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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                          )                                
                                                           
                          )                                
                              File No.: EB-11-SE-058       
     In the Matter of     )                                
                              NAL/Acct. No.: 201232100016  
     NEP Cellcorp, Inc.   )                                
                              FRN: 0014802284              
                          )                                
                                                           
                          )                                


                  Notice of apparent Liability for forfeiture

   Adopted: December 28, 2011 Released: December 28, 2011

   By the Chief, Enforcement Bureau:

   I. introduction

    1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we
       propose a forfeiture in the amount of twenty-five thousand five
       hundred dollars ($25,500) against NEP Cellcorp, Inc. ("NEP"). As
       detailed herein, we find that NEP apparently willfully and repeatedly
       violated section 20.19(c)(3)(ii) of the Commission's rules ("Rules").
       We further find that this apparent misconduct continued for five
       consecutive months during the 2010 calendar year. Specifically, NEP
       apparently failed to offer to consumers the required number or
       percentage of hearing aid-compatible digital wireless handset models
       as set forth in the Rules. These hearing aid compatibility
       requirements serve to ensure that consumers with hearing loss have
       access to advanced telecommunications services.

   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 must offer specified numbers
       or percentages of digital wireless handset models that are rated as
       hearing aid-compatible. The number or percentage of digital wireless
       handset models required to be offered to consumers by each deadline
       depends on the applicable compatibility standard ("M" rating or "T"
       rating), and the deployment schedule is tailored to the size of the
       service provider as measured by its number of subscribers.
       Specifically, 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. Beginning May 15, 2010, non-Tier I service
       providers were required to offer to consumers at least ten handset
       models per digital air interface, or at least 50% of the models
       offered per digital air interface, that met or exceeded the M3 rating.
       Similarly, between May 15, 2010 and May 14, 2011, non-Tier I service
       providers were required to offer at least seven handset models per
       digital air interface, or at least one-third of the models offered per
       digital air interface, that met or exceeded the T3 rating.

    4. On January 18, 2011, NEP submitted a hearing aid compatibility status
       report covering January 1, 2010 to December 31, 2010. NEP identified
       each handset model offered to consumers and specified the model's FCC
       Identification ("FCC ID") as well as the hearing aid compatibility
       rating, if any. After a careful review of NEP's submission, the
       Wireless Telecommunications Bureau referred this matter to the
       Enforcement Bureau ("Bureau") for investigation. As part of its
       investigation, the Bureau consulted FCC Office of Engineering and
       Technology ("OET") Equipment Authorization System to independently
       confirm the hearing aid compatibility rating of each handset model as
       established in the grant of equipment authorization issued by the
       Commission for that handset. Taking into account the
       manufacturer-reported information in the OET database, we conclude
       that NEP apparently failed to offer, for an extended timeframe during
       the 2010 calendar year, the required number or percentage of handset
       models that met or exceeded the M3 rating.

   III. DISCUSSION

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

    5. We find that NEP apparently failed to offer to consumers the required
       number or percentage of hearing aid-compatible handset models that met
       or exceeded the M3 rating.  As noted above, the Commission has imposed
       varying benchmarks for the deployment of hearing aid-compatible
       handsets.  During the period August through October 2010, NEP was
       required to offer at least seven M3 or higher rated handset models
       over the GSM air interface, and during November and December 2010, it
       was required to offer at least eight-significantly fewer than the 14
       to 15 handset models it made available to consumers without hearing
       loss. As set forth in greater detail in the Appendix, NEP apparently
       failed to meet this standard, repeatedly falling short by one handset
       model.  Accordingly, we find that NEP apparently willfully and
       repeatedly violated section 20.19(c)(3)(ii) of the Rules by failing to
       offer to consumers the required number or percentage of digital
       wireless handset models that met or exceeded the M3 rating. We further
       find that this apparent misconduct continued for five consecutive
       months during the 2010 calendar year.

    B. Proposed Forfeiture

    6. 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 for forfeiture 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 NEP is
       apparently liable for a forfeiture for its apparent willful and
       repeated violations of section 20.19(c)(3)(ii) of the Rules.

    7. Section 503(b)(2)(B) of the Act authorizes a forfeiture assessment
       against a common carrier 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."

