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Before the
Federal Communications Commission
Washington, D.C. 20554
)
)
) File No.: EB-10-SE-110
In the Matter of
) NAL/Acct. No.: 201132100011
East Buchanan Telephone Cooperative
) FRN: 0002557627
)
)
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: November 29, 2010 Released: November 29, 2010
By the Chief, Enforcement Bureau:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we
propose a forfeiture of forty-five thousand dollars ($45,000) against
East Buchanan Telephone Cooperative ("East Buchanan"), a Global System
for Mobile Communications-based ("GSM-based") Tier III carrier serving
parts of Iowa. As detailed herein, we find that East Buchanan
apparently willfully and repeatedly violated section 20.19(c)(3)(ii)
of the Commission's rules ("Rules"), by failing to offer to consumers
the required number or percentage of digital wireless handsets that
met or exceeded the radio frequency interference standards for hearing
aid compatibility set forth in section 20.19(b)(1), and apparently
willfully and repeatedly violated section 20.19(d)(3)(ii) of the
Rules, by failing to offer to consumers the required number or
percentage of digital wireless handsets that met or exceeded the
inductive coupling standards for hearing aid compatibility set forth
in section 20.19(b)(2).
II. BACKGROUND
2. In the 2003 Hearing Aid Compatibility Order, the Commission adopted
several measures to enhance the ability of consumers with hearing loss
to access digital wireless telecommunications. The Commission
established technical standards that digital wireless handsets must
meet to be considered compatible with hearing aids operating in
acoustic coupling and inductive coupling (telecoil) modes.
Specifically, the Commission adopted a standard for radio frequency
interference (the "M3" rating) to enable acoustic coupling between
digital wireless phones and hearing aids operating in acoustic
coupling mode, and a separate standard (the "T3" rating) to enable
inductive coupling with hearing aids operating in telecoil mode.
3. In the 2008 Hearing Aid Compatibility First Report and Order, the
Commission established several deadlines between 2008 and 2011 by
which manufacturers and service providers are required to offer
specified numbers or percentages of digital wireless handset models.
These requirements apply separately to phones operating over each air
interface, and the benchmarks and deadlines vary depending upon the
applicable interference standard as well as the category of
manufacturer or service provider. Between September 7, 2008 and May
14, 2009, non-Tier I service providers were required to ensure that at
least eight handset models per digital air interface, or at least 50%
of the models offered per digital air interface, met or exceeded the
M3 rating, and that at least three handset models per digital air
interface, or at least one-third of the models offered per digital air
interface, met or exceeded the T3 rating. Between May 15, 2009 and May
14, 2010, non-Tier I service providers were required to ensure that at
least nine handset models per digital air interface, or at least 50%
of the models offered per digital air interface, met or exceeded the
M3 rating, and that at least five handset models per digital air
interface, or at least one-third of the models offered per digital air
interface, met or exceeded the T3 rating. To ensure that the
Commission can accurately monitor the availability of these handsets,
and to provide valuable information to the public concerning the
technical testing and commercial availability of hearing
aid-compatible handsets (including on the Internet), the FCC also
requires annual reports from service providers and manufacturers on
their efforts towards compliance.
4. On January 11, 2010, East Buchanan submitted its hearing aid
compatibility status report for the 2009 reporting period. East
Buchanan's 2009 Report reveals that between June 1, 2009 and October
31, 2009, only two of the five handset models it offered to consumers
met or exceeded the M3 rating, and between November 1, 2009 and
November 30, 2009, only three of the seven handset models it offered
to consumers met or exceeded the M3 rating. East Buchanan's 2009
Report also reveals that between June 1, 2009 and October 31, 2009,
only one of the five handset models it offered to consumers met or
exceeded the T3 rating, and between November 1, 2009 and November 30,
2009, only one of the seven handset models it offered to consumers met
or exceeded the T3 rating.
5. The Wireless Telecommunications Bureau subsequently referred East
Buchanan's apparent violation of the hearing aid-compatible handset
requirements to the Enforcement Bureau for possible enforcement
action.
III. DISCUSSION
A. Failure to Comply with Hearing Aid-Compatible Handset Deployment
Requirements.
