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                                  Before  the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                  )                               
                                                                  
                                  )   File No. EB-09-SE-126       
     In the Matter of                                             
                                  )   NAL/Acct. No. 201032100033  
     Alpheus Communications, LP                                   
                                  )   FRN No. 0005004361          
                                                                  
                                  )                               


                  Notice of apparent Liability for forfeiture

   Adopted: July 2, 2010 Released: July 6, 2010

   By the Chief, Enforcement Bureau:

   I. introduction

     1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
        Alpheus Communications, LP ("Alpheus") apparently liable for
        forfeiture in the amount of sixty thousand dollars ($60,000) for
        willfully and repeatedly violating the network outage reporting
        requirements set forth in Section 4.9(f) of the Commission's Rules
        ("Rules"). The noted apparent violations involve Alpheus's failure to
        file with the Commission network outage reports for a significant
        disruption in its network services within the time periods specified
        in Section 4.9(f) of the Rules.

   II. BACKGROUND

     2. The Commission's authority to require the submission of network
        outage reports derives from its responsibility, as set forth in the
        Communications Act, "to make available, so far as possible to all of
        the people of the United States ... a rapid, efficient, Nationwide,
        and world-wide wire and radio communications service, with adequate
        facilities ... for the purpose of the national defense, [and] for the
        purpose of promoting safety of life and property through the use of
        wire and radio communication." Section 4(o) of the Act states that
        "[f]or the purpose of obtaining maximum effectiveness from the use of
        radio and wire communications in connection with safety of life and
        property, the Commission shall investigate and study all phases of
        the problem."

     3. The Commission first imposed network outage reporting requirements on
        wireline carriers in 1992. The Commission revised these rules in 2004
        to require the filing of network outage reports by additional
        communications providers, adopt a common metric for determining the
        general outage-reporting threshold criteria that applies across all
        communications platforms, establish specific outage-reporting
        criteria that account for the unique technical aspects of each
        communications platform, and require the electronic filing of outage
        information. In revising the network outage reporting requirements,
        the Commission sought to ensure that it had prompt access to accurate
        information regarding the operation and security of crucial segments
        of the national telecommunications infrastructure. The Commission
        stated that such access would enable it to prevent disruptions in
        service that could potentially threaten "homeland security, public
        health and safety, as well as [our] economic well-being," and
        facilitate alternative means of communicating, either through
        different network routes or different communication facilities. In
        this way, the Commission could meet its statutory obligation to
        protect the public's access to secure communications, even "during
        terrorist attacks, fires, natural disasters (such as hurricanes,
        earthquakes, and tornadoes) and war."

     4. Under Section 4.9(f) of the Rules, wireline service providers must
        report to the Commission an outage of at least 30 minutes duration
        that: (1) potentially affects at least 900,000 user minutes of either
        telephony or paging; (2) affects at least 1,350 DS3 minutes; (3)
        potentially affects any special offices and facilities; or (4)
        potentially affects a 911 special facility. Upon discovery of such an
        outage, wireline service providers must file an electronic
        Notification within 120 minutes, an Initial Communications Outage
        Report within 72 hours, and a Final Communications Outage Report
        within 30 days.

     5. Alpheus is a non-dominant wireline carrier that provides
        telecommunications and data center services, and is therefore subject
        to the network outage reporting rules. In 2009, the Public Safety and
        Homeland Security Bureau referred Alpheus to the Enforcement Bureau
        for investigation, because it appeared that Alpheus had failed to
        file a Notification and an Initial Communications Outage Report for a
        significant disruption in its network services within the time frames
        specified in Section 4.9(f) of the Rules. The Enforcement Bureau
        ("Bureau") through the Spectrum Enforcement Division ("Division")
        issued Alpheus a Letter of Inquiry ("LOI") on September 10, 2009, 
        directing it to provide certain information and documents regarding
        its compliance with the network outage reporting requirements. The
        Bureau received Alpheus's response to the LOI on October 9, 2009. 