    8. 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 compatibility requirements set forth in section 20.19 of
       the Rules. The fact that the Forfeiture Policy Statement does not
       specify a base amount in no way suggests that a forfeiture should not
       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.

    9. 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 advanced 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 public's
       growing reliance on wireless technology and with the increasing median
       age of our population.

   10. We have previously determined that violations of the hearing
       aid-compatible handset deployment requirements are serious in nature
       because failure to make compatible handsets available to consumers
       actually prevents hearing aid users from accessing digital wireless
       communications. Accordingly, we generally apply a base forfeiture
       amount of $15,000 to reflect the gravity of these violations. We have
       applied the $15,000 base forfeiture on a per handset model basis
       (i.e., for each handset model below the minimum number of hearing
       aid-compatible models required by the Rules).

   11. For purposes of calculating the base forfeiture amount for the
       apparent M3-related violations, we focus on NEP's failure to offer to
       consumers the requisite number or percentage of handset models with a
       minimum M3 rating in December 2010, when NEP missed the benchmark by
       one handset model. Accordingly, and consistent with section 503(b)(6)
       of the Act, we start with a base forfeiture of $15,000 for NEP's
       apparent failure to offer to consumers the required number or
       percentage of M3-rated handset models in willful and repeated
       violation of section 20.19(c)(3)(ii) of the Rules.

   12. This base forfeiture amount, however, is subject to adjustment. Given
       the totality of the circumstances, and consistent with the Forfeiture
       Policy Statement, we conclude that an upward adjustment of the $15,000
       base forfeiture amount is warranted. In this regard, we take into
       account that NEP was out of compliance with the hearing aid-compatible
       handset deployment requirements for nearly half of the 2010 calendar
       year-failing to offer to consumers the requisite number or percentage
       of handset models with a minimum M3 rating for five consecutive
       months. Further, we take into account that NEP has previously violated
       our hearing aid-compatible handset deployment requirements. Therefore,
       based on all the factors and evidence, including the duration of the
       violation, NEP's history of noncompliance with the hearing
       aid-compatible handset deployment requirements, and the potentially
       significant impact on consumers with hearing loss, we propose a
       forfeiture of $25,500 against NEP for apparently willfully and
       repeatedly failing to comply with the hearing aid-compatible handset
       deployment requirements set forth in sections 20.19(c)(3)(ii) of the
       Rules.

   IV. ORDERING clauses

   13. 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, NEP Cellcorp,
       Inc. IS NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE in the
       amount of twenty-five thousand five hundred dollars ($25,500) for
       willful and repeated violation of section 20.19(c)(3)(ii) of the
       Rules.

   14. IT IS FURTHER ORDERED that, pursuant to section 1.80 of the Rules,
       within thirty (30) calendar days after the release date of this Notice
       of Apparent Liability for Forfeiture, NEP Cellcorp, Inc. SHALL PAY the
       full amount of the proposed forfeiture or SHALL FILE a written
       statement seeking reduction or cancellation of the proposed
       forfeiture.

   15. Payment of the forfeiture must be made by check or similar instrument,
       payable to the order of the Federal Communications Commission. The
       payment must include the NAL/Account Number and FRN referenced above.
       Payment by check or money order may be mailed to Federal
       Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.
       Payment by overnight mail may be sent to U.S. Bank - Government
       Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
       63101. Payment by wire transfer may be made to ABA Number 021030004,
       receiving bank TREAS/NYC, and account number 27000001. For payment by
       credit card, an FCC Form 159 (Remittance Advice) must be submitted.
       When completing the FCC Form 159, enter the NAL/Account number in
       block number 23A (call sign/other ID), and enter the letters "FORF" in
       block number 24A (payment type code). Requests for full payment under
       an installment plan should be sent to: Chief Financial Officer -
       Financial Operations, 445 12th Street, S.W., Room 1-A625, Washington,
       D.C.  20554. Please contact the Financial Operations Group Help Desk
       at 1-877-480-3201 or Email: arinquiries@fcc.gov with any questions
       regarding payment procedures.  NEP Cellcorp, Inc. must also send
       electronic notification to Linda Nagel at Linda.Nagel@fcc.gov, Pamera
       Hairston at Pamera.Hairston@fcc.gov, and Samantha Peoples at
       Sam.Peoples@fcc.gov on the date said payment is made.

