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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                    )                            
                                                                 
                                    )                            
                                        File No.: EB-07-SE-281   
     In the Matter of               )                            
                                        Acct. No.: 201132100031  
     Cincinnati Bell Wireless LLC   )                            
                                        FRN: 0003010493          
                                    )                            
                                                                 
                                    )                            


                                     ORDER

   Adopted: June 9, 2011 Released: June 9, 2011

   By the Chief, Enforcement Bureau:

    1. In this Order, we adopt the attached Consent Decree entered into
       between the Enforcement Bureau ("Bureau") and Cincinnati Bell Wireless
       LLC ("CBW"). The Consent Decree terminates an investigation initiated
       by the Bureau regarding CBW's compliance with section 20.19(d)(2) of
       the Commission's rules pertaining to the deployment of digital
       wireless hearing aid-compatible handsets.

    2. The Bureau and CBW have negotiated the terms of a Consent Decree that
       would resolve this matter. A copy of the Consent Decree is attached
       hereto and incorporated by reference.

    3. After reviewing the terms of the Consent Decree and evaluating the
       facts before us, we find that the public interest would be served by
       adopting the Consent Decree and terminating the investigation.

    4. In the absence of material new evidence relating to this matter, we
       conclude that our investigation raises no substantial or material
       questions of fact as to whether CBW possesses the basic
       qualifications, including those related to character, to hold or
       obtain any Commission license or authorization.

    5. Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the
       Communications Act of 1934, as amended, and sections 0.111 and 0.311
       of the Rules, the Consent Decree attached to this Order IS ADOPTED.

    6. IT IS FURTHER ORDERED that the above-captioned investigation IS
       TERMINATED.

    7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
       shall be sent by first class mail and certified mail, return receipt
       requested, to Jouett K. Brenzel, Corporate Counsel, Cincinnati Bell
       Wireless LLC, 221 E. Fourth Street, Suite 103-1280, Cincinnati, OH
       45202.

   FEDERAL COMMUNICATIONS COMMISSION

   P. Michele Ellison

   Chief, Enforcement Bureau

                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                    )                            
                                                                 
                                    )   File No.: EB-07-SE-281   
     In the Matter of                                            
                                    )   Acct. No.: 201132100031  
     Cincinnati Bell Wireless LLC                                
                                    )   FRN: 0003010493          
                                                                 
                                    )                            


                                 CONSENT DECREE

   The Enforcement Bureau of the Federal Communications Commission and
   Cincinnati Bell Wireless LLC, by their authorized representatives, hereby
   enter into this Consent Decree for the purpose of terminating the
   Enforcement Bureau's investigation into possible violations of section
   20.19(d)(2) of the Commission's rules regarding the deployment of digital
   wireless hearing aid-compatible handsets.

   I. DEFINITIONS

    1. For the purposes of this Consent Decree, the following definitions
       shall apply:

    a. "Act" means the Communications Act of 1934, as amended, 47 U.S.C. S:
       151 et seq.

    b. "Adopting Order" means an order of the Bureau adopting the terms of
       this Consent Decree without change, addition, deletion, or
       modification.

    c. "Bureau" means the Enforcement Bureau of the Federal Communications
       Commission.

    d. "CBW" means Cincinnati Bell Wireless LLC and its
       predecessors-in-interest and successors-in-interest.

    e. "Commission" and "FCC" mean the Federal Communications Commission and
       all of its bureaus and offices.

    f. "Compliance Plan" means the compliance obligations and compliance
       program described in this Consent Decree at paragraph 8 hereof.

    g. "Covered Employees" means all employees and agents of CBW who perform
       duties that trigger or may trigger compliance-related responsibilities
       under section 20.19 of the Rules and other Rules, Commission orders or
       statutory requirements governing wireless hearing aid-compatible
       handsets, including the design, selection or acquisition of wireless
       handsets, or the marketing or distribution of such handsets to
       consumers in the United States.

    h. "Effective Date" means the date on which the Bureau releases the
       Adopting Order.

    i. "Investigation" means the investigation commenced by the Bureau's
       August 13, 2007 letter of inquiry regarding CBW's deployment of
       digital wireless hearing aid-compatible handsets.

    j. "Parties" means CBW and the Bureau, each of which is a "Party".

    k. "Rules" means the Commission's regulations found in Title 47 of the
       Code of Federal Regulations.