   III. Discussion

   A. Alpheus Apparently Violated the Network Outage Reporting Requirements

     6. Section 4.9(f) of the Rules requires Alpheus to submit to the
        Commission an electronic Notification within 120 minutes after
        discovering that it has experienced a network outage of at least 30
        minutes duration that meets certain criteria on any facility that it
        owns, operates, leases, or otherwise utilizes. Thereafter, Alpheus
        must file an Initial Communications Outage Report with respect to the
        outage within 72 hours after discovery of the outage, and a Final
        Communications Outage Report within 30 days after discovery of the
        outage. The Notification serves to inform the Commission that a major
        event has occurred and assists the Commission in determining "whether
        an immediate response is required (e.g., terrorist attack or systemic
        failure) and whether patterns of outages are emerging (e.g., phased
        terrorist attacks) that warrant further coordination or other
        action." The Initial and Final Communications Outage Reports provide
        the Commission with more detailed data necessary to analyze outages
        in order to improve network reliability and security.

     7. The record establishes that, within the past year, Alpheus failed to
        timely file both an electronic Notification within 120 minutes and an
        Initial Communications Outage Report within 72 hours of discovering a
        reportable outage. Because our rules treat network outage reports as
        confidential for national security and commercial and trade secret
        reasons, we will not describe herein the details of this outage,
        including the basis for determining that it is reportable, its
        location, duration, or the number and type of customers affected.
        That information is provided in an Appendix hereto that will remain
        confidential. As set forth in detail in the confidential Appendix, we
        conclude that Alpheus apparently willfully and repeatedly violated
        Section 4.9(f) of the Rules by failing to file an electronic
        Notification within 120 minutes and an Initial Communications Outage
        Report within 72 hours of discovering a reportable outage.

   B. Proposed Forfeiture

     8. Under Section 503(b)(1)(B) of the Act and Section 1.80(a)(1) of the
        Rules, 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. We conclude under
        this standard that Alpheus is apparently liable for forfeiture for
        its apparent willful and repeated violations of Section 4.9(f) of the
        Rules.

     9. Section 503(b)(2)(B) of the Act authorizes the Commission to assess a
        common carrier a maximum forfeiture of $150,000 for each violation,
        or each day of a continuing violation, up to a statutory maximum of
        $1,500,000 for any single continuing violation. In determining the
        appropriate forfeiture amount, Section 503(b)(2)(E) of the Act
        directs the Commission to consider factors, such as "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."

    10. The Commission's Forfeiture Policy Statement and its implementing
        rules establish $3,000 as the base forfeiture for failure to file
        required forms and information. We believe, however, that a
        substantial upward adjustment of the base forfeiture amount is
        warranted.  Reliable communication services are essential to the
        operation of virtually all government, business and critical
        infrastructure, as well as to the nation's economy, and the network
        outage reporting rules were intended to help ensure the reliability
        of our communications infrastructure. Indeed, the failure to file
        timely and accurate network outage reports jeopardizes the ability of
        the Commission to effectively monitor and respond to network outages
        that potentially threaten homeland security.

    11. Distinctions between the three required network outage reports merit
        a two-tiered forfeiture approach. As noted above, the Notification
        alerts the Commission to possible widespread problems, while the
        Initial and Final Communications Outage Reports supplement the
        notification and provide more detailed information on the outage.
        Thus, failure to timely file the Notification has a more critical and
        significantly higher impact on public safety than does failure to
        timely file the Initial and Final Communications Outage Reports. In
        light of the increased impact on public safety of a violation
        involving the Notification (for the same outage), we adopt a
        two-tiered forfeiture approach for late-filed reports. We set the
        base forfeiture at $40,000 per late filing for failure to timely file
        Notifications and at $20,000 per late filing for failure to timely
        file Initial and Final Communications Outage Reports. Under the
        general forfeiture authority contained in Section 503 of the Act and
        the Commission's Forfeiture Policy Statement however, we retain the
        discretion to depart from this approach and issue forfeitures  on a
        case by case basis, including appropriate upward and/or downward
        adjustments, based on the particular circumstances of a case.

