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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                             )                                
                                                              
                             )                                
                                                              
                             )   File No.: EB-10-SE-113       
     In the matter of                                         
                             )   NAL/Acct. No.: 201132100018  
     Indigo Wireless, Inc.                                    
                             )   FRN#: 0009120999             
                                                              
                             )                                
                                                              
                             )                                


                  NOTICE OF APPARENT LIABILITY FOR FORFEITURE

   Adopted: December 29, 2010 Released: December 30, 2010

   By the Chief, Enforcement Bureau:

   I. INTRODUCTION

    1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we
       propose a forfeiture of thirty-nine thousand dollars ($39,000) against
       Indigo Wireless, Inc. ("Indigo Wireless"), a Global System for Mobile
       Communications-based ("GSM-based") Tier III carrier serving parts of
       New York and Pennsylvania. As detailed herein, we find that Indigo
       Wireless apparently willfully and repeatedly violated section
       20.19(c)(3)(ii) of the Commission's rules ("Rules"), by failing to
       offer to consumers for nine months 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) of the Rules.

   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.
       The number or percentage of digital wireless handset models required
       by each deadline is based on several factors, including the applicable
       interference standard and air interface. For example, 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 15, 2010, Indigo Wireless submitted its hearing aid
       compatibility status report for the 2009 reporting period ("2009
       Report"). A review of Indigo Wireless's 2009 Report reveals apparent
       inconsistencies between the hearing aid compatibility ratings for
       certain handsets listed in the Report and the ratings for those
       handsets specified in the Commission's equipment authorizations for
       those handsets. Taking these inconsistencies into account, Indigo
       Wireless's 2009 Report indicates that it failed to offer to consumers
       the requisite number or percentage of digital hearing aid-compatible
       handsets that met or exceeded the M3 rating between March 1, 2009 and
       July 30, 2009 and between September 1, 2009 and December 31, 2009.
       Specifically, of the total number of handset models offered each
       month, only seven of the fifteen handset models (March 2009); seven of
       the sixteen handset models (April 2009); six of the fifteen handset
       models (May 2009); five of the thirteen handset models (June and July
       2009); six of the thirteen handset models (August 2009); five of the
       twelve handset models (September 2009); four of the ten handset models
       (October and November 2009) and four of the eleven handset models
       (December 2009) met or exceeded the M3 rating.

    5. The Wireless Telecommunications Bureau subsequently referred Indigo
       Wireless's apparent violation of the hearing aid-compatible handset
       deployment requirements to the Enforcement Bureau ("Bureau") for
       possible enforcement action. On September 8, 2010, the Bureau issued a
       letter of inquiry ("LOI") to Indigo Wireless. Indigo Wireless
       responded to the LOI ("LOI Response") on October 11, 2010. In its LOI
       response, Indigo Wireless explained that it relied on information from
       Internet sources such as PhoneNews.com and PhoneScoop.com to confirm
       the rating for the Pantech c810 handset, the Sony Ericsson w920
       handset and the Samsung s5230 handset because the third-party Internet
       sources were the "best information available to us at the time of
       filing." With respect to the Samsung s5230, Indigo Wireless explained
       that it sold the handset model for only one week in December 2009 and
       no longer promotes the handset as hearing aid-compatible. Indigo
       Wireless further explains that "this handset may have been reported
       incorrectly however it was not willfully done so."

   III. DISCUSSION

          A. Failure to Comply with Hearing Aid-Compatible Handset Deployment
             Requirements.

    6. We find that Indigo Wireless failed to offer the required number
       of hearing aid-compatible handsets that met or exceeded the M3
       rating for nine months during the 2009 reporting period.  As noted
       above, the Commission has imposed varying benchmarks for the
       deployment of hearing aid-compatible handsets.  As set forth in
       greater detail in the Appendix, between January 1, 2009 and May 14,
       2009, Indigo Wireless was obligated to ensure that at least eight
       handset models or 50% of the handset models it offered met or exceeded
       the M3 rating.  Indigo Wireless failed to meet this standard, offering
       only seven M3-rated hearing aid-compatible handsets during March
       through the first half of May of 2009.  In addition, during the latter
       part of the reporting period (between May 15, 2009 and December 2009),
       the handset deployment benchmarks for non-Tier I digital wireless
       service providers increased.  While Indigo Wireless was thus required
       to ensure that at least nine handset models or at least 50% of the
       handset models it offered met or exceeded the M3 rating during this
       period (that is, at least 50 percent of the 10 to 16 handsets offered
       during May through December 2009), the company again failed to offer
       the requisite number of hearing-aid compatible handsets, repeatedly
       falling short by one to two models.  Accordingly, we conclude that
       Indigo Wireless apparently willfully  and repeatedly  violated section
       20.19(c)(3)(ii) of the Rules for nine months of the 12-month reporting
       period.

