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Before the
Federal Communications Commission
Washington, D.C. 20554
)
) File No. EB-09-SE-066
In the Matter of
) NAL/Acct. No. 201032100030
CruiseEmail
) FRN # 0006501092
)
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: June 9, 2010 Released: June 11, 2010
By the Chief, Spectrum Enforcement Division, Enforcement Bureau:
I. introduction
1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
CruiseEmail, licensee of public coast stations KDS (Olympia,
Washington) ("KDS"), WGM (Fort Lauderdale, Florida) ("WGM"), and WHX
(Pocomoke, Maryland) ("WHX"), apparently liable for a forfeiture in
the amount of fifteen thousand dollars ($15,000) for willful and
repeated violations of Section 301 of the Communications Act of 1934,
as amended ("Act"), and Section 1.903(a) of the Commission's Rules
("Rules"). The noted apparent violations involve CruiseEmail's
operation of stations KDS, WGM, and WHX at locations other than their
licensed locations without prior Commission authorization.
II. background
2. On April 23, 2008, the Mobility Division of the Wireless
Telecommunications Bureau ("Mobility Division") directed CruiseEmail to
provide information regarding the construction and operational status of
stations KDS, WGM, and WHX. In its May 20, 2008 response to the Mobility
Division, CruiseEmail indicated all three stations were operating at
locations other than their licensed locations. Accordingly, the Mobility
Division referred this matter to the Spectrum Enforcement Division
("Division") of the Enforcement Bureau for further investigation, and the
Division sent CruiseEmail a letter of inquiry ("LOI") on August 12, 2009.
3. In its September 20, 2009 Response to the LOI ("Response"), CruiseEmail
admits to operating stations KDS, WGM, and WHX at locations other than
their licensed locations without first obtaining a modification of the
stations' licenses. CruiseEmail states that in approximately 2004, it
moved station KDS from its licensed location in Everett, Washington, to
Olympia, Washington after being informed that the station manager had
"changed his full time job, and moved to another state." CruiseEmail
states that in approximately 2005, it moved station WGM from its licensed
location in Lake Placid, Florida, to Fort Lauderdale, Florida after the
Lake Placid station was destroyed by three major hurricanes, including
hurricanes Donna and Edna. CruiseEmail also states that "a few years"
after it began operating station WHX, it moved the station from its
licensed location in Seabrook, Maryland, to Pocomoke, Maryland "due to the
station manager changing full time jobs, and not [being] content as to the
noise level in that area [of Seabrook]." CruiseEmail states that at the
time of the move, CruiseEmail "did re-file" and that on January 25, 2006,
it renewed its license for station WHX but that CruiseEmail "noticed that
the address did not change on the new license." CruiseEmail states that
since it first built stations KDS and WHX, CruiseEmail has continuously
operated these stations. CruiseEmail states further that it took station
WGM off-the-air for approximately 27 hours to rebuild the station in Fort
Lauderdale, Florida, but has continuously operated the station since the
relocation.
4. On July 1, 2009, CruiseEmail requested modification of its license to
operate station WGM at its new location, and on August 25, 2009, the
Wireless Telecommunications Bureau granted CruiseEmail's request. On July
2, 2009, CruiseEmail requested modifications of its licenses to operate
stations KDS and WHX at their new locations, and those requests were
granted by the Wireless Telecommunications Bureau on August 12, 2009, and
September 9, 2009 respectively.
III. discussion
5. Section 301 of the Act and Section 1.903(a) of the Rules prohibit the
use or operation of any apparatus for the transmission of energy or
communications or signals by a wireless radio station except under, and in
accordance with, a Commission granted authorization. Under Section
1.903(a) of the Rules, licensees must request a modification of their
license before changing the location where the station is operated.