    12. Alpheus filed the Notification more than 120 minutes after
        discovering the outage and the Initial Communications Outage Report
        more than 72 hours after discovery of the outage. Alpheus's failure
        to timely file the Notification and the Initial Communications Outage
        Report had a significant adverse impact on the Commission's ability
        to ensure the availability of the nation's communications capability
        and track possible threats to national security. Accordingly, we find
        that each of Alpheus's failures to file constitutes a separate
        violation that continued until the violation was cured. In light of
        Alpheus's failure to timely file the Notification and the Initial
        Communications Outage Report in this case, we find it apparently
        liable for a base forfeiture in the amount of forty thousand dollars
        ($40,000) for the late Notification and twenty thousand dollars
        ($20,000) for the late Initial Communications Outage Report, for an
        aggregate base forfeiture amount of sixty thousand dollars ($60,000).

    13. As detailed in the attached confidential Appendix, the outage in this
        case had a relatively limited impact in comparison to other network
        outages. However, Alpheus did not correct its failure to file until
        it was contacted by Commission staff. Accordingly, we find that no
        downward adjustment of the base forfeiture is appropriate. We
        therefore propose a total forfeiture of $60,000 for Alpheus's failure
        to file a timely Notification and a timely Initial Communications
        Outage Report for a reportable network outage in apparent willful and
        repeated violation of Section 4.9(f) of the Rules.

   IV. ORDERING CLAUSES

    14. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the
        Act, and Section 1.80 of the Rules, and the authority delegated by
        Sections 0.111 and 0.311 of the Rules, Alpheus Communications, LP is
        hereby NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE in the
        amount of sixty thousand dollars ($60,000) for its willful and
        repeated violations of Section 4.9(f) of the Rules.

    15. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Rules,
        within thirty (30) days of the release date of this Notice of
        Apparent Liability for Forfeiture, Alpheus SHALL PAY the full amount
        of the proposed forfeiture or SHALL FILE a written statement seeking
        reduction or cancellation of the proposed forfeiture.

    16. 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.
        Alpheus will also send electronic notification on the date said
        payment is made to Kathryn Berthot at Kathy.Berthot@fcc.gov and to
        Linda Nagel at Linda.Nagel@fcc.gov.

    17. 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
        response should also be e-mailed to Kathryn Berthot at
        Kathy.Berthot@fcc.gov and to Linda Nagel at Linda.Nagel@fcc.gov.

    18. 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.

    19. 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 Stephen W. Crawford, Esq.,
        General Counsel and Senior Vice President, Alpheus Communications,
        LP, 1301 Fannin St., 20th Floor, Houston, TX 77002 and to counsel for
        Alpheus, Joshua M. Bobeck, Esq., Bingham McCutchen LLP, 2020 K
        Street, NW, Washington, DC 20006-1806.

   FEDERAL COMMUNICATIONS COMMISSION

   P. Michele Ellison

   Chief, Enforcement Bureau

   47 C.F.R. S: 4.9(f).

   Section 1 of the Communications Act of 1934, as amended ("Act"), 47 U.S.C.
   S: 151.

   47 U.S.C. S: 154(o).

   See Notification by Common Carriers of Service Disruptions, Report and
   Order, 7 FCC Rcd 2010 (1992); Memorandum Opinion and Order and Further
   Notice of Proposed Rulemaking, 8 FCC Rcd 8517 (1993); Second Report and
   Order, 9 FCC Rcd 3911 (1994); Order on Reconsideration of Second Report
   and Order, 10 FCC Rcd 11764 (1995).