6. According to its 2009 Report, East Buchanan failed to ensure that it
offered to consumers the required number or percentage of wireless
handsets that met or exceeded the M3 and T3 hearing aid compatibility
ratings for six months during the 2009 reporting period. Specifically,
only two of the five handsets models offered by East Buchanan between
June 1, 2009 and October 31, 2009, and only three of the seven handset
models it offered between November 1, 2009 and November 30, 2009, met
or exceeded the M3 rating. Section 20.19(c)(3)(ii) of the Rules
requires non-Tier I digital wireless service providers like East
Buchanan to ensure that between May 15, 2009 and May 14, 2010, for
each air interface for which they offered handsets to consumers, at
least 50% of the handset models they offered, or at least nine handset
models, met or exceeded the M3 rating for radio frequency
interference. Thus, East Buchanan was required to offer at least three
M3-compliant handsets between June 1, 2009 and October 31, 2009, and
four M3-compliant handsets from November 1, 2009 to November 30, 2009.
Accordingly, we conclude that East Buchanan apparently willfully and
repeatedly violated section 20.19(c)(3)(ii) of the Rules.
7. East Buchanan's 2009 Report also reflects that only one of the five
handset models it offered between June 1, 2009 and October 31, 2009,
and only one of the seven handset models it offered between November
1, 2009 and November 30, 2009, met or exceeded the T3 rating. Section
20.19(d)(3)(ii) of the Rules requires non-Tier I digital wireless
service providers like East Buchanan to ensure that between May 15,
2009 and May 14, 2010, for each air interface for which they offered
handsets to consumers, at least one-third of the handset models they
offered, or at least five handset models, met or exceeded the T3
rating for inductive coupling. Thus, East Buchanan was required to
offer at least two T3-compliant handsets between June 1, 2009 and
October 31, 2009, and at least three T3-compliant handsets between
November 1, 2009 and November 30, 2009. Accordingly, we conclude that
East Buchanan apparently willfully and repeated violated section
20.19(d)(3)(ii) of the Rules.
A. Proposed Forfeiture
8. 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. We conclude
under this standard that East Buchanan is apparently liable for
forfeiture for its apparent willful and repeated violation of section
20.19(c)(3)(ii) of the Rules and its apparent willful and repeated
violation of section 20.19(d)(3)(ii) of the Rules.
9. Section 503(b)(2)(B) of the Act authorizes a forfeiture assessment
against a common carrier of up to $150,000 for each violation, or for
each day of a continuing violation, up to a maximum of $1,500,000 for
a single act or failure to act. 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."
10. In determining the appropriate forfeiture amount for violation of the
hearing aid- compatible handset deployment requirements, we take into
account that these requirements serve to ensure that consumers with
hearing loss have access to digital wireless telecommunications
services. In adopting the hearing aid compatibility rules, the
Commission underscored the strong and immediate need for such access,
stressing that individuals with hearing loss should not be denied the
public safety and convenience benefits of digital wireless telephony.
Moreover, as the Commission has noted, the demand for hearing
aid-compatible handsets is likely to increase with the growing
reliance on wireless technology and with the increasing median age of
our population.
11. We have previously determined that violations of the hearing
aid-compatible handset deployment requirements are serious in nature
because failure to make compliant handsets available actually prevents
hearing aid users from accessing digital wireless communications. As
such, we generally apply a base forfeiture amount of $15,000 to
reflect the gravity of these violations. We have also applied the
$15,000 base forfeiture on a per handset basis (i.e., for each handset
model below the minimum number of hearing aid-compatible models
required by the rules).
12. The record establishes that East Buchanan was out of compliance with
the handset deployment requirements for both reduced RF interference
and inductive coupling capability for six months (between June 1, 2009
and November 30, 2009) during the 2009 reporting period. Thus, East
Buchanan did not satisfy the requirement that non-Tier I service
providers ensure that at least 50% of the handset models that they
offered (or nine models) met or exceeded the M3 rating. Accordingly,
because East Buchanan missed the required number of M3-rated handsets
by one handset throughout this period, it is apparently liable for a
forfeiture of $15,000 for failing to offer to consumers the required
number or percentage of acoustic coupling-compatible handset models in
willful and repeated violation of section 20.19(c)(3)(ii) of the
Rules.
13. As noted above, East Buchanan also failed to comply with the
requirement that non-Tier I service providers ensure that at least
one-third of the handset models that they offered (or three models)
met or exceeded the T3 rating. Accordingly, because East Buchanan
missed the required number of T3-rated handsets by up to two handsets
during this period, it is apparently liable for a forfeiture of
$30,000 for failing to offer to consumers the required number or
percentage of inductive coupling-capable handset models in willful and
repeated violation of section 20.19(d)(3)(ii) of the Rules.
