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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                        )                               
                            File No. EB-09-SE-160       
     In the Matter of   )                               
                            NAL/Acct. No. 201032100010  
     ZTE Corporation    )                               
                            FRN 0009043175              
                        )                               


                  Notice of apparent Liability for forfeiture

   Adopted: January 14, 2010 Released: January 14, 2010

   By the Chief, Spectrum Enforcement Division, Enforcement Bureau:

   I. introduction

     1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
        that ZTE Corporation ("ZTE") apparently willfully and repeatedly
        violated the wireless handset hearing aid compatibility status report
        filing requirements set forth in Section 20.19(i)(1) of the
        Commission's Rules ("Rules") and the public web site posting
        requirements set forth in Section 20.19(h) of the Rules. For these
        apparent violations, we propose a forfeiture in the amount of
        eighteen thousand dollars ($18,000).

   II. BACKGROUND

     2. In the 2003 Hearing Aid Compatibility Order, the Commission adopted
        several measures to enhance the ability of individuals with hearing
        disabilities 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. The Commission further established, for each standard,
        deadlines by which manufacturers and service providers were required
        to offer specified numbers or percentages of digital wireless
        handsets per air interface that are compliant with the relevant
        standard if they did not come under the de minimis exception. In
        February 2008, as part of a comprehensive reconsideration of the
        effectiveness of the hearing aid compatibility rules, the Commission
        released an order that, among other things, adopted new compatible
        handset deployment benchmarks beginning in 2008.

     3. Of primary relevance, the Commission also adopted reporting
        requirements to ensure that it could 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
        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). 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. The Commission also made clear
        that these reporting requirements even apply to manufacturers and
        service providers that fit the de minimis exception. In addition, the
        Commission instituted a requirement that manufacturers and service
        providers with publicly-accessible web sites maintain a list of
        hearing aid-compatible handset models and certain information
        regarding those models on their web sites. The web site postings,
        which must be updated within 30 days of a change in a manufacturer's
        or service provider's offerings, will enable consumers to obtain
        up-to-date hearing aid compatibility information from their service
        providers.

     4. ZTE, a handset manufacturer, failed to file the required reports for
        the periods July 1, 2008 through December 31, 2008 (due January 15,
        2009) and January 1, 2009 through June 30, 2009 (due July 15, 2009).
        ZTE also failed to list available hearing aid-compatible handset
        models on its web site. The Wireless Telecommunications Bureau
        ("WTB") referred ZTE's apparent violations to the Enforcement Bureau
        for action.

     5. On November 4, 2009, the Enforcement Bureau's Spectrum Enforcement
        Division issued a Letter of Inquiry ("LOI") to ZTE USA, Inc. ("ZTE
        USA"), a U.S. subsidiary of ZTE Corporation, to which ZTE USA
        responded on November 25, 2009. In ZTE USA's LOI Response, filed on
        behalf of ZTE, it acknowledged that ZTE did not file the required
        reports. ZTE USA explained that ZTE did not file "due to a mistake in
        understanding the new process." ZTE USA noted that ZTE does provide
        hearing aid compatibility information in the equipment authorization
        test data submitted for each handset. ZTE USA further admitted that
        ZTE did not post the required information on its web site.

   III. DISCUSSION

   A. Failure to File Timely Hearing Aid Compatibility Status Reports

     6. Section 20.19(i)(1) of the Rules requires all handset manufacturers
        to file hearing aid compatibility status reports under the current
        rules initially on January 15, 2009 (covering the six month period
        ending December 31, 2008) and then annually beginning July 15, 2009.
        These reports are necessary to enable the Commission to perform its
        enforcement function and evaluate whether ZTE is in compliance with
        Commission mandates that were adopted to facilitate the accessibility
        of hearing aid-compatible wireless handsets. These reports also
        provide valuable information to the public concerning the technical
        testing and commercial availability of hearing aid-compatible
        handsets.  ZTE did not timely file the reports covering the six month
        periods ending December 31, 2008 and June 30, 2009. Accordingly, we
        find that ZTE failed to timely file the hearing aid compatibility
        status reports due on January 15, 2009 and July 15, 2009 in apparent
        willful and repeated violation of the requirements set forth in
        Section 20.19(i)(1) of the Rules.