CruiseEmail admits to operating station KDS at an unauthorized location
since approximately 2004, and station WGM at an unauthorized location
since approximately 2005. With respect to station WHX, CruiseEmail admits
to operating at an unauthorized location "a few years" before its renewal
application was granted on January 25, 2006. Although CruiseEmail
indicated that it "noticed" that its renewal did not include information
regarding the station's relocation to Pocomoke, Maryland, CruiseEmail's
application for renewal did not disclose the relocation of the station or
the station's new address, and no modification request for the station was
filed at that time. Indeed, CruiseEmail did not request modification of
its license to operate station WGM at its new location until July 1, 2009;
and did not request modifications of its licenses to operate stations KDS
and WHX at their new locations until July 2, 2009. The Wireless
Telecommunications Bureau granted CruiseEmail's modification request for
the relocation of station KDS on August 12, 2009, for the relocation of
WGM on August 25, 2009, and for the relocation of WHX on September 9,
2009. Based on this information, we find CruiseEmail apparently liable for
its willful and repeated violations of Section 301 of the Act and Section
1.903(a) of the Rules by operating stations KDS, WHX, and WGM at new
locations prior to obtaining authorization for such operation.
6. 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 Rule. As set forth below, we conclude under this standard that
CruiseEmail is apparently liable for a forfeiture in the amount of $15,000
for its apparent willful and repeated violations of Section 301 of the Act
and Section 1.903(a) of the Rules.
7. Under Section 503(b)(2)(B) of the Act, we are authorized to assess
against common carriers a forfeiture penalty of $150,000 for each
violation, or for each day of a continuing violation, up to a total of
$1,500,000 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." Section
503(b)(6) of the Act bars the Commission from proposing a forfeiture for
violations that occurred more than a year prior to the issuance of an NAL.
Section 503(b)(6) does not, however, bar the Commission from assessing
whether CruiseEmail's conduct prior to that time period apparently
violated the provisions of the Act and Rules and from considering such
conduct in determining the appropriate forfeiture amount for violations
that occurred within the one-year statutory period. Thus, while we may
consider the fact that CruiseEmail's conduct has continued for several
years, the forfeiture amount we propose herein relates only to
CruiseEmail's apparent violations occurring within the past year.
8. The Commission's Forfeiture Policy Statement and Amendment of Section
1.80 of the Rules to Incorporate the Forfeiture Guidelines ("Forfeiture
Policy Statement") and Section 1.80 of the Rules, set the base forfeiture
amount for operation at an unauthorized location at $4,000. Accordingly,
we propose a total base forfeiture of $12,000 ($4,000 x 3 stations)
against CruiseEmail for its operation of stations KDS, WGM, and WHX at
unauthorized locations in apparent willful and repeated violations of
Section 301 of the Act and Section 1.903(a) of the Rules. This amount,
however, is subject to upward adjustment based on the extended duration of
each station's operation at an unauthorized location; specifically,
CruiseEmail operated station KDS at an unauthorized location for
approximately five years, station WGM at an unauthorized location for
approximately four years, and station WHX at an unauthorized location for
an estimated "few years." In the absence of any recent precedent relating
to extended operations at unauthorized locations, we turn to analogous
precedent relating to unauthorized operations. Consistent with this
precedent, we upwardly adjust the base forfeiture by $1000 per violation,
i.e., from $4000 to $5000. Thus, we propose a total forfeiture of $15,000
($5,000 x 3 stations).
IV. ORDERING CLAUSES
9. Accordingly, IT IS ORDERED that, pursuant to pursuant to Section 503(b)
of the Act and Sections 0.111, 0.311, and 1.80 of the Rules, CruiseEmail
IS hereby NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE in the
amount of fifteen thousand dollars ($15,000) for willfully and repeatedly
violating Section 301 of the Act and Section 1.903(a) of the Rules.
10. 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 and Order, CruiseEmail SHALL PAY the full amount
of the proposed forfeiture or SHALL FILE a written statement seeking
reduction or cancellation of the proposed forfeiture.
11. 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. CruiseEmail will also send
electronic notification to Ricardo Durham at Ricardo.Durham@fcc.gov and
Nissa Laughner at Nissa.Laughner@fcc.gov on the date said payment is made.