14. We therefore find that East Buchanan is apparently liable for a total
forfeiture of $45,000 for apparently willfully and repeatedly failing
to comply with the hearing aid- compatible handset deployment
requirements set forth in section 20.19(c)(3)(ii) and (d)(3)(ii) of
the Rules.
IV. ORDERING CLAUSES
15. Accordingly, IT IS ORDERED that, pursuant to section 503(b) of the
Act, and section 1.80 of the Rules, East Buchanan Telephone
Cooperative IS NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE in
the amount of forty-five thousand dollars ($45,000) for willful and
repeated violation of sections 20.19(c)(3)(ii) and 20.19(d)(3(ii) of
the Rules.
16. 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, East Buchanan Telephone Cooperative SHALL
PAY the full amount of the proposed forfeiture or SHALL FILE a written
statement seeking reduction or cancellation of the proposed
forfeiture.
17. 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 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. East Buchanan Telephone Cooperative
must also send electronic notification on the date said payment is
made to Ricardo Durham at Ricardo.Durham@fcc.gov and to Kathy Harvey
at Kathy.Harvey@fcc.gov.
18. 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. Number referenced in the caption. The statement must
also be emailed to Ricardo Durham at Ricardo.Durham@fcc.gov and to
Kathy Harvey at Kathy.Harvey@fcc.gov.
19. 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.
20. 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 East Buchanan Telephone Cooperative, 214
Third Street North, Winthrop, IA 50682, and to its counsel, D. Cary
Mitchell, Esq., Blooston, Mordkofsky, Dickens, Duffy & Prendergast,
LLP, 2120 L Street, NW, Suite 300, Washington, DC 20037.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Tier III carriers are non-Nationwide wireless radio service providers with
500,000 or fewer subscribers as of the end of September 2001. See Revision
of the Commission's Rules to Ensure Compatibility with Enhanced 911
Emergency Calling Systems, Phase II Compliance Deadlines for
Non-Nationwide CMRS Carriers, Order to Stay, 17 FCC Rcd 14841, 14847-48
P:P: 22-24 (2002).
47 C.F.R. S: 20.19(c)(3)(ii).
47 C.F.R. S: 20.19(b)(1).
47 C.F.R. S: 20.19(d)(3)(ii).
47 C.F.R. S: 20.19(b)(2).
Section 68.4(a) of the Commission's Rules Governing Hearing Aid-Compatible
Telephones, Report and Order, 18 FCC Rcd 16753 (2003); Erratum, 18 FCC Rcd
18047 (2003) ("Hearing Aid Compatibility Order"); Order on
Reconsideration and Further Notice of Proposed Rulemaking, 20 FCC Rcd
11221 (2005). The Commission adopted these requirements for digital
wireless telephones under the authority of the Hearing Aid Compatibility
Act of 1988, codified at section 710(b)(2)(C) of the Communications Act of
1934, as amended (Act), 47 U.S.C. S: 610(b)(2)(C).
See Hearing Aid Compatibility Order, 18 FCC Rcd at 16777 P: 56; 47 C.F.R.
S: 20.19(b)(1), (2). The Hearing Aid Compatibility Order described the
acoustic coupling and the inductive (telecoil) coupling modes as follows:
In acoustic coupling mode, the microphone picks up surrounding sounds,
desired and undesired, and converts them into electrical signals. The
electrical signals are amplified as needed and then converted back into
electrical signals. In telecoil mode, with the microphone turned off, the
telecoil picks up the audio signal-based magnetic field generated by the
voice coil of a dynamic speaker in hearing aid-compatible telephones,
audio loop systems, or powered neck loops. The hearing aid converts the
magnetic field into electrical signals, amplifies them as needed, and
converts them back into sound via the speaker. Using a telecoil avoids the
feedback that often results from putting a hearing aid up against a
telephone earpiece, can help prevent exposure to over amplification, and
eliminates background noise, providing improved access to the telephone.
Id. at 16763 P: 22.