   II. BACKGROUND

    2. Congress enacted the Hearing Aid Compatibility Act of 1988 to provide
       access to telecommunications services for individuals with hearing
       disabilities in recognition that telecommunications services are an
       essential component of our daily lives. 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 a
       technical standard for radio frequency interference - the "U3" (now
       "M3") rating - that would enable acoustic coupling between digital
       wireless phones and hearing aids operating in acoustic coupling
       (a.k.a. microphone) mode, and a separate standard - the "U3T" (now
       "T3") rating - for handset production of an audio signal-based
       magnetic field to enable inductive coupling with hearing aids
       operating in telecoil mode. For each of these standards, the
       Commission further established 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 unless the de minimis exception
       applies. For example, service providers not covered by the de minimis
       exception  were required to make available at least two handset models
       that met, at a minimum, the U3T ("T3") rating for inductive coupling
       capability by September 18, 2006.

    3. 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. 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 until November 17, 2006, and then
       annually thereafter through the fifth year of implementation until
       November 17, 2008.

    4. CBW reported in its November 17, 2006 hearing aid compatibility status
       report that it was offering two or more handsets that met the
       inductive coupling standard. On August 13, 2007, the Bureau's Spectrum
       Enforcement Division ("Division") issued a letter of inquiry ("LOI")
       to CBW. The LOI directed CBW to submit a sworn written response to a
       series of questions related to CBW's compliance with section
       20.19(d)(2) of the Rules regarding the inductive coupling hearing aid
       compatibility deployment requirements. CBW responded to the LOI on
       August 23, 2007. In its LOI Response, CBW stated that after filing its
       November 17, 2006 Annual Report, it came to CBW's attention that the
       Nokia 6126 handset model it had offered since August 16, 2006, did not
       meet the inductive coupling requirements. CBW explained that the
       compliant handset model was the Nokia 6126h model. CBW indicated that
       in February 2007, it began offering another handset that met the
       inductive coupling requirements.

   III. TERMS OF AGREEMENT

    5. Adopting Order. The Parties agree that the provisions of this Consent
       Decree shall be subject to final approval by the Bureau by
       incorporation of such provisions by reference in the Adopting Order
       without change, addition, modification, or deletion.

    6. Jurisdiction. CBW agrees that the Bureau has jurisdiction over it and
       the matters contained in this Consent Decree and has the authority to
       enter into and adopt this Consent Decree.

    7. Effective Date; Violations. The Parties agree that this Consent Decree
       shall become effective on the Effective Date as defined herein. Upon
       release, the Adopting Order and this Consent Decree shall have the
       same force and effect as any other order of the Bureau. Any violation
       of the Adopting Order or of the terms of this Consent Decree shall
       constitute a separate violation of a Bureau order, entitling the
       Bureau to exercise any rights and remedies attendant to the
       enforcement of a Commission order.

    8. Termination of Investigation. In express reliance on the covenants and
       representations in this Consent Decree and to avoid further
       expenditure of public resources, the Bureau agrees to terminate the
       Investigation. In consideration for the termination of said
       Investigation, CBW agrees to the terms, conditions, and procedures
       contained herein. The Bureau further agrees that in the absence of new
       material evidence, the Bureau will not use the facts developed in this
       Investigation through the Effective Date, or the existence of this
       Consent Decree, to institute on its own motion any new proceeding,
       formal or informal, or take any action on its own motion against CBW
       concerning the matters that were the subject of the Investigation. The
       Bureau also agrees that in the absence of new material evidence it
       will not use the facts developed in this Investigation through the
       Effective Date, or the existence of this Consent Decree, to institute
       on its own motion any proceeding, formal or informal, or take any
       action on its own motion against CBW with respect to CBW's basic
       qualifications, including its character qualifications, to be a
       Commission licensee or to hold Commission licenses or authorizations.

    9. Compliance Plan. For purposes of settling the matters set forth
       herein,  CBW agrees that it shall within sixty (60) calendar days
       after the Effective Date (i) develop and implement a Compliance Plan
       related to future compliance with the Act, the Rules, and the
       Commission's orders, including section 20.19 of the Rules, and other
       Rules, Commission orders and statutory requirements governing wireless
       hearing aid-compatible handsets; (ii) establish standard, internal
       operating procedures and policies ("Operating Procedures") that CBW
       shall follow to ensure compliance with section 20.19 of the Rules and
       other hearing aid compatibility requirements; and (iii) incorporate
       such Operating Procedures into a Compliance Manual pursuant to
       paragraph 8(c) hereof. The Compliance Plan shall include, at a
       minimum, the following components:

   (a) Regulatory Steering Committee. CBW has established, and shall
   maintain, a Regulatory Steering Committee to ensure compliance with a
   variety of federal and state regulatory requirements and the terms of this
   Consent Decree. The Regulatory Steering Committee shall serve as a
   resource for resolving questions related to the Compliance Plan and CBW's
   compliance with applicable hearing aid compatibility requirements, and
   shall act as a central point of contact for the dissemination of the
   Commission's hearing aid compatibility requirements throughout the
   company. The Regulatory Steering Committee, with input from the Compliance
   Officer, shall oversee the development and implementation of the Training
   Program and shall monitor changes to the Commission's hearing aid
   compatibility rules to ensure that those changes are documented in the
   Compliance Manual discussed in paragraph 8(c) and disseminated
   appropriately to all Covered Employees, as defined herein. The Regulatory
   Steering Committee shall include representatives from CBW's legal and
   regulatory departments.

   (b) Compliance Officer. Within thirty (30) calendar days after the
   Effective Date, CBW shall designate a senior corporate manager to serve as
   a Compliance Officer. The Compliance Officer shall be responsible for
   administering the Compliance Plan and ensuring compliance with this
   Consent Decree, shall be familiar with the FCC's requirements governing
   wireless hearing aid-compatible handsets and other relevant Rules, and
   shall report to the Regulatory Steering Committee.

   (c) Compliance Manual. The Compliance Officer shall develop and distribute
   a Compliance Manual to all Covered Employees. The Compliance Manual shall
   (i) describe the Commission's handset deployment and other wireless
   hearing aid compatibility requirements; and (ii) set forth the relevant
   Operating Procedures that CBW will follow to ensure compliance with such
   requirements. CBW shall periodically review and, to the extent necessary,
   revise the Compliance Manual to ensure that it remains current and
   complete. Any such revisions shall be disseminated promptly to all Covered
   Employees.

   (d) Training Program. Within sixty (60) calendar days after the Effective
   Date, CBW shall establish and implement a Training Program on compliance
   with the Commission's digital wireless hearing-aid compatible handset
   deployment requirements. The Training Program shall be provided to all
   Covered Employees. Any person who becomes a Covered Employee at any time
   after the initial training session shall be provided such training within
   thirty (30) calendar days after the date such person becomes a Covered
   Employee. CBW shall conduct the Training Program on an annual basis, and
   shall periodically review and, to the extent necessary, revise the
   Training Program to ensure that it remains current and complete, and to
   enhance its effectiveness.

   (e) Operating Procedures for the Availability of Hearing Aid Compatible
   Handsets. CBW's Operating Procedures shall include internal procedures and
   policies specifically designed to ensure that CBW offers the requisite
   number or percentage of hearing aid compatible handsets to consumers as
   required by the Rules, including the following:

   (i) CBW shall develop a compliance checklist that describes the
   Commission's hearing aid compatibility requirements and the steps that a
   Covered Employee will follow to ensure that the inclusion of a new handset
   model, or discontinuance of an existing handset offering, will not result
   in a violation of the Commission's digital wireless hearing aid-compatible
   handset deployment requirements.

   (ii) Prior to ordering any new handset model, or discontinuing any
   existing handset offering, the Covered Employee responsible for
   completing, approving or authorizing such action must complete, sign, and
   date the compliance checklist indicating whether the affected handset is
   hearing aid-compatible and whether the offering of such handset, or the
   discontinuance of such handset offering, by CBW will result in a violation
   of the Commission's digital wireless hearing aid-compatible handset
   deployment requirements. CBW shall utilize such compliance checklists to
   prepare its Hearing Aid Compatibility Reports on FCC Form 655, and shall
   retain such checklists for a period of two (2) years after the Effective
   Date, or until the FCC Form 655 for the period covered by such checklist
   has been filed, whichever is later.

   (f) Reporting Non-Compliance. CBW shall report any non-compliance with
   section 20.19 of the Rules, and other Rules, Commission orders or
   statutory requirements governing wireless hearing aid-compatible handsets
   within fifteen (15) calendar days after the discovery of such
   non-compliance. Such reports shall include a detailed explanation of (i)
   each instance of non-compliance; (ii) the steps that CBW has taken or will
   take to remedy such non-compliance; (iii) the schedule on which such
   remedial actions will be taken; and (iv) the steps that CBW has taken or
   will take to prevent the recurrence of any such non-compliance. All
   reports of non-compliance shall be submitted to the Chief, Spectrum
   Enforcement Division, Enforcement Bureau, Federal Communications
   Commission, 445 12th Street, S.W. Washington, D.C. 20554, with a copy
   submitted electronically to Jennifer Burton at Jennifer.Burton@fcc.gov and
   to JoAnn Lucanik at JoAnn.Lucanik@fcc.gov.