   See 47 C.F.R. Part 4; see also New Part 4 of the Commission's Rules
   Concerning Disruptions to Communications, Report and Order and Further
   Notice of Proposed Rulemaking, 19 FCC Rcd 16830, 16833-34, 16882-94 P:P:
   2, 97-126 (2004) ("2004 Network Outage Order") (extending the network
   outage reporting requirements to paging and wireless, cable circuit-switch
   telephony, and satellite communications providers).

   2004 Network Outage Order, 19 FCC Rcd at 16834 n.5, 16861-62 P:P: 55-56.

   Id. at 16876-16894 P:P: 82-126.

   Id. at 16833-34, 16908-9 P:P: 2, 156-158.

   Id. at 16833, 16835-36, 16910 P:P: 1, 11, 160.

   Id. at 16910 P: 160.

   Id. at 16835-36, 16910 P:P: 11, 160.

   See 47 U.S.C. S:S: 151, 154(k) and (o).

   2004 Network Outage Order, 19 FCC Rcd at 16837 P: 11. Noting that there
   are many examples of the critical need for, and our dependence upon,
   reliable communications service, the Commission offered one illustration -
   our financial infrastructure - which largely consists of computers,
   databases, and communications links. The Commission stated that:

   If the communications links were severed, or severely degraded, ATM
   machines would not be able to supply cash, credit card transactions would
   not `go through,' banks would not be able to process financial
   transactions (including checks), and the financial markets would become
   dysfunctional. In a short time, economic activity would grind to a halt
   and consumers' ability to purchase food, fuel or clothing would be
   severely limited if not destroyed.

   Id. at 16836-37 P: 11.

   "User minutes" are defined as "assigned telephone number minutes ... for
   telephony and for those paging networks in which each individual user is
   assigned a telephone number" or "the mathematical result of multiplying
   the duration of an outage, expressed in minutes, by the number of end
   users potentially affected by the outage for all other forms of
   communication." 47 C.F.R. S: 4.7(e).

   "DS3 minutes" are defined as "the mathematical result of multiplying the
   duration of an outage, expressed in minutes, by the number of previously
   operating DS3 circuits that were affected by the outage." 47 C.F.R. S:
   4.7(d).

   "Special offices and facilities" include major military installations, key
   government facilities, nuclear power plants, and certain airports. 47
   C.F.R. S: 4.5(b)-(d).

   See 47 C.F.R. S: 4.5(e).

   See 47 C.F.R. S: 4.9(f).

   A "data center" is defined as a "centralized location where computing
   resources critical to an organization are maintained in a highly
   controlled environment." See Harry Newton, Newton's Telecom Dictionary,
   228 (CMP Books, 17th ed., 2001).

   47 C.F.R. S:S: 4.3(b), 4.9(f). See also Application for the Transfer of
   Control of Alpheus Communications, L.P., and Alpheus Data Services, LLC,
   WC Docket No. 07-246 (filed October 30, 2007).

   Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
   Enforcement Bureau, to Stephen W. Crawford, Esq., General Counsel and
   Senior Vice President, Alpheus Communications, LP (September 10,
   2009)("LOI").

   Letter from Joshua M. Bobeck, Esq., Counsel for Alpheus Communications,
   LP, to Linda M. Nagel, Esq., Spectrum Enforcement Division, Enforcement
   Bureau, Federal Communications Commission (October 9, 2009) ("LOI
   Response").

   47 C.F.R. S: 4.9(f). See also supra, P: 4.

   2004 Network Outage Order, 19 FCC Rcd at 16868 P: 69.

   See id. at 16834 P: 3, 16868 P:P: 73-75.

   In the 2004 Network Outage Order, the Commission afforded confidential
   treatment to network outage reports. 2004 Network Outage Report, 19 FCC
   Rcd at 16853-55, P:P: 42-46. Section 4.2 of the Rules specifically states
   that Part 4 outage reports "will be presumed to be confidential" and that
   public access to outage reports may be sought only pursuant to the
   procedures set forth in Section 0.461 of the Rules which addresses
   requests for inspection of materials not routinely available for public
   inspection. 47 C.F.R. S: 4.2; see also 47 C.F.R. 0.461. On March 30, 2009,
   the Commission added a new Section 0.457(d)(1)(vii) of the Rules, 47
   C.F.R. S: 0.457(d)(1)(vii), to further codify the confidential treatment
   of network outage reporting. This new Section became effective on April
   29, 2009. See 74 FR 14,078 (March 30, 2009).