   B. Failure to Post Required Information Concerning Hearing Aid-Compatible
   Handset Models on its Web Site

     7. Section 20.19(h) of the Rules requires that, beginning January 15,
        2009, each manufacturer and service provider that operates a
        publicly-accessible web site make available on its web site a list of
        all hearing aid-compatible handset models currently offered, the
        ratings of those models, and an explanation of the rating system. In
        addition, the Commission has stated that any changes to a
        manufacturer's or service provider's offerings must be reflected on
        its public web site listing within 30 days of the change. These web
        site postings provide consumers up-to-date hearing aid compatibility
        information.

     8. ZTE admitted that it failed to list all available hearing
        aid-compatible handset models and the ratings for those models on its
        web site within the required timeframe. ZTE also took no action to
        address this violation until after it received the Division's LOI.
        Accordingly, we find that ZTE apparently willfully and repeatedly
        violated the web site posting requirements set forth in Section
        20.19(h) of the Rules.

   C. Proposed Forfeiture

     9. 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. Under this standard, we conclude that ZTE is
        apparently liable for forfeiture for its failure to timely file the
        required hearing aid compatibility status reports in apparent willful
        and repeated violation of Section 20.19(i)(1) of the Rules, and for
        its failure to post the required information regarding its hearing
        aid-compatible handsets on its web site in apparent willful and
        repeated violation of Section 20.19(h) of the Rules.

    10. The Commission's Forfeiture Policy Statement and Section 1.80(b) of
        the Rules set a base forfeiture amount of $3,000 for the failure to
        file required forms or information. While the base forfeiture
        requirements are guidelines lending some predictability to the
        forfeiture process, the Commission retains the discretion to depart
        from these guidelines and issue forfeitures  on a case-by-case basis,
        under its general forfeiture authority contained in Section 503 of
        the Act. In exercising such discretion, 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."

    11. We have exercised our discretion to set a higher base forfeiture
        amount for violations of the wireless hearing aid compatibility
        reporting requirements. In the American Samoa Telecommunications
        Authority NAL, we found that the status reports are essential to the
        implementation and enforcement of the hearing aid compatibility
        rules. The Commission relies on these reports to provide consumers
        with information regarding the technical specifications and
        commercial availability of hearing aid-compatible digital wireless
        handsets and to hold the digital wireless industry accountable to the
        increasing number of hearing-impaired individuals. We noted that when
        setting an $8,000 base forfeiture for violations of the hearing
        aid-compatible handset labeling requirements, the Commission
        emphasized that individuals with hearing impairments could only take
        advantage of critically important public safety benefits of digital
        wireless services if they had access to accurate information
        regarding hearing aid compatibility features of handsets. We also
        noted that the Commission has upwardly adjusted the base forfeiture
        when noncompliance with filing requirements interferes with the
        accurate administration and enforcement of Commission rules. Because
        the failure to file hearing aid compatibility status reports
        implicates similar public safety and enforcement concerns, we
        exercised our discretionary authority and established a base
        forfeiture amount of $6,000 for failure to file a hearing aid
        compatibility report. Consistent with ASTCA, we believe the
        established $6,000 base forfeiture for each hearing aid compatibility
        reporting violation should apply here, for an aggregate forfeiture of
        $12,000 ($6,000 * 2 reporting violations).

    12. Failure to file these reports, as is the case here, can have an
        adverse impact on the Commission's ability to ensure the commercial
        availability of hearing aid-compatible digital wireless handsets, to
        the detriment of consumers. We do not believe that the circumstances
        presented by the company warrant any downward adjustment of the
        proposed forfeiture amount. It is well established that a violator's
        lack of knowledge or erroneous beliefs are not a mitigating factor
        warranting a forfeiture reduction.  Accordingly, we propose a
        forfeiture of $12,000 against ZTE for apparently willfully and
        repeatedly failing to timely file its January 15, 2009 and July 15,
        2009 hearing aid compatibility status reports in violation of Section
        20.19(i)(1) of the Rules.