   (g) Compliance Reports. CBW shall file Compliance Reports with the
   Commission ninety (90) calendar days after the Effective Date, twelve (12)
   months after the Effective Date, and twenty-four (24) months after the
   Effective Date.

       i. Each compliance report shall include a detailed description of
          CBW's efforts during the relevant period to comply with the terms
          and conditions of this Consent Decree and the Commission's
          requirements governing wireless hearing aid-compatible handsets. In
          addition, each Compliance Report shall include a certification by
          the Compliance Officer, as an agent of and on behalf of CBW,
          stating that the Compliance Officer has personal knowledge that CBW
          (A) has established and implemented the Compliance Plan; (B) has
          utilized the Operating Procedures since the implementation of the
          Compliance Plan; and (C) is not aware of any instances of
          non-compliance with the terms and conditions of this Consent
          Decree, including the reporting obligations set forth in paragraph
          8(f) hereof.

       ii. The certification shall be accompanied by a statement explaining
           the basis for the Compliance Officer's certification and must
           comply with section 1.16 of the Rules and be subscribed to as true
           under penalty of perjury in substantially the form set forth
           therein.

       iii. If the Compliance Officer cannot provide the requisite
            certification, the Compliance Officer, as an agent of and on
            behalf of CBW, shall provide the Commission with a detailed
            explanation of (A) each instance of non-compliance; (B) the steps
            that CBW has taken or will take to remedy such non-compliance,
            including the schedule on which proposed remedial actions will be
            taken; and (C) the steps that CBW has taken or will take to
            prevent the recurrence of any such non-compliance, including the
            schedule on which such preventive action will be taken.

       iv. All Compliance Reports shall be submitted to Chief, Spectrum
           Enforcement Division, Enforcement Bureau, Federal Communications
           Commission, 445 12th Street, S.W., Washington, D.C. 20554, with a
           copy submitted electronically to Jennifer Burton at
           Jennifer.Burton@fcc.gov and to JoAnn Lucanik at
           JoAnn.Lucanik@fcc.gov.

   (h) Termination Date. Unless otherwise stated, the requirements of
   paragraph 8 of the Consent Decree shall expire twenty-four (24) months
   after the Effective Date.

   10. Section 208 Complaints; Subsequent Investigations. Nothing in this
       Consent Decree shall prevent the Commission or its delegated authority
       from adjudicating complaints filed pursuant to section 208 of the Act
       against CBW or its affiliates for alleged violations of the Act, or
       for any other type of alleged misconduct, regardless of when such
       misconduct took place. The Commission's adjudication of any such
       complaint will be based solely on the record developed in that
       proceeding. Except as expressly provided in this Consent Decree, this
       Consent Decree shall not prevent the Commission from investigating new
       evidence of noncompliance by CBW with the Act, the Rules, or
       Commission orders.

   11. Voluntary Contribution. CBW agrees that it will make a voluntary
       contribution to the United States Treasury in the amount of thirty
       thousand dollars ($30,000.00). The payment must be made within thirty
       (30) calendar days after the Effective Date. The payment must be made
       by check or similar instrument, payable to the order of the Federal
       Communications Commission. The payment must include the Account Number
       and FRN referenced in the caption to the Adopting Order. 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 Account number in block number 23A (call
       sign/other ID), and enter the letters "FORF" in block number 24A
       (payment type code). CBW shall also send electronic notification to
       Jennifer Burton at Jennifer.Burton@fcc.gov and to JoAnn Lucanik at
       JoAnn.Lucanik@fcc.gov on the date said payment is made.

   12. Waivers. CBW waives any and all rights it may have to seek
       administrative or judicial reconsideration, review, appeal or stay, or
       to otherwise challenge or contest the validity of this Consent Decree
       and the Adopting Order, provided the Bureau issues an Adopting Order
       adopting the Consent Decree without change, addition, modification, or
       deletion. CBW shall retain the right to challenge Commission
       interpretation of the Consent Decree or any terms contained herein. If
       either Party (or the United States on behalf of the Commission) brings
       a judicial action to enforce the terms of the Adopting Order, neither
       CBW nor the Commission shall contest the validity of the Consent
       Decree or the Adopting Order, and CBW shall waive any statutory right
       to a trial de novo. CBW hereby agrees to waive any claims it may have
       under the Equal Access to Justice Act, 5 U.S.C. S: 504 and 47 C.F.R.
       S: 1.1501 et seq., relating to the matters addressed in this Consent
       Decree.