   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 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 terms in the
   Section 503(b) context. See, e.g., Southern California Broadcasting Co.,
   Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388 P: 5 (1991), recon.
   denied, Memorandum Opinion and Order, 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 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, Inc., Forfeiture Order, 17 FCC Rcd 7589,
   7591 (2002) (forfeiture paid).

   47 U.S.C S: 503(b)(2)(B). 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/$1,325,000 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 only applies
   to violations that occur after that date. See 73 Fed. Reg. 44663-5.
   Because Alpheus's apparent violations occurred after September 2, 2008, it
   is subject to the new forfeiture limits.

   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.

   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, 17117, recon. denied, 15 FCC Rcd 303 (1999) ("Forfeiture
   Policy Statement"); see also 47 C.F.R. S: 1.80(b)(4), Note to paragraph
   (b)(4): Section I. Base Amounts for Section 503 Forfeitures.

   We note that the Commission has upwardly adjusted the base forfeiture for
   the failure to file Telecommunications Reporting Worksheets from $3,000 to
   $50,000, because of the importance of the Worksheets to the Commission's
   administration of the Universal Service Fund ("USF"), Telecommunications
   Relay Services Fund ("TRS fund"), and other telecommunications regulatory
   programs. See, e.g., InPhonic, Inc., Notice of Apparent Liability for
   Forfeiture, 20 FCC Rcd 13277, 13286-67 (2005), forfeiture ordered, Order
   of Forfeiture and Further Notice of Apparent Liability for Forfeiture, 22
   FCC Rcd 8689 (2007) ("In Phonic"); Globcom, Inc. d/b/a Globcom Global
   Communications, Notice of Apparent Liability for Forfeiture and Order, 18
   FCC Rcd 19893, 19905 (2003), forfeiture ordered,  21 FCC Rcd 4710 (2006)
   ("Globcom").

   2004 Network Outage Order, 19 FCC Rcd at 16836 P: 11.

   See supra paragraph 6.

   See 47 U.S.C. S: 503(b)(2)(E).

   See Forfeiture Policy Statement, 12 FCC Rcd  at 17099 P: 22, 17101 P: 29.
   See also 47 C.F.R. S:1.80(b)(4) ("The Commission and its staff may use
   these guidelines in particular cases [, and] retain the discretion to
   issue a higher or lower forfeiture than provided in the guidelines, to
   issue no forfeiture at all, or to apply alternative or additional
   sanctions as permitted by the statute.") (emphasis added).

   See Telrite Corporation, Notice of Apparent Liability for Forfeiture and
   Order, 23 FCC Rcd 7231, 7244-45 (2008) (determining that the failure to
   file Telecommunications Reporting Worksheets was a continuing violation)
   ("Telrite"); Compass Global, Inc., Notice of Apparent Liability for
   Forfeiture, 23 FCC Rcd 6125, 6138 (2008) (same) ("Compass Global"); VCI
   Company, Notice of Apparent Liability for Forfeiture and Order, 22 FCC Rcd
   15933, 15940 (2007) (determining that the failure to file Lifeline and
   Linkup Worksheets was a continuing violation) ("VCI"); American Samoa
   Telecommunications Authority, Notice of Apparent Liability for Forfeiture,
   23 FCC Rcd 16432, 16437 (Enf. Bur., Spectrum Enf. Div. 2008), response
   received ("ASTCA NAL").

   See LOI Response, Exhibit 4.

   (continued ...)

   Federal Communications Commission DA 10-1258

   2

   Federal Communications Commission DA 10-1258