12. The written statement seeking reduction or cancellation of the
proposed forfeiture, if any, must include a detailed factual statement
supported by appropriate documentation and affidavits pursuant to Sections
1.80(f)(3) and 1.16 of the Rules. The written statement 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 statement should also be e-mailed to Ricardo Durham at
Ricardo.Durham@fcc.gov and to Nissa Laughner at Nissa.Laughner@fcc.gov.
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;
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. 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 Dr. John Gregory, Chief Executive Officer,
CruiseEmail, 1440 Coral Ridge Dr., Suite 160, Coral Springs, Florida
33071.
FEDERAL COMMUNICATIONS COMMISSION
Kathryn S. Berthot
Chief, Spectrum Enforcement Division
Enforcement Bureau
47 U.S.C. S: 301; 47 C.F.R. S: 1.903(a).
See Letter from Scot Stone, Deputy Chief, Mobility Division, Wireless
Telecommunications Bureau, Federal Communications Commission, to Dr. John
Gregory, Chief Executive Officer, CruiseEmail (April 23, 2008). See also
47 U.S.C. S: 308(b).
See Letter from Dr. John Gregory, Chief Executive Officer, CruiseEmail, to
Scot Stone, Deputy Chief, Mobility Division, Wireless Telecommunications
Bureau, Federal Communications Commission (May 20, 2008) ("Response to the
Mobility Division").
See Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
Enforcement Bureau, Federal Communications Commission, to Dr. John
Gregory, Chief Executive Officer, CruiseEmail (August 12, 2009).
See Letter from Dr. John Gregory, Chief Executive Officer, CruiseEmail, to
Kathryn S. Berthot, Chief, Spectrum Enforcement Division, Enforcement
Bureau, Federal Communications Commission (September 20, 2009).
See Response at 1 (stating that the station "stayed active for about two
years" at its licensed location). See also Response to Mobility Division
at 1 (stating that the station became operational in January of 2002, and
was operated at its licensed location for two and a half years).
See Response at 1. See also Modification Request for Station KDS, File No.
0003890798 (filed July 2, 2009; granted August 12, 2009). CruiseEmail
moved station KDS from its authorized location at 1715 McDougall Avenue,
Everett, Washington (47-59-39.3 N, 122-12-2.5 W) to 10216 35th Lane,
Olympia, Washington (47-01-48.0 N, 122-59-23.0 W).
See Response at 1-2 (stating that CruiseEmail operated station WGM at its
licensed location until hurricanes Donna, Edna, and Wilma destroyed its
facilities three to four years ago). See also Modification Request for
Station WGM, File No. 0003889330 (filed July 1, 2009; granted August 25,
2009). CruiseEmail moved station WGM from its authorized location at 21
Silk Oak St., Lake Placid, Florida (27-50-00.0 N, 080-31-00.0 W) to 1069
NW 53 St., Ft. Lauderdale, Florida (26-18-00.0 N, 080-14-00.0 W). We note
that there were no hurricanes named Donna and Edna in 2005. The 2005
Hurricane Season in Florida included the following major hurricanes:
Dennis, Emily, Katrina, Rita, and Wilma. With storms named Dennis and
Emily, there would not, under current naming conventions, also have been
storms named Donna and Edna. See Worldwide Tropical Cyclone Names,
available at http://www.nhc.noaa.gov/aboutnames.shtml (last accessed, May
26, 2010). Moreover, for the purpose of identifying hurricanes in the
Atlantic Ocean, Caribbean Sea, and the Gulf of Mexico, the name Donna was
retired in 1960, and the name Edna was retired in 1968. See Retired
Hurricane Names since 1954, available at
http://www.nhc.noaa.gov/retirednames.shtml (last accessed, May 26, 2010).
See Response at 1. See also Modification Request for Station WHX, File No.
0003890009 (filed July 2, 2009; granted September 9, 2009). CruiseEmail
moved station WHX from its authorized location at 9303 Calnada Street,
Seabrook, Maryland (38-57-51.4 N, 076-50-44.9 W) to 2350 Bear Landing,
Pocomoke, Maryland (38-06-00.0 N, 075-54-00.0 W).