   16. 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 Linda Nagel at Linda.Nagel@fcc.gov and Pamera
       Hairston at Pamera.Hairston@fcc.gov.

   17. 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.

   18. 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 Steven Tourje, Chief Executive Officer,
       NEP Cellcorp, Inc., 720 Main St., Post Office Box D, Forest City, PA
       18421.

   FEDERAL COMMUNICATIONS COMMISSION

   P. Michele Ellison

   Chief

   Enforcement Bureau

                                    APPENDIX

                               NEP Cellcorp, Inc.

                 Hearing Aid-Compatible Handset Model Offerings

                             (M3 or higher rating)


         Total  M3-rated                                                                                         
 Period Handset Handset  M3-rated Handset      M3                                                                
        Models   Models   Models Required  Compliance?                                                           
        Offered Offered                                                                                          

  Jan.     8       5                           Yes                                                               
  2010                                                                                                           

  Feb.    10       6                                   Yes                                                       
  2010                                                                                                           

 March    10       6                                       Yes                                                   
  2010                                                                                                           

 April    10       6                                           Yes                                               
  2010                                                                                                           

  May                                                                                                            
 1-14,    12       6                                                      Yes                                    
  2010                                                                                                           

  May                    the total number                                                                        
 15-31,   12       6     of handset models                                            Yes                        
  2010                      offered or                                                                           

  June    12       6        at least 9                                                    Yes                    
  2010                    handset models                                                                         

  July    12       6     (5/15/09-5/14/10)                          At least 50% of           Yes                
  2010                                                              the total number                             

  Aug.    14       6                                                   offered or                 No             
  2010                                                                                                           

 Sept.    14       6                                                 handset models                  No          
  2010                                                                                                           

  Oct.    14       6                                                                                    No       
  2010                                                                                                           

  Nov.    15       7                                                                                       No    
  2010                                                                                                           

  Dec.    15       7                                                                                          No 
  2010                                                                                                           


   NEP is a Global System for Mobile Communications-based ("GSM-based") Tier
   III carrier serving Northeast Pennsylvania. Tier III carriers are
   non-nationwide wireless radio service providers with 500,000 or fewer
   subscribers as of the end of 2001. See Revision of the Commission's Rules
   to Ensure Compatibility with Enhanced 911 Emergency Calling Systems, Phase
   II Compliance Deadlines for Non-Nationwide CMRS Carriers, Order to Stay,
   17 FCC Rcd 14841, 14847-48 P:P: 22-23 (2002).

   47 C.F.R. S: 20.19(c)(3)(ii).

   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)(B) of the Communications Act of
   1934, as amended (the "Act"), 47 U.S.C. S: 610(b)(2)(B).

   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 coupling (telecoil) 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
   sound by the hearing aid speaker. 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.

   Hearing Aid Compatibility Order,  18 FCC Rcd at 16763 P: 22.

   As subsequently amended, section 20.19(b)(1) provides that, for the period
   beginning January 1, 2010, a wireless handset is deemed hearing
   aid-compatible for radio frequency interference if, at a minimum, it meets
   the M3 rating associated with the technical standard set forth in the
   standard document "American National Standard Methods of Measurement of
   Compatibility between Wireless Communication Devices and Hearing Aids,"
   ANSI C63.19-2007 (June 8, 2007) ("ANSI C63.19-2007"), except that grants
   of certification issued before January 1, 2010 under earlier versions of
   ANSI C63.19 remain valid for hearing aid compatibility purposes. 47 C.F.R.
   S: 20.19(b)(1). Section 20.19(b)(2) provides that, for the period
   beginning 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 set forth in ANSI
   C63.19-2007, except that grants of certification issued before January 1,
   2010 under earlier versions of ANSI C63.19 remain valid for hearing aid
   compatibility purposes. 47 C.F.R. S: 20.19(b)(2).

