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                                   Before the

                       Federal Communications Commission

                              Washington, DC 20554


                                )                            
                                                             
                                )                            
                                                             
                                )   File No.: EB-10-SE-124   
     In the Matter of                                        
                                )   Acct. No.: 201332100001  
     TelAlaska Cellular, Inc.                                
                                )   FRN: 0003740768          
                                                             
                                )                            
                                                             
                                )                            


                                     ORDER

   Adopted: October 12, 2012 Released: October 12, 2012

   By the Chief, Enforcement Bureau:

    1. In this Order, we adopt the attached Consent Decree entered into
       between the Enforcement Bureau (Bureau) of the Federal Communications
       Commission (Commission) and TelAlaska Cellular, Inc. (TelAlaska). The
       Consent Decree resolves and terminates the Bureau's investigation into
       TelAlaska's compliance with Sections 20.19(c)(3) and 20.19(d)(3) of
       the Commission's rules (Rules) concerning the deployment of digital
       wireless hearing aid-compatible handsets.

    2. The Bureau and TelAlaska have negotiated the Consent Decree that
       resolves this matter. A copy of the Consent Decree is attached hereto
       and incorporated herein 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 TelAlaska 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 Sections 4(i) and 503(b)
       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 Brenda C. Shepard, Chief Executive Officer, TelAlaska
       Cellular, Inc., 201 E 56th Avenue, Anchorage, AK 99518, and to D. Cary
       Mitchell, counsel for TelAlaska Cellular, Inc., Blooston, Mordkofsky,
       Dickens, Duffy & Prendergast, 2120 L Street, NW, Suite 300,
       Washington, DC 20037.

   FEDERAL COMMUNICATIONS COMMISSION

   P. Michele Ellison

   Chief, Enforcement Bureau

                                   Before the

                       Federal Communications Commission

                              Washington, DC 20554


                                )                            
                                                             
                                )                            
                                    File No.: EB-10-SE-124   
     In the Matter of           )                            
                                    Acct. No.: 201332100001  
     TelAlaska Cellular, Inc.   )                            
                                    FRN: 0003740768          
                                )                            
                                                             
                                )                            


                                 CONSENT DECREE

   The Enforcement Bureau of the Federal Communications Commission and
   TelAlaska Cellular, Inc., by their authorized representatives, hereby
   enter into this Consent Decree for the purpose of terminating the
   Enforcement Bureau's investigation into possible violations of Sections
   20.19(c)(3) and 20.19(d)(3) of the Commission's rules pertaining to 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. "Commission" and "FCC" mean the Federal Communications Commission and
       all of its bureaus and offices.

    e. "Communications Laws" means collectively, the Act, the Rules, and the
       published and promulgated orders and decisions of the Commission to
       which TelAlaska is subject by virtue of its business activities,
       including but not limited to, the Hearing Aid Compatibility Rules.

    f. "Compliance Plan" means the compliance obligations, program, and
       procedures described in this Consent Decree at paragraph 10.

    g. "Covered Employees" means all employees and agents of TelAlaska who
       perform, or supervise, oversee, or manage the performance of, duties
       that relate to TelAlaska's responsibilities under the Hearing Aid
       Compatibility Rules.

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

    i. "Hearing Aid Compatibility Rules" means Section 20.19 of the Rules and
       other Communications Laws governing digital wireless hearing aid
       compatibility, such as the Rules governing the design, selection, or
       acquisition of wireless handsets and the marketing or distribution of
       such handsets to consumers in the United States.

    j. "Investigation" means the investigation commenced by the Bureau's
       September 9, 2010 letter of inquiry regarding TelAlaska's deployment
       of digital wireless hearing aid-compatible handsets.

    k. "Operating Procedures" means the standard, internal operating
       procedures and compliance policies established by TelAlaska to
       implement the Compliance Plan.

    l. "Parties" means TelAlaska and the Bureau, each of which is a "Party."

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

    n. "TelAlaska" means TelAlaska Cellular, Inc.  and its
       predecessors-in-interest and successors-in-interest.

   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 for radio frequency interference (the
       M rating) and inductive coupling (the T rating) that digital wireless
       handsets must meet to be considered compatible with hearing aids
       operating in acoustic coupling and inductive coupling (telecoil)
       modes, respectively. 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. 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. On January 14, 2010, TelAlaska submitted its annual hearing aid
       compatibility status report for the January 1, 2009 to December 31,
       2009 reporting period (2009 Report). On August 12, 2010, the Wireless
       Telecommunications Bureau referred TelAlaska's apparent hearing
       aid-compatible handset deployment violations to the Bureau's Spectrum
       Enforcement Division (Division) for investigation and possible
       enforcement action. On September 9, 2010, the Division issued a letter
       of inquiry (LOI) to TelAlaska, which directed the company to submit a
       sworn written response to a series of questions related to its
       compliance with the Hearing Aid Compatibility Rules.

