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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                       )                                
                                                                        
                                       )                                
                                           File No.: EB-03-TC-144       
     In the Matter of                  )                                
                                           NAL/Acct. No.: 200832170005  
     See Through Windows & Doors LLC   )                                
                                           FRN: 0017132275              
                                       )                                
                                                                        
                                       )                                


                                FORFEITURE ORDER

   Adopted: January 28, 2011 Released: January 28, 2011

   By the Chief, Enforcement Bureau:

   I. INTRODUCTION

    1. In this Forfeiture Order ("Order"), we issue a monetary forfeiture in
       the amount of $20,000 against See Through Windows & Doors LLC ("See
       Through Windows") for willful and repeated violations of section
       64.1200(c)(2) of the Commission's rules, by making telephone
       solicitations to two residential telephone consumers who had
       registered their telephone numbers on the National Do-Not-Call
       Registry.

   II. BACKGROUND AND DISCUSSION

    2. Section 64.1200(c)(2) of the Commission's rules generally prohibits
       initiating telephone solicitations to residential telephone numbers
       that are contained in the National Do-Not-Call Registry. Pursuant to
       section 503(b)(5) of the Act, the Enforcement Bureau ("Bureau") issued
       a citation to See Through Windows on July 2, 2004,  in response to one
       or more consumer complaints alleging that See Through Windows had
       initiated telephone solicitations to residential telephone consumers
       who had registered their telephone numbers on the National Do-Not-Call
       Registry. See Through Windows informed the Bureau that technical
       problems prevented See Through Windows from accessing the Registry and
       that it would correct this issue. Thereafter, the Commission staff
       sent letters of inquiry to See Through Windows to further investigate
       the alleged violations, and See Through Windows responded.

    3. Subsequent to the Bureau issuing its citation to See Through Windows,
       the Commission received two complaints from consumers alleging that
       See Through Windows had again initiated telephone solicitations to
       residential telephone numbers that the consumers had registered on the
       national Do-Not-Call Registry. These solicitations, which occurred
       after the Bureau's citation, resulted in the Bureau, pursuant to
       section 503(b) of the Act, issuing a Notice of Apparent Liability
       ("NAL") against See Through Windows on November 16, 2007 in the amount
       of $20,000.  The NAL ordered See Through Windows either to pay the
       proposed forfeiture amount within thirty days or to submit evidence or
       arguments in response to the NAL to show that no forfeiture should be
       imposed or that some lesser amount should be assessed.

    4. On December 17, 2007, See Through Windows responded to the NAL,
       seeking to reduce or cancel the proposed forfeiture, claiming the two
       complainants' names and telephone numbers did not appear on its call
       sheets. See Through Windows argued that because the complainants'
       names and telephone numbers were not found in its records, a call
       center representative may have misdialed the numbers. Even if true,
       these facts do not indicate that See Through Windows did not violate
       our do-not-call rules. The rules do excuse those who do not comply
       with them as a result of error, but only if the violator shows that as
       part of its routine business practices, it, among other things: (A)
       has established and implemented written procedures to comply with our
       do-not-call rules; (B) has trained its personnel and others in those
       procedures; (C) has maintained and recorded a list of telephone
       numbers that the seller may not contact; (D) uses a process to prevent
       telephone solicitations to telephone numbers on the Registry,
       employing a version of the Registry that it obtained no more than 31
       days prior to the date any call is made, and maintains records
       documenting this process; and (E) uses a process to ensure that it
       does not sell, rent, lease, buy, or use the Registry for any purpose
       except compliance with our rules or similar state or federal laws. 
       See Through Windows has failed to demonstrate that it has satisfied
       these criteria, and otherwise to identify facts or circumstances to
       persuade us that there is a basis for modifying or cancelling the
       proposed forfeiture. Based on the information before us, we hereby
       impose a total forfeiture of $20,000 for See Through Windows's willful
       and repeated violation of section 64.1200(c)(2) of the Commission's
       rules.

   III. ORDERING CLAUSES

    5. Accordingly, IT IS ORDERED, pursuant to section 503(b) of the
       Communications Act of 1934, as amended, 47 U.S.C. S: 503(b), and
       section 1.80(f)(4) of the Commission's rules, 47 C.F.R. S: 1.80(f)(4),
       and under authority delegated by sections 0.111, 0.311 of the
       Commission's rules, 47 C.F.R. S:S: 0.111, 0.311, that See Through
       Windows & Doors LLC IS LIABLE FOR A MONETARY FORFEITURE to the United
       States Government in the sum of $20,000 for willfully and repeatedly
       violating section 64.1200(c)(2) of the Commission's rules, 47 C.F.R.
       S: 64.1200(c)(2).