See Response at 1. See also Renewal Authorization for Station WHX, File
No. 0002400766 (filed December 6, 2005; granted January 25, 2006).
See Response at 1.
See id. at 2.
See Modification Request for Station WGM, File No. 0003889330 (filed July
1, 2009; granted August 25, 2009).
See Modification Request for Station KDS, File No. 0003890798 (filed July
2, 2009; granted August 12, 2009) and Modification Request for Station
WHX, File No. 0003890009 (filed July 2, 2009; granted September 9, 2009).
47 U.S.C. S: 301.
47 C.F.R. S: 1.903(a).
See Response at 1. See also Response to Mobility Division at 1.
See Response at 2.
See id. at 1.
See id.
See Renewal Application for Station WHX, File No. 0002400766 (filed
December 6, 2005; granted January 25, 2006).
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"); see also Telrite
Corporation, Notice of Apparent Liability for Forfeiture, 23 FCC Rcd 7231,
7237 (2008); Regent USA, Notice of Apparent Liability for Forfeiture, 22
FCC Rcd 10520, 10523 (2007); San Jose Navigation, Inc., Notice of Apparent
Liability for Forfeiture, 21 FCC Rcd 2873 (2006), forfeiture ordered,
Forfeiture Order, 22 FCC Rcd 1040 (2007), consent decree ordered, Order
and Consent Decree, 26 FCC Rcd 1494 (2010).
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),
forfeiture ordered, 17 FCC Rcd 22626 (2002); Southern California, 6 FCC
Rcd at 4388.
47 U.S.C. S: 503(b).
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 (2002) (forfeiture paid).
See 47 U.S.C. S: 503(b)(2)(B) (setting forth the statutory maximum
forfeiture for common carriers). 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, 9847 (2008) (adjusting the maximum statutory
amounts for common carriers from $130,000/$1,300,000 to
$150,000/$1,500,000); Amendment of Section 1.80 of the Commission's Rules
and Adjustment of Forfeiture Maxima to Reflect Inflation, Order, 19 FCC
Rcd 10945, 10947 (2004) (adjusting the maximum statutory amounts for
common carriers from $120,000/$1,200,000 to $130,000/ $1,300,000);
Amendment of Section 1.80 of the Commission's Rules and Adjustment of
Forfeiture Maxima to Reflect Inflation, Order, 15 FCC Rcd 18221, 18223
(2000) (adjusting the maximum statutory amounts for common carriers from
$100,000/$1,000,000 to $120,000/$1,200,000). The most recent inflation
adjustment took effect September 2, 2008, and applies to violations that
occur after that date. See 73 Fed. Reg. 44663-5. CruiseEmail's violations
of Section 301 of the Act and Section 1.903(a) of the Rules continued
until the Commission approved CruiseEmail's modification requests to
relocate stations KDS, WGM and WHX; thus, CruiseEmail is subject to the
higher forfeiture amount for these violations.
Public coast stations are classified as commercial mobile radio service
providers ("CMRS") and thus, are common carriers subject to the higher
statutory maximum forfeiture amounts set forth in Section 503(b)(2)(B) of
the Act and Section 1.80(b) of the Rules. See Amendment of the
Commission's Rules Concerning Maritime Services, Second Report and Order
and Second Further Notice of Proposed Rule Making, 12 FCC Rcd 16949, 17011
(1997) (citing Implementation of Sections 3(n) and 332 of the
Communications Act - Regulatory Treatment of Mobile Services, Second
Report and Order, 9 FCC Rcd 1411, 1448 (1994)). The Commission has
addressed concerns regarding the business size of small CMRS providers by
noting that forfeitures are assessed not on the basis of the service but
on the basis of the violation. See Forfeiture Policy Statement and
Amendment of Section 1.80(b) of the Rules to Incorporate the Forfeiture
Guidelines, Report and Order, 12 FCC Rcd 17087, 17121 (1997) ("Forfeiture
Policy Statement"), recon. denied, Memorandum Opinion and Order, 15 FCC
Rcd 303 (1999).
