal Communications
            Commission, Enforcement Bureau, and must include the NAL/Acct.
            No. referenced in the caption.

        16. 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.

        17. IT IS FURTHER ORDERED that a copy of this Notice of Apparent
            Liability for Forfeiture shall be sent by Certified Mail, Return
            Receipt Requested, and regular mail, to Target Corporation  at 
            its address of record and its counsel, Robert Schwartz,
            Constantine Cannon LLP, 1627 Eye Street NW, Washington, DC 20006.

       FEDERAL COMMUNICATIONS COMMISSION

       Marlene H. Dortch

       Secretary

                                  Attachment A

                           Citations Issued to Target


              Store #-                                      
                               Citation No.   Release Date  
              Location                                      

              Miami, FL        C20073260005     5/31/07     

         San Diego, CA 92111   C20073294007     5/31/07     

          Houston, TX 77070    C20073254001      6/1/07     

              Tampa, FL        C20073270003      6/1/07     

           Chesapeake, VA      C20073264002      6/1/07     

            Mesquite, TX       C20073250007      6/1/07     

            Lakewood, CA       C20073290019      6/1/07     

            Lakewood, CO       C20073280006      6/4/07     

          Vernon Hills, IL     C20073232006      6/5/07     

            Cupertino, CA      C20073296008      6/5/07     

              Allen, TX        C2007325009       6/6/07     

            Broadview, IL      C20073232008      6/6/07     

             Garland, TX       C20073250012      6/6/07     

           North Wales, PA     C20073240013      6/6/07     

             Laurel, MD        C20073234006      6/6/07     

            Westbury, NY       C20073238014      6/6/07     

            Langhorne, PA      C20073240014      6/7/07     

         San Diego, CA 92108   C20073294013      6/7/07     

          Houston, TX 77084    C20073254012      6/7/07     

          Mays Landing, NJ     C20073240016     6/11/07     

           Burlington, NJ      C20073240017     6/11/07     

             Humble, TX        C20073254013     6/11/07     

             Canton, MI        C20073236009     6/12/07     

              Plano, TX        C20073250014     6/12/07     

           Willowbrook, IL     C20073232010     6/13/07     

            Brooklyn, NY       C20073238027     6/14/07     

             Hayward, CA       C20073296019     6/15/07     

            Abington, PA       C20073240031     6/28/07     

               Webpage          DA 07-2351       6/6/07     


                                  Attachment B

                     Models Erroneously Listed in Citations


         Citation No.   Manufacturer Model No.    

         C20073290019   Sony model SLV-D380P      

         C20073270003   TruTech model CR270TT8    

         C20073232006   TruTech model CR270TT8    

         C20073232006   TruTech model CR130TT8    

         C20073232008   TruTech model CR270TT8    

         C20073232008   TruTech model CR130TT8    

         C20073238014   TruTech model CR270TT8    

         C20073238014   TruTech model CR130TT8    

         C20073238014   TruTech model PVS31170S1  

         C20073240017   TruTech model CR270TT8    

         C20073240017   TruTech model CR130TT8    

         C20073236009   TruTech model CR270TT8    

         C20073236009   TruTech model CR130TT8    

         C20073238027   TruTech model CR270TT8    

         C20073238027   TruTech model CR130TT8    

         C20073238027   TruTech model PVS31170S1  

         C20073260005   TruTech model CR130TT8    

         C2007325009    TruTech model CR130TT8    

         C20073234006   TruTech model CR130TT8    

         C20073294007   TruTech model PVS31170S1  

         C20073294013   TruTech model CR270TT8    

         C20073294013   TruTech model PVS31170S1  

         C20073264002   TruTech model ZV450TT8    

         C20073264002   TruTech model CR130TT8    


                                  Attachment C

         1. 6/19/07, Target Store # 1031, Springfield, MO.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Magnavox       TV       26MF605W   $8,000             

         Magnavox       TV       32MF605    $8,000             

         Trutech        TV/DVD   KLV3112    $8,000             

                                 Subtotal   $24,000            


         2. 6/19/07, Target Store # 774, Joplin, MO.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Magnavox       TV       15MF605T   $8,000             

         Magnavox       TV       26MF605W   $8,000             

                                 Subtotal   $16,000            


         3. 6/19/07, Target Store # 2006, Staten Island, NY.