As subsequently amended, section 20.19(b)(1) provides that, for the period
beginning June 6, 2008 and ending January 1, 2010, a wireless handset is
deemed hearing aid-compatible for radio frequency interference if, at
minimum, it meets the M3 rating associated with the technical standard set
forth in either the standard document "American National Standard Methods
of Measurement of Compatibility between Wireless Communication Devices and
Hearing Aids," ANSI C63.19-2006 (June 12, 2006) or ANSI 63.19-2007 (June
8, 2007). 47 C.F.R. S: 20.19(b)(1). Section 20.19(b)(2) provides that, for
the period beginning June 6, 2008 and ending January 1, 2010, a wireless
handset is deemed hearing aid-compatible for inductive coupling if, at
minimum, it meets the T3 rating associated with the technical standard as
set forth in either the standard document "American National Standard
Methods of Measurement of Compatibility between Wireless Communication
Devices and Hearing Aids," ANSI C63.19-2006 (June 12, 2006) or ANSI
63.19-2007 (June 8, 2007). 47 C.F.R. S: 20.19(b)(2).
This requirement does not apply to service providers and manufacturers
that meet the de minimis exception. See Amendment of the Commission's
Rules Governing Hearing Aid-Compatible Mobile Handsets, First Report and
Order, 23 FCC Rcd 3406, 3418-24 P:P: 34-46 (2008) ("Hearing Aid
Compatibility First Report and Order"), Order on Reconsideration and
Erratum, 23 FCC Rcd 7249 (2008); 47 C.F.R. S:S: 20.19(c), (d). The de
minimis exception provides that manufacturers or mobile service providers
that offer two or fewer digital wireless handset models per air interface
are exempt from the hearing aid compatibility requirements and
manufacturers or service providers that offer three digital wireless
handset models per air interface must offer at least one compliant model.
47 C.F.R. S: 20.19(e). We note that the Commission recently limited the de
minimis exception to exclude service providers that are not small entities
after an initial two-year period. See Amendment of the Commission's Rules
Governing Hearing Aid-Compatible Mobile Handsets, Policy Statement and
Second Report and Order and Further Notice of Proposed Rulemaking, FCC
10-145 P:P: 35-59 (rel. Aug. 5, 2010).
The term "air interface" refers to the technical protocol that ensures
compatibility between mobile radio service equipment, such as handsets,
and the service provider's base stations. Currently, the leading air
interfaces include Code Division Multiple Access (CDMA), Global System for
Mobile Communications (GSM), Integrated Digital Enhanced Network (iDEN),
and Wideband Code Division Multiple Access (WCDMA) a/k/a Universal Mobile
Telecommunications System (UMTS).
See Hearing Aid Compatibility First Report and Order, 23 FCC Rcd at 3419
P: 35; 47 C.F.R. S: 20.19(c)(3)(ii).
See Hearing Aid Compatibility First Report and Order, 23 FCC Rcd at 3419
P: 36; 47 C.F.R. S: 20.19(d)(3)(ii).
See Hearing Aid Compatibility First Report and Order, 23 FCC Rcd at 3419
P: 35; 47 C.F.R. S: 20.19(c)(3)(ii).
See Hearing Aid Compatibility First Report and Order, 23 FCC Rcd at 3419
P: 36; 47 C.F.R. S: 20.19(d)(3)(ii).
See Hearing Aid Compatibility First Report and Order, 23 FCC Rcd at 3443
P: 91. The Commission initially required manufacturers and digital
wireless service providers to report every six months on efforts toward
compliance with the hearing aid compatibility requirements for the first
three years of implementation (May 17, 2004, November 17, 2004, May 17,
2005, November 17, 2005, May 17, 2006 and November 17, 2006), and then
annually thereafter through the fifth year of implementation (November 19,
2007 and November 17, 2008). Hearing Aid Compatibility Order, 18 FCC Rcd
at 16787 P: 89; see also Wireless Telecommunications Bureau Announces
Hearing Aid Compatibility Reporting Dates for Wireless Carriers and
Handset Manufacturers, Public Notice, 19 FCC Rcd 4097 (Wireless Tel. Bur.
2004). In its 2008 Hearing Aid Compatibility First Report and Order, the
Commission extended these reporting requirements with certain
modifications on an open ended basis, beginning January 15, 2009. See
Hearing Aid Compatibility First Report and Order, 23 FCC Rcd at 3410 P:
13. In addition, the Commission made clear that these reporting
requirements apply to manufacturers and service providers that fit within
the de minimis exception. Id. at 3446 P: 99.
See East Buchanan Telephone Cooperative Hearing Aid Compatibility Status
Report (filed January 11, 2010) ("2009 Report"), at
http://wireless.fcc.gov/hac_documents/100317/East%20Buchanan%20Teleph_151.PDF.
Id. East Buchanan's 2009 Report indicates that it offered the required
number or percentage of handset models that met or exceeded the M3 rating
between January 1, 2009 and May 30, 2009, and between December 1, 2009 and
December 31, 2009.