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.
47 U.S.C. S: 503(b)(6).
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 for Forfeiture and Order, 21 FCC
Rcd 1820, 1825 (2006), forfeiture ordered, Forfeiture Order, 22 FCC Rcd
10451 (2007); Globcom, Inc. d/b/a Globcom Global Communications, Notice of
Apparent Liability for Forfeiture, 18 FCC Rcd 19893, 19903 (2003),
forfeiture ordered, Forfeiture Order, 21 FCC Rcd 4710 (2006); Roadrunner
Transportation, Inc., Forfeiture Order, 15 FCC Rcd 9669, 9671-72 (2000);
Cate Communications Corp., Memorandum Opinion and Order, 60 RR 2d 1386,
1388 (1986); Eastern Broadcasting Corp., Memorandum Opinion and Order, 10
FCC 2d 37 (1967), recon. denied, 11 FCC 2d 193 (1967).
12 FCC Rcd 17087 (1997), recon. denied, 15 FCC Rcd 303 (1999).
47 C.F.R. S: 1.80.
See Forfeiture Policy Statement 12 FCC Rcd at 17113-15; 47 C.F.R. S:
1.80(b)(4), note to paragraph (b)(4), Section I. See also KM Radio of St.
Johns, Memorandum Opinion and Order and Notice of Apparent Liability for
Forfeiture, 19 FCC Rcd 5847, 5852 (2004) (proposing a $4,000 forfeiture
for construction of new FM station 900 feet from authorized site); Maria
L. Salazar, Memorandum Opinion and Order, 19 FCC Rcd 5050, 5051 (2004)
($34,000 forfeiture for multiple violations by FM station including $4,000
for operations outside community of license); Morradio, Forfeiture Order,
14 FCC Rcd 5201 (Consumer Info. Bur. 1999) (imposing a $4,000 forfeiture
for operation at unauthorized site).
In several analogous cases involving unauthorized operation, we have
upwardly adjusted the base forfeiture by $1000 per violation. See, e.g.,
Mathews Readymix LLC, Notice of Apparent Liability for Forfeiture, 23 FCC
Rcd 12828, 12831 (Enf. Bur., Spectrum Enf. Div. 2007) (forfeiture paid)
(upwardly adjusting the proposed base forfeiture from $5,000 to $6,000 for
the operation of a General Mobile Radio Service ("GMRS") station for
approximately six years without Commission authorization); Mitchell
Electric Membership Cooperative, Notice of Apparent Liability for
Forfeiture, 22 FCC Rcd 5538, 5540-41 (Enf. Bur., Spectrum Enf. Div. 2007)
(forfeiture paid) (upwardly adjusting the proposed base forfeiture from
$5,000 to $6,000 for the operation of a Private Land Mobile Radio Service
("PLMRS") station for almost five years without Commission authorization);
National Weather Networks, Inc., Notice of Apparent Liability for
Forfeiture, 21 FCC Rcd 3922, 3925 (Enf. Bur., Spectrum Enf. Div. 2006)
(forfeiture paid) (upwardly adjusting the proposed base forfeiture from
$5,000 to $6,000 for the operation of a satellite earth station for over
four years without Commission authorization); Shared Data Networks, LLC,
Notice of Apparent Liability for Forfeiture, 20 FCC Rcd 18184, 18187 (Enf.
Bur., Spectrum Enf. Div. 2005) (forfeiture paid) (upwardly adjusting the
proposed aggregate base forfeiture of $15,000 ($5,000 per earth station)
to an aggregate forfeiture of $18,000 ($6,000 per earth station) for
operating three earth stations for almost five years without Commission
authorization).
47 U.S.C. S: 503(b).
47 C.F.R. S:S: 0.111, 0.311, 1.80.
47 C.F.R. S:S: 1.80(f)(3), 1.16.
(Continued from previous page)
(continued....)
Federal Communications Commission DA 10-1047
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Federal Communications Commission DA 10-1047