   These requirements apply to each air interface over which service
   providers offer service. See Amendment of the Commission's Rules Governing
   Hearing Aid-Compatible Mobile Handsets, First Report and Order, 23 FCC Rcd
   3406, 3419 P:P: 35-36 (2008) ("Hearing Aid Compatibility First Report and
   Order"), Order on Reconsideration and Erratum, 23 FCC Rcd 7249 (2008)
   (stating that the hearing aid compatibility handset deployment
   requirements apply on a per air interface basis). However, the handset
   deployment requirements do not apply to service providers and
   manufacturers that meet the de minimis exception. Id. at 3413 P: 20. See
   also 47 C.F.R. S: 20.19(e). 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). Effective September
   10, 2012, the de minimis exception will not be available to manufacturers
   or mobile service providers that do not meet the definition of a "small
   entity" beginning two years after their initial offerings. 47 C.F.R. S:
   20.19(e)(1)(ii); see also 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 GSM, Code Division Multiple Access ("CDMA"), 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 supra note 8.

   See supra note 9.

   See NEP Cellcorp, Inc. Hearing Aid Compatibility Status Report (filed Jan.
   18, 2011), available at
   http://wireless.fcc.gov/hac_documents/110210/5949489_299.PDF ("2010
   Report").

   The FCC Office of Engineering and Technology Equipment Authorization
   System is an electronic database of all equipment certified under FCC
   authority. The database identifies the hearing aid compatibility rating of
   each device by FCC ID, as reported by the handset manufacturer in test
   reports submitted to the Commission at the time of an equipment
   authorization or of any modifications to such authorization. See
   http://transition.fcc.gov/oet/ea/fccid/.

   We note that our review revealed apparent inconsistencies between the
   hearing aid compatibility ratings for certain handset models listed in the
   2010 report and the ratings information specified in the Commission's
   equipment authorization for those models. Specifically, NEP's 2010 Report
   indicated that the Samsung Galaxy i9000 handset (FCC ID A3LGTI9000) has an
   M3/T3 rating when in fact Commission records show that this handset is not
   rated for hearing aid compatibility; that the Motorola Milestone Android
   handset (FCC ID IHDP56KC2) has an M3/T3 rating while Commission records
   show that this handset is not rated for hearing aid compatibility; and
   that the Motorola MB300 Backflip handset (FCC ID IHDP56KD2) has an M3
   rating when Commission records show that this handset is not rated for
   hearing aid compatibility.

   See supra note 13 and accompanying text.

   See 47 C.F.R. S: 20.19(c)(3)(ii) (requiring non-Tier I digital wireless
   service providers to ensure that beginning May 15, 2010, either at least
   50% of the handset models they offered, or at least 10 handset models, met
   or exceeded the M3 rating for radio frequency interference). All of NEP's
   handset models operated only over the GSM air interface during the 2010
   reporting period.

   We note that while non-hearing aid-compatible handsets are technically
   available to all consumers, these handsets may not function effectively
   with hearing aids and can create excessive feedback and "noise." See
   Hearing Aid Compatibility Order, 18 FCC Rcd at 16756 P: 6 ("[D]igital
   wireless phones can cause interference to hearing aids and cochlear
   implants because of electromagnetic energy emitted by the phone's antenna,
   backlight, or other components. This interference can be significant
   enough to prevent individuals with hearing aids or cochlear implants from
   using digital wireless phones and services. In addition, most wireless
   phones do not internally provide the capability to inductively couple with
   hearing aids containing telecoils, as wireline phones do.").

   See Appendix, NEP Cellcorp, Inc. Hearing Aid-Compatible Handset Offerings
   (M3 or higher rating) (indicating that between August 1, 2010 and December
   31, 2010, NEP offered either 14 or 15 handset models, only 6 to 7 of which
   had a minimum M3 rating).

   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 clarifies that this definition of willful applies to both
   sections 312 and 503(b) of the Act, H.R. Conf. Rep. No. 97-765 (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); 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 Monetary Forfeiture, 16 FCC Rcd 1359, 1362 (2001),
   forfeiture ordered, Forfeiture Order, 17 FCC Rcd 22626 (2002) (forfeiture
   paid); 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)(4); 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). The Commission has amended section 1.80(b)(2)
   of the Rules, 47 C.F.R. S: 1.80(b)(2), three times to increase the maximum
   forfeiture amounts, in accordance with the inflation adjustment
   requirements contained in the Federal Civil Penalties Inflation Adjustment
   Act of 1990, 28 U.S.C. S: 2461 note, as amended by the Debt Collection
   Improvement Act of 1996, 31 U.S.C. S: 3701 note. The most recent inflation
   adjustment took effect September 2, 2008 and applies to violations that
   occur after that date. See Amendment of Section 1.80(b) of the
   Commission's Rules, Adjustment of Forfeiture Maxima to Reflect Inflation,
   Order, 23 FCC Rcd 9845, 9847 (2008) (adjusting the maximum statutory
   amounts for common carriers from $130,000/$1,325,000 to
   $150,000/$1,500,000); 73 Fed. Reg. 44663-5.