         Manufacturer   Device   Model #       Forfeiture Amount  

         Magnavox       TV       20MF605T/17   $8,000             

         TruTech        TV/DVD   KLV3112       $8,000             

         TruTech        TV/DVD   PVS2119       $8,000             

         TruTech        TV/DVD   KLV3170       $8,000             

                                 Subtotal      $32,000            


         4. 6/19/07, Target Store # 836, Glendale Heights, IL.


         Manufacturer   Device             Model #    Forfeiture Amount  

         Philips        DVD Player & VCR   DVP3050V   $8,000             

                                           Subtotal   $8,000             


         5. 6/19/07, Target Store # 1430, Richardson, TX.


         Manufacturer   Device       Model #    Forfeiture Amount  

         Magnavox       Television   26MF605W   $8,000             

                                     Subtotal   $8,000             


         6. 6/20/07, Target Store # 1763, Frisco, TX.


         Manufacturer   Device       Model #    Forfeiture Amount  

         Magnavox       Television   32MF605    $8,000             

                                     Subtotal   $8,000             


         7. 6/20/07, Target Store # 1975, Houston, TX.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Trutech        TV/DVD   KLV3112    $8,000             

         Trutech        TV/DVD   KLV3170    $8,000             

                                 Subtotal   $16,000            


         8. 6/21/07, Target Store # 1363, Reno, NV.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Memorex        DVD      MVDR2100   $8,000             

                                 Subtotal   $8,000             


         9. 6/22/07, Target Store # 1502, Roseville, CA.


         Manufacturer   Device       Model #    Forfeiture Amount  

         Memorex        DVDR         MVDR2100   $8,000             

         Memorex        TV/VCR/DVD   MVDT2002   $8,000             

         Philips        DVD/VCR      DVP3050V   $8,000             

                                     Subtotal   $24,000            


        10. 6/25/07, Target Store # 0055, Dallas, TX.


         Manufacturer   Device   Model #        Forfeiture Amount  

         Magnavox       TV       26MF605/231D   $8,000             

         Magnavox       TV       32MF605/231D   $8,000             

                                 Subtotal       $16,000            


        11. 7/2/07, Target Store # 64, Boulder, CO.


         Manufacturer   Device         Model #      Forfeiture Amount  

         Memorex        DVD Recorder   MVDR2100/2   $8,000             

         Memorex        DVD Recorder   MVDR2102     $8,000             

                                       Subtotal     $16,000            


        12. 7/3/07, Target Store # 1004, Bowie, MD.


         Manufacturer   Device   Model #     Forfeiture Amount  

         Memorex        20" TV   MT2012/24   $8,000             

                                 Subtotal    $8,000             


        13. 7/9/07, Target Store # 1775, Dallas, TX.


         Manufacturer   Device       Model #       Forfeiture Amount  

         Magnavox       Television   26MF605W/17   $8,000             

         Magnavox       Television   32MF605W/17   $8,000             

         TruTech        TV/DVD       PVS2119       $8,000             

                                     Subtotal      $24,000            


        14. 11/28/07, Target Store # 1840, Kansas City, MO.


         Manufacturer   Device          Model #    Forfeiture Amount  

         Phillips       DVD/VCR Combo   DVP3050V   $8,000             

                                        Subtotal   $8,000             


        15. 11/29/07, Target Store # 1201, Independence, MO.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Memorex        TV       MT2012     $8,000             

                                 Subtotal   $8,000             


        16. 12/5/07, Target Store # 1842, Overland Park, KS.


         Manufacturer   Device          Model #    Forfeiture Amount  

         Philips        DVD/VCR Combo   DVP3050V   $8,000             

                                        Subtotal   $8,000             


        17. 12/18/07, Target Store # 2043, Overland Park, KS.