    13. Turning to the violation of the web posting requirements, no base
        forfeiture amount has previously been established for violation of
        Section 20.19(h) 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. As noted above, the base forfeiture amount for "failure to
        file required forms or information" is $3,000. In determining the
        appropriate forfeiture amount for violation of the web site
        information posting requirements, we take into account that these
        requirements are "essential to the proper functioning of our hearing
        aid compatibility rules" and serve to increase the availability of
        up-to-date hearing aid compatibility information to consumers and
        service providers. Thus, we view a manufacturer's or service
        provider's failure to list the required hearing aid-compatible
        handset information on its web site as similar to its failure to
        submit the required hearing aid compatibility status report.

    14. In particular, we find that the web site may be the primary means
        through which consumers obtain information, and that the updated
        information between status reports is likely to be critical to both
        consumers and service providers. As the Commission noted in the 2008
        Hearing Aid Compatibility First Report and Order, information
        provided in the status reports will inevitably become dated over the
        course of a year. The web site postings, which must be updated within
        30 days of a change in a manufacturer's or service provider's
        offerings, will enable consumers to obtain up-to-date hearing aid
        compatibility information from their service providers and will also
        enable service providers to readily obtain up-to-date information
        from their manufacturer suppliers. Accordingly, the same
        considerations that lead us to increase the base forfeitures for
        hearing aid compatibility status reporting violations also apply to
        the requirement for web posting. We therefore establish $6,000 as the
        base forfeiture for violation of Section 20.19(h).

    15. As noted above, ZTE acknowledged that it did not post the required
        information on its web site within the required timeframe and did not
        correct this failure until after it received the Division's LOI, and
        ZTE presented no mitigating factors in its LOI Response justifying a
        downward adjustment to the $6,000 base forfeiture. Accordingly, we
        propose a forfeiture of $6,000 against ZTE for apparently willfully
        and repeatedly failing to list its hearing aid-compatible models on
        its public web site in violation of Section 20.19(h) of the Rules.

    16. Accordingly, we propose a total forfeiture of $18,000 against ZTE for
        its apparent willful and repeated violations of Sections 20.19(i)(1)
        and 20.19(h) of the Rules.

   IV. ORDERING clauses

    17. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the
        Act, and Section 1.80 of the Rules, ZTE Corporation IS NOTIFIED of
        its APPARENT LIABILITY FOR A FORFEITURE in the amount of eighteen
        thousand dollars ($18,000) for failing to file its hearing aid
        compatibility status reports in apparent willful and repeated
        violation of the requirements set forth in Section 20.19(i)(1) of the
        Rules, and for failing to post required information concerning its
        hearing aid-compatible handset models on its public web site in
        apparent willful and repeated violation of Section 20.19(h) of the
        Rules.

    18. 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, ZTE Corporation SHALL PAY the full amount
        of the proposed forfeiture or SHALL FILE a written statement seeking
        reduction or cancellation of the proposed forfeiture.

    19. 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.
        ZTE will also send electronic notification on the date said payment
        is made to Susan.Stickley@fcc.gov and Ricardo.Durham@fcc.gov.

    20. The written statement seeking reduction or cancellation of the
        proposed forfeiture, if any, must include a detailed factual
        statement supported by appropriate documentation and affidavits
        pursuant to Sections 1.80(f)(3) and 1.16 of the Rules. The written
        statement must be mailed to the Office of the Secretary, Federal
        Communications Commission, 445 12th Street, S.W., Washington, D.C.
        20554, ATTN: Enforcement Bureau - Spectrum Enforcement Division, and
        must include the NAL/Acct. No. referenced in the caption. The
        statement should also be emailed to Ricardo Durham at
        Ricardo.Durham@fcc.gov and Susan Stickley at Susan.Stickley@fcc.gov.

    21. 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.

    22. 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 Mr. Yin Yimin, President
        and CEO, ZTE Corporation, ZTE Plaza, Keji Road South, Hi-Tech
        Industrial Park, Nanshan District, Shenzhen, The People's Republic of
        China, and to Mr. Xiang-Yang Jiang, CEO, ZTE USA, Inc., 2425 North
        Central Expressway, Suite 323, Richardson, Texas 75080.