   47 U.S.C. S: 503(b)(2)(E). See also 47 C.F.R. S: 1.80(b)(5), Note to
   paragraph (b)(5): 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,  Report and
   Order, 12 FCC Rcd 17087 (1997), recon. denied, Memorandum Opinion and
   Order, 15 FCC Rcd 303 (1999) ("Forfeiture Policy Statement"); 47 C.F.R.
   S:S: 1.80, 20.19.

   Forfeiture Policy Statement, 12 FCC Rcd at 17099 P: 22.

   Id.

   Hearing Aid Compatibility Order, 18 FCC Rcd at 16755 P: 4.

   Id. at 16756 P: 5 (noting that approximately one in ten Americans, or 28
   million Americans, 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 Section 68.4(a) of the Commission's
   Rules Governing Hearing Aid-Compatible Telephones, Report on the Status of
   Implementation of the Commission's Hearing Aid Compatibility Requirements,
   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 people - with that number expected to reach
   approximately 40 million people at the end of [2010]").

   See South Canaan Cellular Communications Company, L.P, Notice of Apparent
   Liability for Forfeiture, 23 FCC Rcd 20, 24 P: 11(Enf. Bur., Spectrum Enf.
   Div. 2008) (forfeiture paid) ("South Canaan") (finding that "a violation
   of the labeling requirements, while serious because it deprives hearing
   aid users from making informed choices, is less egregious than a violation
   of the handset requirements because failure to make compliant handsets
   available actually deprives hearing aid users from accessing digital
   wireless communications."). See also, e.g., NEP Cellcorp, Inc., Notice of
   Apparent Liability for Forfeiture, 24 FCC Rcd 8, 13 P: 11 (Enf. Bur.,
   Spectrum Enf. Div. 2009) (forfeiture paid) ("NEP Cellcorp"); Pinpoint
   Wireless, Inc., Notice of Apparent Liability for Forfeiture, 23 FCC Rcd
   9290, 9295 P: 11 (Enf. Bur., Spectrum Enf. Div. 2008), consent decree
   ordered, Order and Consent Decree, 24 FCC Rcd 2951 (Enf. Bur., Spectrum
   Enf. Div. 2009) ("Pinpoint Wireless"); Smith Bagley, Inc., Notice of
   Apparent Liability for Forfeiture, 24 FCC Rcd 14113, 14118 P: 11 (Enf.
   Bur., Spectrum Enf. Div. 2009), response pending ("Smith Bagley").

   See, e.g., NEP Cellcorp, 24 FCC Rcd at 13 P: 11; Pinpoint Wireless, 23 FCC
   Rcd at 9295 P: 11; Smith Bagley, 24 FCC Rcd at 14118 P: 11; South Canaan,
   23 FCC Rcd at 24 P:11.

   See supra note 32.

   See supra para. 5.

   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 NEP'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 P: 8 (2000); BASF Corporation, Notice of Apparent Liability
   for Forfeiture, 25 FCC Rcd 17300, 17302 n.24 (Enf. Bur., Spectrum Enf.
   Div. 2010); Call Mobile, Inc., Notice of Apparent Liability for
   Forfeiture, 26 FCC Rcd 74, 76 n.23 (Enf. Bur., Spectrum Enf. Div. 2011).
   The forfeiture amount we propose herein relates only to NEP's apparent
   violations that have occurred within the past year.

   See NEP Cellcorp, Inc., Notice of Apparent Liability for Forfeiture, 24
   FCC Rcd 8, 13 P: 11 (Enf. Bur., Spectrum Enf. Div. 2009) (proposing a
   $12,000 forfeiture for the failure to offer at least two models that meet
   the inductive coupling standards for hearing aid compatibility)
   (forfeiture paid).

   47 C.F.R. S: 20.19(c)(3)(ii).

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

   47 C.F.R. S: 1.80(f)(3), 1.16.

   Federal Communications Commission DA 11-2079

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   Federal Communications Commission DA 11-2079