     A. Proposed Forfeiture

    7. 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 Indigo Wireless is apparently liable for a
       forfeiture for its apparent willful and repeated violation of section
       20.19(c)(3)(ii) of the Rules.

    8. 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."

    9. The Commission's Forfeiture Policy Statement  and section 1.80 of the
       Rules do not establish a base forfeiture amount for violations of the
       hearing aid-compatible handset requirements set forth in section 20.19
       of the Rules. The fact that the Forfeiture Policy Statement does not
       specify a base amount does not indicate that no forfeiture should be
       imposed. The Forfeiture Policy Statement states that "... any omission
       of a specific rule violation from the ... [forfeiture guidelines] ...
       should not signal that the Commission considers any unlisted violation
       as nonexistent or unimportant." The Commission retains the discretion,
       moreover, to depart from the Forfeiture Policy Statement and issue
       forfeitures  on a case-by-case basis, under its general forfeiture
       authority contained in section 503 of the Act.

   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 Indigo Wireless failed to offer the
       required number of M3-rated handsets during March through July of 2009
       and during September through December of 2009. During that period,
       Indigo Wireless failed to offer the minimum number of M3-rated
       handsets by up to two handsets. In imposing a forfeiture, we are
       unpersuaded by Indigo Wireless's claim that the inconsistency in the
       ratings for three of its handsets (the Pantech c810 handset, the Sony
       Ericsson w910 handset and the Samsung s5230 handset) was due to
       reliance on information from third-party websites, it is well
       established that a violator's erroneous beliefs are not a mitigating
       factor warranting a forfeiture reduction. We also note that hearing
       aid compatibility ratings information for wireless handsets is
       publicly available on the FCC's web site, simply by entering the FCC
       Identification number for the handset into the Office of Engineering
       and Technology's Equipment Authorization Database. Accordingly, we
       find Indigo Wireless apparently liable for a forfeiture of $30,000 for
       failing to offer to consumers the required number or percentage of
       hearing aid-compatible handset models in willful and repeated
       violation of section 20.19(c)(3)(ii) of the Rules.

   13. This base forfeiture amount is, however, subject to upward adjustment.
       We note, in this regard, that Indigo Wireless was out of compliance
       with the hearing aid-compatible handset deployment requirements for
       nine of the 12 months during the 2009 reporting period. In view of the
       extended duration of the violation, we find that a significant upward
       adjustment of the base forfeiture amount from $30,000 is warranted. We
       therefore propose a $39,000 forfeiture against Indigo Wireless 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) of the Rules.

   14. We therefore find Indigo Wireless is apparently liable for a total
       forfeiture of $39,000 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) of the Rules.

   IV. ORDERING CLAUSES

   15. Accordingly, IT IS ORDERED that, pursuant to section 503(b) of the
       Act, and sections 0.111, 0.311, and 1.80 of the Rules, Indigo
       Wireless, Inc. IS NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE
       in the amount of thirty-nine thousand dollars ($39,000) for willful
       and repeated violation of section 20.19(c)(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, Indigo Wireless, Inc. 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 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. Indigo Wireless, Inc. will also send
       electronic notification on the date said payment is made to JoAnn
       Lucanik at JoAnn.Lucanik@fcc.gov and to Pamera Hairston at
       Pamera.Hairston@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/Account Number referenced in the caption. The statement must
       also be emailed to JoAnn Lucanik at JoAnn.Lucanik@fcc.gov and to
       Pamera Hairston at Pamera.Hairston@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 Indigo Wireless, Inc., 18 Beechnut
       Terrace, Ithaca, NY 14850.