         Manufacturer   Device          Model #    Forfeiture Amount  

         Philips        DVD/VCR Combo   DVP3050V   $8,000             

                                        Subtotal   $8,000             


        18. 12/18/07, Target Store # 1756, Olathe, KS.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Memorex        TV       MT2012     $8,000             

                                 Subtotal   $8,000             


        19. 12/18/07, Target Store # 1543, Olathe, KS.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Memorex        TV       MT2012     $8,000             

                                 Subtotal   $8,000             


        20. 1/22/08, Target Store # 0296, Poway, CA.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Memorex        TV/DVD   MT2024     $8,000             

                                 Subtotal   $8,000             


        21. 1/22/08, Target Store # 1775, Dallas, TX.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Memorex        TV       MT2012     $8,000             

                                 Subtotal   $8,000             


        22. 1/22/08, Target Store # 0360, Eagen, MN.


         Manufacturer   Device   Model #    Forfeiture Amount  

         Trutech        TV/DVD   KLV3112    $8,000             

         Trutech        TV/DVD   KLV3170    $8,000             

                                 Subtotal   $16,000            


        23. 2/25/08, Target Store # 1416, Springfield, VA.


         Manufacturer   Device   Model #      Forfeiture Amount  

         Memorex        TV       MT2024/25D   $8,000             

                                 Subtotal     $8,000             


       TOTAL PROPOSED FORFEITURE: $296,000.00

       47 C.F.R. S: 15.117(k).

       47 U.S.C. S: 503(b).

       2002 Biennial Regulatory Review, Report and Order and Notice of
       Proposed Rulemaking, 18 FCC Rcd 13620, 13825 P: 532 (2003).

       Id.

       Second Periodic Review of the Commission's Rules and Policies
       Affecting the Conversion To Digital Television, Second Report and
       Order, 22 FCC Rcd 8776 at P: 1 (2007) ("Second DTV Periodic Report and
       Order").

       Id. at P: 10.

       Second DTV Periodic Report and Order at P: 14. See 47 C.F.R. S:
       15.117(k). In the Second DTV Periodic Report and Order, the Commission
       defined "point of sale" as the "place where televisions are displayed
       for consumers prior to purchase." See Second DTV Periodic Report and
       Order at n.29.

       Second Periodic Review in the Commission's Rules and Policies
       Affecting the Conversion to Digital Television, 72 Fed. Reg. 28894-01
       (May 23, 2007).

       47 C.F.R. S: 15.117(k)(1).

       Id.

       47 C.F.R. S: 15.117(k)(2).

       Target Corporation, Citation No. C20073254001, (Enf. Bur. Houston
       Office, rel. June 1, 2007).

       See Attachment A for a list of the citations issued to Target 
       (collectively "Citations"). In preparing the Citations, Enforcement
       Bureau staff relied on publicly available information, including
       retailer websites, to identify the television receiving equipment with
       analog-only tuners.  Subsequently, Enforcement Bureau staff determined
       that several Citations referred, in whole or in part, to erroneously
       identified equipment models. In light of this evidence, we hereby
       cancel the relevant portions of the citations listed in Attachment B
       with respect to those models.

       On June 18, 2007, Target responded to the first Citation. See Letter
       from Robert Schwartz, counsel for Target, Constantine Cannon LLO to
       Kris Monteith, Chief, Enforcement Bureau, dated June 18, 2007 
       ("Citation Response"). Target also filed a response to a Citation
       issued by the Dallas Office of the Enforcement Bureau. See Letter from
       Lisa Bushland, Store #0235 Team Leader to James Wells, District
       Director, Dallas Office, Enforcement Bureau, dated June 11, 2007.

       See Attachment C for a listing of the stores visited and the models
       observed at each store.  Enforcement Bureau staff determined that
       these models had analog-only tuners by consulting the manufacturer's
       product manuals or, if such were unavailable, the models' technical
       specifications from Target's website.