   13. Invalidity. In the event that this Consent Decree in its entirety is
       rendered invalid by any court of competent jurisdiction, it shall
       become null and void and may not be used in any manner in any legal
       proceeding.

   14. Subsequent Rule or Order. The Parties agree that if any provision of
       the Consent Decree conflicts with any subsequent Rule or order adopted
       by the Commission (except an order specifically intended to revise the
       terms of this Consent Decree to which CBW does not expressly consent)
       that provision will be superseded by such Commission Rule or order.

   15. Successors and Assigns. CBW agrees that the provisions of this Consent
       Decree shall be binding on its successors, assigns, and transferees.

   16. Final Settlement. The Parties agree and acknowledge that this Consent
       Decree shall constitute a final settlement between the Parties with
       respect to the matters set forth herein. The Parties further agree
       that this Consent Decree does not constitute either an adjudication on
       the merits or a factual or legal finding or determination regarding
       any compliance or noncompliance with the requirements of the Act or
       the Rules and Commission's orders.

   17. Modifications. This Consent Decree cannot be modified without the
       advance written consent of both Parties.

   18. Paragraph Headings. The headings of the paragraphs in this Consent
       Decree are inserted for convenience only and are not intended to
       affect the meaning or interpretation of this Consent Decree.

   19. Authorized Representative. The individual signing this Consent Decree
       on behalf of CBW represents and warrants that he is authorized by CBW
       to execute this Consent Decree and to bind CBW to the obligations set
       forth herein. The FCC signatory represents that she is signing this
       agreement in her official capacity and that she is authorized to
       execute this Consent Decree.

   20. Counterparts. This Consent Decree may be signed in any number of
       counterparts (including by facsimile), each of which, when executed
       and delivered, shall be an original, and all of which counterparts
       together shall constitute one and the same fully executed instrument.

   ________________________________

   P. Michele Ellison

   Chief

   Enforcement Bureau

   ________________________________

   Date

   ______________________________

   Christopher J. Wilson

   Vice President, General Counsel & Secretary

   Cincinnati Bell Wireless LLC

   ______________________________

   Date

   47 C.F.R. S: 20.19(d)(2).

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

   47 C.F.R. S:S: 0.111, 0.311.

   47 C.F.R. S: 20.19(d)(2).

   Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
   Enforcement Bureau, Federal Communications Commission, to Jouett K.
   Brenzel, Esq., Cincinnati Bell Wireless LLC (August 13, 2007).

   Pub. L. No. 100-394, 102 Stat. 976 (1988), codified at section
   710(b)(2)(C) of the Act, 47 U.S.C. S: 610(b)(2)(C).

   See Section 68.4 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); Order on Reconsideration and
   Further Notice of Proposed Rulemaking, 20 FCC Rcd 11221 (2005).

   See Hearing Aid Compatibility Order, 18 FCC Rcd at 16777 P: 56; 47 C.F.R.
   S: 20.19(b)(1),(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 Digital 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: 20.19(c), (d). The de minimis exception established in the 2003 Hearing
   Aid Compatibility Order  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). Subsequent amendments to
   the de minimis exception do not apply to the instant case.

   See Hearing Aid Compatibility Order, 18 FCC Rcd at 16780 P: 71; 47 C.F.R.
   S: 20.19(c)(2)(i)(A).

   See Hearing Aid Compatibility Order, 18 FCC Rcd at 16787 P: 89.

   Id.; 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 LOI Response at 1-2.

   See supra note 2.

   See Letter from Jouett K. Brenzel, Corporate Counsel, Cincinnati Bell, to
   Kathryn S. Berthot, Chief, Spectrum Enforcement Division, Enforcement
   Bureau, Federal Communications Commission (Aug. 23, 2007) ("LOI
   Response").

   See LOI Response at 2.

   Id. This is consistent with the Bureau's understanding that when the new
   hearing aid compatibility requirements took effect in September 2006,
   there was some confusion among carriers that certain handset models met
   the inductive coupling requirements, when in fact they only met the
   acoustic coupling requirements.

   See LOI Response at 2.

   Federal Communications Commission DA 11-1002

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   Federal Communications Commission DA 11-1002

   Federal Communications Commission DA 11-1002

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   Federal Communications Commission DA 11-1002