   FEDERAL COMMUNICATIONS COMMISSION

   P. Michele Ellison

   Chief, Enforcement Bureau

                                    APPENDIX

      Indigo Wireless Hearing Aid-Compatible Handset Offerings (M3 rating)


                       Hearing        Hearing                                                              
            Total   Aid-Compatible Aid-Compatible                                                          
  Period   Handsets    Handsets       Handsets    Compliance?                                              
           Offered     Offered        Required                                                             
                                                                                                           
                     (M3 rating)    (M3 rating)                                                            

  January     7           6                           Yes                                                  
   2009                                                                                                    

 February     11          7                                   Yes                                          
   2009                                                                                                    

   March      15          7                                       No                                       
   2009                                                                                                    

   April      16          7                                          No                                    
   2009                                                                                                    

 May 1-14,    16          7              or                                                                
   2009                                                                                                    

    May                             total number                                                           
  15-31,      16          7              of                                                                
   2009                                                                                                    

 June 2009    14          6           offered                               50% or   No                    

 July 2009    14          6        (March 1, 2009                          At least     No                 

  August      14          7                                                 total          Yes             
   2009                            May 14, 2009)                            number                         

 September    13          6                                                handsets            No          
   2009                                                                    offered                         

  October     11          5                                                (May 15,               No       
   2009                                                                     2009 -                         

 November     10          4                                                  31,                     No    
   2009                                                                     2009)                          

 December     11          4                                                                             No 
   2009                                                                                                    


   Tier III carriers are non-Nationwide wireless radio service providers with
   500,000 or fewer subscribers. 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).

   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) of the Rules 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) of the Rules 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).

   These requirements do 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, 25 FCC
   Rcd 11167, 11180-89 P:P: 35-59 (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 3443
   P: 91; 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.

   Indigo Wireless's Hearing Aid Compatibility Status Report (filed January
   15, 2010) ("2009 Report"), at
   http://wireless.fcc.gov/hac_documents/100317/Indigo%20Wireless_189.PDF.

   Indigo Wireless's 2009 Report indicated that the Pantech c810 handset (FCC
   ID JYCC810) is M4/T3 rated, the Sony Ericsson w910 handset (FCC ID
   PY7A3052021) is M3/T3 rated, and the Samsung s5230 (FCC ID A3LGTS5230) is
   M3 rated. Id. Commission records, however, show that these three handsets
   have not been rated for hearing aid compatibility.

   Id. Indigo Wireless's 2009 Report indicated that it offered the required
   number of M3-rated handsets during August 2009 and the required number of
   T3-rated handsets during the 2009 reporting period.

   See Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
   Enforcement Bureau, Federal Communications Commission, to John C. Rigas,
   President, Indigo Wireless, Inc. (September 8, 2010) ("LOI").

   See e-mail from Laura Boyden, Operations Manager, Indigo Wireless, Inc. to
   Kathryn S. Berthot, Chief, Spectrum Enforcement Division, Enforcement
   Bureau, Federal Communications Commission (October 11, 2010) ("LOI
   Response").

   Id. at 1.

   Id. at 1-2.

   Id.

   See Appendix, Indigo Wireless Hearing-Aid Compatible Handset Offerings
   (M3-rated); see also (requiring non-Tier 1 digital wireless service
   providers to ensure that between September 7, 2009 and May 14, 2009, at
   least 50% of the handset models they offered, or at least eight handset
   models, met or exceeded the M3 rating for radio frequency interference).
   These requirements applied to each air interface for which service
   providers offered handsets to consumers. All of Indigo Wireless's handsets
   for the 2009 reporting period operated only over the GSM air interface.

   47 C.F.R. S: 20.19(c)(3)(ii) (requiring non-Tier I digital wireless
   service providers to ensure that between May 15, 2009 and May 14, 2010, 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).

   See Appendix (indicating that between May 15, 2009 and December 31, 2009,
   Indigo Wireless offered between 10 and 16 total handsets, of which only
   four-seven were hearing-aid compatible).

   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 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). In 2008, the Commission 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, 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). The inflation
   adjustment, effective September 2, 2008, applies to violations that occur
   after that date; See 73 Fed. Reg. 44663-5.

   47 U.S.C. S: 503(b)(2)(E). See also 47 C.F.R. S: 1.80(b)(4), Note to
   paragraph (b)(4): Section II. Adjustment Criteria for Section 503
   Forfeitures.

   See The Commission's Forfeiture Policy Statement and Amendment of Section
   1.80 of the Rules to Incorporate the Forfeiture Guidelines,  12 FCC Rcd
   17087 (1997), recon. denied, 15 FCC Rcd 303 (1999) ("Forfeiture Policy
   Statement").

   Forfeiture Policy Statement, 12 FCC Rcd at 17099.

   Id.

   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).

   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.

   Id. at 2.