    6. Payment of the forfeiture shall be made in the manner provided for in
       section 1.80 of the Commission's rules within thirty (30) days of the
       release of this Order. If the forfeiture is not paid within the period
       specified, the case may be referred to the Department of Justice for
       collection pursuant to section 504(a) of the Act. Payment of the
       forfeiture must be made by check or similar instrument, payable to the
       order of the Federal Communications Commission. The payment must
       include the NAL/Account Number and FRN referenced above. Payment by
       check or money order may be mailed to Federal Communications
       Commission, P.O. Box 979088, St. Louis, MO 63197-9000. Payment by
       overnight mail may be sent to U.S. Bank - Government Lockbox #979088,
       SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101. Payment by
       wire transfer may be made to ABA Number 021030004, receiving bank
       TREAS/NYC, and account number 27000001. For payment by credit card, an
       FCC Form 159 (Remittance Advice) must be submitted.  When completing
       the FCC Form 159, enter the NAL/Account number in block number 23A
       (call sign/other ID), and enter the letters "FORF" in block number 24A
       (payment type code). See Through Windows & Doors LLC shall also send
       electronic notification on the date said payment is made to
       Johnny.Drake@fcc.gov. 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.

    7. IT IS FURTHER ORDERED that a copy of the Forfeiture Order shall be
       sent by First Class mail and certified mail return receipt requested
       to See Through Windows & Doors LLC, See Through Windows & Doors LLC,
       See Thru Windows LLC 3101 Hubbard Road, Landover, MD 20785; See
       Through Windows & Doors LLC, 11132a Rockville Pike, Rockville, MD
       20852; and Johanson Berenson LLP, Attorneys and Counselors at Law,
       1146 Walker Road, Suite C, Great Falls, VA 22066.

   FEDERAL COMMUNICATIONS COMMISSION

   P. Michele Ellison

   Chief, Enforcement Bureau

   47 C.F.R. S: 64.1200(c)(2).

   There are certain limited exceptions to this rule, see 47 C.F.R. S:
   64.1200(c)(2)(i) - (iii), but none of them apply here.

   47 U.S.C. S: 503(b)(5) (authorizing the Commission to issue citations to
   persons who do not hold a license, permit, certificate or other
   authorization issued by the Commission or an applicant for any of those
   listed instrumentalities for violations of the Act or of the Commission's
   rules and orders).

   Citation from Kurt A. Schroeder, Deputy Chief, Telecommunications
   Consumers Division, Enforcement Bureau, File No. EB-03-TC-144, issued to
   See Through Windows & Doors LLC on July 2, 2004. Bureau staff mailed the
   citation to the following addresses: See Through Windows & Doors LLC, See
   Thru Windows LLC 3101 Hubbard Road, Landover, MD 20785; See Through
   Windows & Doors LLC, 11132a Rockville Pike, Rockville, MD 20852; and
   Johanson Berenson LLP, Attorneys and Counselors at Law, 1350 Beverly Road,
   Suite 115, PMB 208, Mclean, VA 22101.

   Letters from D.S. Berenson, L.C., Johanson Berenson LLP, to Kurt
   Schroeder, Deputy Chief, Telecommunications Consumers Division,
   Enforcement Bureau, Federal Communications Commission, File No.
   EB-04-TC-144, dated December 8, 2003; February 28, 2004; and May 24, 2004.

   Letters from Kurt A. Schroeder, Deputy Chief, Telecommunications Consumers
   Division, Enforcement Bureau, File No. EB-03-TC-144, to See Through
   Windows, dated February 9, 2007 and July 6, 2007.

   Letters from Kevin M. Tierney, Johanson Berenson LLP, to Kurt Schroeder,
   Deputy Chief, Telecommunications Consumers Division, Enforcement Bureau,
   Federal Communications Commission, File No. EB-03-TC-144, dated March 1,
   2007, August 3, 2007 and August 13, 2007.

   47 U.S.C. S: 503(b)(5) (authorizing the Commission to assess a forfeiture
   penalty against any person who does not hold a license, permit,
   certificate or other authorization issued by the Commission, or an
   applicant for any of those listed instrumentalities, so long as such
   person (A) is first issued a citation of the violation charged; (B) is
   given a reasonable opportunity for a personal interview with an official
   of the Commission, at the field office of the Commission nearest to the
   person's place of residence; and (C) subsequently engages in conduct of
   the type described in the citation).

   See Through Windows & Doors LLC, Notice of Apparent Liability for
   Forfeiture, 22 FCC Rcd 19899 (2007); see also 47 U.S.C. S: 503(b)(1).

   Letter from Kevin M. Tierney, Johanson Berenson LLP, to Kurt Schroeder,
   Deputy Chief, Telecommunications Consumers Division, Enforcement Bureau,
   Federal Communications Commission, File No. EB-03-TC-144, dated December
   17, 2007.

   Id., at 2.

   See 47 C.F.R. S: 64.1200(c)(2)(1)(A)-(E).

   47 U.S.C. S: 504(a).

   (...continued from previous page)

                                                              (continued....)

   Federal Communications Commission DA 11-174

                                       2

   Federal Communications Commission DA 11-174