   FEDERAL COMMUNICATIONS COMMISSION

   Kathryn S. Berthot

   Chief, Spectrum Enforcement Division

   Enforcement Bureau

   47 C.F.R. S:S: 20.19(i)(1) and 20.19(h).

   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, 47
   U.S.C. S: 610(b)(2)(C). See Section 68.4(a) of the Commission's Rules
   Governing Hearing Aid-Compatible Telephones, Report and Order, 18 FCC Rcd
   16753, 16787 P: 89 (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) ("Hearing Aid Compatibility
   Reconsideration Order").

   See Hearing Aid Compatibility Order, 18 FCC Rcd at 16777 P: 56; 47 C.F.R.
   S:S: 20.19(b)(1) and (2).

   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 Dispatch Enhanced Network (iDEN)
   and Wideband Code Division Multiple Access (WCDMA) a/k/a Universal Mobile
   Telecommunications System (UMTS).

   See Hearing Aid Compatibility Order, 18 FCC Rcd at 16780 P: 65; 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 deployment requirements, and manufacturers or mobile 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).
   This provision was affirmed in Amendment of the Commission's Rules
   Governing Hearing Aid-Compatible Mobile Handsets, First Report and Order,
   23 FCC Rcd 3406, 3435 P: 72 (2008) ("Hearing Aid Compatibility First
   Report and Order"), Order on Reconsideration and Erratum, 23 FCC Rcd 7249
   (2008).

   Id., Hearing Aid Compatibility First Report and Order.

   See Hearing Compatibility First Report and Order, 23 FCC Rcd at 3443 P:
   91.

   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).

   See Hearing Aid Compatibility First Report and Order, 23 FCC Rcd at 3445
   P:P: 97-99.

   Id. at 3446 P: 99.

   Id. at 3450 P: 112.

   Id.

   See Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
   Enforcement Bureau, Federal Communications Commission to Mr. Xiang-Yang
   Jiang, CEO, ZTE USA, Inc. (November 4, 2009).

   See Letter from Xiang-Yang Jiang, CEO, ZTE USA, Inc. to Susan M. Stickley,
   Esq., Spectrum Enforcement Division, Enforcement Bureau, Federal
   Communications Commission (November 25, 2009) ("LOI Response").

   Id. at 1. ZTE filed the report due July 15, 2009 on December 1, 2009, but
   to date has not filed the report due January 15, 2009.

   Id.

   Id. at 2. Following receipt of the Division's LOI, ZTE USA posted the
   required information for its hearing aid-compatible handset models on its
   web site at www.zteusa-support.com.

   47 C.F.R. S: 20.19(i)(1).

   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).

   Section 312(f)(2) defines "repeated" as "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). As with the definition of
   "willful," the Commission has interpreted the term to apply to forfeiture
   proceedings. See Southern California, supra.

   47 C.F.R. S: 20.19(i)(1).

   See Hearing Compatibility First Report and Order, 23 FCC Rcd at 3450 P:
   112.

   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 P: 4 (2002).

   47 C.F.R. S: 20.19(i)(1).

   47 C.F.R. S: 1.80(b).

   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).

   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 American Samoa Telecommunications Authority, Notice of Apparent
   Liability for Forfeiture, 23 FCC Rcd 16432 (Enf. Bur., Spectrum Enf. Div.
   2008), response pending ("ASTCA").

   See ASTCA, 23 FCC Rcd at 16436-7 P: 10.

   Id.

   Id.

   Id.

   See, e.g., Profit Enterprises, Inc., 8 FCC Rcd 2846, 2846 P: 5 (1993)
   (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., 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., 15 FCC Rcd 12933, 12935 P: 7 (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., 8 FCC Rcd 784, 784 P: 2 (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).

   47 C.F.R. S: 20.19(i)(1).

   See Forfeiture Policy Statement, 12 FCC Rcd at 17099.

   Id.

   47 C.F.R. S: 1.80(b).

   See Hearing Compatibility First Report and Order, 23 FCC Rcd at 3450 P:
   112.

   Id.

   Id.

   In this regard, we note that each manufacturer and service provider is
   required to continuously maintain the required information concerning its
   hearing aid-compatible handset models on its web site and to update the
   web sites within 30 days of a change in its handset offerings.

   47 C.F.R. S: 20.19(h).

   (Continued from previous page ...)

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   Federal Communications Commission DA 10-80

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   Federal Communications Commission DA 10-80