   See, e.g., Profit Enterprises, Inc., Notice of Apparent Liability for
   Forfeiture, 8 FCC Rcd 2846, 2846 P: 5 (1993), cancelled on other grounds,
   12 FCC Rcd 14999 (1997) (denying the mitigation claim of a
   manufacturer/distributor who thought that the equipment certification and
   marketing requirements were inapplicable, stating that its "prior
   knowledge or understanding of the law is unnecessary to a determination of
   whether a violation existed ... ignorance of the law is [not] a mitigating
   factor"); Lakewood Broadcasting Service, Inc., Memorandum Opinion and
   Order, 37 FCC 2d 437, 438 P: 6 (1972) (denying a mitigation claim of a
   broadcast licensee who asserted an unfamiliarity with the station
   identification requirements, stating that licensees are expected "to know
   and conform their conduct to the requirements of our rules"); Kenneth Paul
   Harris, Sr., Notice of Apparent Liability for Forfeiture, 15 FCC Rcd
   12933, 12935 P: 7 (Enf. Bur. 2000), forfeiture ordered, 15 FCC Rcd 23991
   (Enf. Bur. 2000), (denying a mitigation claim of a broadcast licensee,
   stating that its ignorance of the law did not excuse the unauthorized
   transfer of the station); Maxwell Broadcasting Group, Inc., Memorandum
   Opinion and Order, 8 FCC Rcd 784, 784 P: 2 (MMB 1993), recon. denied,
   Memorandum Opinion and Order, 8 FCC Rcd 4322 (MMB 1993) (denying a
   mitigation claim of a noncommercial broadcast licensee, stating that the
   excuse of "inadverten[ce], due to inexperience and ignorance of the rules
   ... are not reasons to mitigate a forfeiture" for violation of the
   advertisement restrictions).

   See https://fjallfoss.fcc.gov/oetcf/eas/reports/GenericSearch.cfm. The
   hearing aid compatibility ratings information is included on the equipment
   certification for the handset.

   To the extent that Indigo Wireless argues that its failure to offer the
   required number of handsets was not willful, we reject this claim. See LOI
   Response at 1-2. As noted, section 312(f)(1) of the Act provides that "the
   term `willful,' when used with reference to the commission or omission of
   any act, means the conscious or deliberate commission or omission of such
   act, irrespective of any intent to violate any provision of this Act or
   any rule or regulation of the Commission." Indeed, it is well established
   that, in the context of forfeiture actions, "willful" does not require a
   finding that the rule violation was intentional or that the violator was
   aware that it was committing a rule violation. Rather, the term "willful"
   simply requires that the violator knew it was taking or failing to take
   the action in question, irrespective of any intent to violate the
   Commission's rules. See Southern California, 6 FCC Rcd  at 4387-88
   (stating that "inadvertence ... is at best, ignorance of the law, which
   the Commission does not consider a mitigating circumstance" and applying
   the definitions of willful in section 312(f)(1) to forfeiture cases). See
   also Abocom Systems, Inc., Memorandum Opinion and Order, 22 FCC Rcd 7448,
   7451 (Enf. Bur. 2007) (rejecting Abocom's argument that it was only
   "inadvertently noncompliant" and that "its actions were not deliberate or
   intended to violate the rules"); Five Star Parking d/b/a Five Star Taxi
   Dispatch, Forfeiture Order, 23 FCC Rcd 2649, 2651-52 (Enf. Bur., Spectrum
   Enf. Div. 2008) (declining to reduce or cancel forfeiture for late-filed
   renewal based on licensee's administrative error); Domtar Industries,
   Inc., Notice of Apparent Liability for Forfeiture, 21 FCC Rcd 13811, 13815
   (Enf. Bur., Spectrum Enf. Div. 2006) ("Domtar Industries") (same);
   National Weather Networks, Inc., Notice of Apparent Liability for
   Forfeiture, 21 FCC Rcd 3922, 3925 (Enf. Bur., Spectrum Enf. Div. 2006)
   (same).

   See 47 C.F.R. S: 1.80(b)(4), Note to Paragraph (b)(4): Section II.
   Adjustment Criteria for Section 503 Forfeitures (establishing "repeated or
   continuous violation" as an upward adjustment factor).

   While 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, we may consider the fact that Indigo Wireless's
   misconduct occurred over an extended period to place "the violations in
   context, thus establishing the licensee's degree of culpability and the
   continuing nature of the violations." Roadrunner Transportation Inc.,
   Forfeiture Order, 15 FCC Rcd 9669, 9671-72 (2000).  The forfeiture amount
   we propose herein relates only to Indigo Wireless's apparent violations
   that have occurred within the past year.

   47 U.S.C. S: 503(b); 47 C.F.R. S:S: 0.111, 0.311, and 1.80.

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