       47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(2).

       47 U.S.C. S: 312(f)(1).

       H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).

       See, e.g., Application for Review of Southern California Broadcasting
       Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388 (1991)
       ("Southern California Broadcasting Co.").

       See, e.g., Callais Cablevision, Inc., Grand Isle, Louisiana, Notice of
       Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359, 1362, P:
       10 (2001) ("Callais Cablevision") (issuing a Notice of Apparent
       Liability for, inter alia, a cable television operator's repeated
       signal leakage).

       Southern California Broadcasting Co., 6 FCC Rcd at 4388, P: 5; Callais
       Cablevision, Inc., 16 FCC Rcd at 1362, P: 9.

       47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).

       See, e.g., SBC Communications, Inc.,  Forfeiture Order, 17 FCC Rcd
       7589, 7591, P: 4 (2002) (forfeiture paid).

       Attachment C lists the date(s) of the Enforcement Bureau inspections,
       the analog-only models identified in violation of Section 15.117(k),
       as well as the Target store(s) involved.

       Section 503(b)(5) states that no forfeiture liability shall be
       determined against any person who does not hold a license, permit,
       certificate, or other authorization issued by the Commission unless,
       prior to issuance of any Notice of Apparent Liability, such person is
       "(A) sent 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 which is nearest
       to such person's place of residence; and (C) subsequently engages in
       conduct of the type described in such citation." 47 U.S.C. S:
       503(b)(5). The violations discussed in this NAL are subject to
       forfeiture because we have issued the Citations and afforded Target an
       opportunity for a personal interview or to submit a written response.
       See Attachments A and B for 14 Citations cancelled in whole or in
       part. To the extent that the television receiving models involved in
       this NAL differ from those listed in the Citations, no additional
       citations are necessary because the more recent apparent violations
       are "conduct of the type described" in the earlier Citations -
       violations of Section 15.117(k). See HighTech CB Shop, Forfeiture
       Order, 20 FCC Rcd 12514, 12516 P: 9 (Enf. Bur. South Central Region
       2005), recon. denied, 20 FCC Rcd 19269 (Enf. Bur. 2005). In any event,
       the requirements of Section 503(b)(5) do not apply to Target, which is
       a Commission licensee and therefore subject to forfeiture under
       Section 503(b)(2) of the Act without first receiving notice via a
       citation. See Call Sign WPOM307.

       47 U.S.C. S: 503(b)(2)(D). The Commission twice amended Section
       1.80(b)(3) of the Rules, 47 C.F.R. S: 1.80(b)(3), 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, Order, 15 FCC Rcd 18221 (2000) (adjusting the maximum
       statutory amounts from $10,000/$75,000 to $11,000/$87,500); 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).

       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").

       Second DTV Periodic Report and Order at P: 12.

       Id. See also 47 C.F.R. S:S: 11.1-11.61, 79.2.

       See Pine Telephone Inc., Notice of Apparent Liability, 22 FCC Rcd
       9205, 9210 (Enf. Bur., Spectrum Enf. Div. 2007) subsequent history
       omitted; IT&E Overseas, Inc., Notice of Apparent Liability, 22 FCC Rcd
       7660, 7665 (Enf. Bur., Spectrum Enf. Div. 2007).

       We caution Target  and other retailers that future cases involving
       repeat offenders may result in the imposition of forfeitures on a
       continuing violation basis.

       "After the transition, absent a label requirement, even cable and
       satellite subscribers might be surprised to find that they cannot
       receive television broadcasts over-the-air on an analog-only
       television purchased today if they choose to discontinue subscription
       service or their cable or satellite service is terminated by disaster,
       service disruption, or for non-payment of their bills." Second DTV
       Periodic Report and Order at P: 12.

       See Attachment C regarding the calculation of the total proposed
       forfeiture amounts.

       47 U.S.C. S: 503(b), 47 C.F.R. S:S: 1.80, 15.117(k).

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       Federal Communications Commission FCC 08-108