Id. East Buchanan's 2009 Report indicates that it offered the required
number or percentage of handset models that met or exceeded the T3 rating
between January 1, 2009 and May 30, 2009, and between December 1, 2009 and
December 31, 2009.
All of East Buchanan's handsets for the 2009 reporting period operated
only over the GSM air interface.
47 C.F.R. S: 20.19(c)(3)(ii).
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 P: 5 (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 P: 12 (2008); Regent USA, Notice of Apparent Liability for
Forfeiture, 22 FCC Rcd 10520, 10523 P: 9 (2007); San Jose Navigation,
Inc., Forfeiture Order 22 FCC Rcd 1040, 1042 P: 9 (2007), consent decree
ordered, Order and Consent Decree, 25 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); Southern
California, 6 FCC Rcd at 4388.
47 C.F.R. S: 20.19(d)(3)(ii).
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).
47 U.S.C. S: 503(b)(2)(B). This amount is subject to further adjustment
for inflation (see id. S: 1.80(b)(5)), and the forfeiture amount
applicable to any violation will be determined based on the statutory
amount designated at the time of the violation. 47 C.F.R. S: 1.80(b)(3).
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.
Hearing Aid Compatibility Order, 18 FCC Rcd at 16755 P: 4.
Id. at 16756 P: 5 (noting that approximately one in ten Americans, 28
million, have some level of hearing loss, that the proportion increases
with age, and that the number of those affected will likely grow as the
median age increases). See also Report on the Status of Implementation of
the Commission's Hearing Aid Compatibility Requirements, Report, 22 FCC
Rcd 17709, 17719 P: 20 (2007) (noting, just four years later, that the
number of individuals with hearing loss in the United States was "at an
all time high of 31 million - with that number expected to reach
approximately 40 million at the end of this decade").
Compare, e.g., South Central Utah Telephone Association, Inc., Notice of
Apparent Liability for Forfeiture, 22 FCC Rcd 19251, 19255-56 P: 10 (Enf.
Bur., Spectrum Enf. Div. 2007), response pending; Pine Telephone Company,
Inc., Notice of Apparent Liability for Forfeiture, 22 FCC Rcd 9205, 9210
P: 11 (Enf. Bur., Spectrum Enf. Div. 2007), consent decree ordered, Order
and Consent Decree, 23 FCC Rcd 4485 (Enf. Bur. 2008). In contrast to
handset deployment requirement violations, we have found that a violation
of the labeling requirements (while serious because it prevents hearing
aid users from making informed choices) is less egregious than a violation
of the deployment requirements. In the past, a base forfeiture amount of
$8,000 has applied to violations of the labeling requirements for wireless
hearing aid-compatible handsets.
See, e.g., SLO Cellular, Inc., Notice of Apparent Liability for
Forfeiture, 23 FCC Rcd 3990, 3996-97 P: 14 (Enf. Bur. 2008), response
pending; NEP Cellcorp, Inc., Notice of Apparent Liability for Forfeiture,
24 FCC Rcd 8, 13 P: 11 (Enf. Bur., Spectrum Enf. Div. 2009); Corr Wireless
Communications, LLC, Notice of Apparent Liability for Forfeiture, 23 FCC
Rcd 11567, 11571 P: 11 (Enf. Bur., Spectrum Enf. Div. 2008), response
pending; Blanca Telephone Company, Notice of Apparent Liability for
Forfeiture, 23 FCC Rcd 9398, 9403 P: 12 (Enf. Bur., Spectrum Enf. Div.
2008), response pending; Pinpoint Wireless, Inc., Notice of Apparent
Liability for Forfeiture, 23 FCC Rcd 9290, 9295 P: 11 (Enf. Bur., Spectrum
Enf. Div. 2008); Iowa Wireless Services, LLC d/b/a i Wireless, Notice of
Apparent Liability for Forfeiture, 23 FCC Rcd 4735, 4739 P: 12 (Enf.
Bur., Spectrum Enf. Div. 2008); South Slope Cooperative Telephone Company
d/b/a South Slope Wireless, Notice of Apparent Liability for Forfeiture,
23 FCC Rcd 4706, 4711-12 P: 12 (Enf. Bur., Spectrum Enf. Div. 2008),
response pending.
Id.
(Continued from previous page)
(continued....)
Federal Communications Commission DA 10-2250
3
Federal Communications Commission DA 10-2250