    4. TelAlaska responded to the LOI on September 28, 2010. In its LOI
       Response, TelAlaska states that it commenced offering service in
       August 2009 and that as of December 2009 the company provided service
       to a total of 546 subscribers in six remote rural Alaska communities.
       In addition, TelAlaska reports that it discovered its apparent
       violation of the hearing aid-compatible handset deployment
       requirements prior to the filing of its 2009 Report, that it
       immediately initiated efforts to correct those apparent violations,
       and that the company became compliant with these requirements prior to
       the Bureau's initiation of the Investigation. The Bureau and TelAlaska
       entered into tolling agreements to toll the statute of limitations.

   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.

    6. Jurisdiction. TelAlaska agrees that the Bureau has jurisdiction over
       it and the matters contained in this Consent Decree and that the
       Bureau 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. As of
       the Effective Date, the Adopting Order and this Consent Decree shall
       have the same force and effect as any other order of the Commission.
       Any violation of the Adopting Order or of the terms of this Consent
       Decree shall constitute a separate violation of a Commission order,
       entitling the Commission 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 the
       Investigation, TelAlaska 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 the 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 TelAlaska 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 the
       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 TelAlaska
       with respect to TelAlaska's basic qualifications, including its
       character qualifications, to be a Commission licensee or to hold
       Commission licenses or authorizations.

    9. Compliance Officer. Within thirty (30) calendar days after the
       Effective Date, TelAlaska shall designate a senior corporate manager
       with the requisite corporate and organizational authority to serve as
       Compliance Officer and to discharge the duties set forth below. The
       Compliance Officer shall be responsible for developing, implementing,
       and administering the Compliance Plan and ensuring that TelAlaska
       complies with the terms and conditions of the Compliance Plan and this
       Consent Decree. In addition to the general knowledge of the
       Communications Laws necessary to discharge his/her duties under this
       Consent Decree, the Compliance Officer shall have specific knowledge
       of the Hearing Aid Compatibility Rules prior to assuming his/her
       duties.

   10. Compliance Plan. For purposes of settling the matters set forth
       herein, TelAlaska agrees that it shall within sixty (60) calendar days
       after the Effective Date, develop and implement a Compliance Plan
       designed to ensure future compliance with the Communications Laws,
       including the Hearing Aid Compatibility Rules, and with the terms and
       conditions of this Consent Decree. The Compliance Plan shall include,
       without limitation, the following components:

     a. Operating Procedures on Hearing Aid Compatibility. Within sixty (60)
        calendar days after the Effective Date, TelAlaska shall establish
        Operating Procedures that all Covered Employees must follow to help
        ensure TelAlaska's compliance with the Hearing Aid Compatibility
        Rules. TelAlaska's Operating Procedures shall include internal
        procedures and policies specifically designed to ensure that
        TelAlaska offers the requisite number or percentage of hearing
        aid-compatible digital wireless handset models to consumers as
        required by the Hearing Aid Compatibility Rules. TelAlaska also shall
        develop a Compliance Checklist that describes the steps that a
        Covered Employee must follow to ensure that the inclusion of a new
        handset model, or discontinuance of an existing handset model
        offering, will not result in a violation of the Commission's digital
        wireless hearing aid-compatible handset deployment requirements. At a
        minimum, the Compliance Checklist shall require Covered Employees to
        verify the hearing aid compatibility rating of each existing and
        proposed handset model offering using the Commission's equipment
        authorization database.

     b. Compliance Manual. Within sixty (60) calendar days after the
        Effective Date, the Compliance Officer shall develop and distribute a
        Compliance Manual to all Covered Employees. The Compliance Manual
        shall explain the Hearing Aid Compatibility Rules and set forth the
        Operating Procedures that Covered Employees shall follow to help
        ensure TelAlaska's compliance with the Hearing Aid Compatibility
        Rules. TelAlaska shall periodically review and revise the Compliance
        Manual as necessary to ensure that the information set forth therein
        remains current and complete. TelAlaska shall distribute any
        revisions to the Compliance Manual promptly to all Covered Employees.

     c. Compliance Training Program. TelAlaska shall establish and implement
        a Compliance Training Program on compliance with the Hearing Aid
        Compatibility Rules and the Operating Procedures. As part of the
        Compliance Training Program, Covered Employees shall be advised of
        TelAlaska's obligation to report any noncompliance with the Hearing
        Aid Compatibility Rules under paragraph 11 of this Consent Decree and
        shall be instructed on how to disclose noncompliance to the
        Compliance Officer. All Covered Employees shall be trained pursuant
        to the Compliance Training Program within sixty (60) calendar days
        after the Effective Date,  except that any person who becomes a
        Covered Employee at any time after the Effective Date shall be
        trained within thirty (30) calendar days after the date such person
        becomes a Covered Employee. TelAlaska shall repeat the compliance
        training on an annual basis, and shall periodically review and revise
        the Compliance Training Program as necessary to ensure that it
        remains current and complete and to enhance its effectiveness.

   11. Reporting Noncompliance. TelAlaska shall report any noncompliance with
       the Hearing Aid Compatibility Rules and with the terms and conditions
       of this Consent Decree within fifteen (15) calendar days after
       discovery of such noncompliance. Such reports shall include a detailed
       explanation of (i) each instance of noncompliance; (ii) the steps that
       TelAlaska has taken or will take to remedy such noncompliance; (iii)
       the schedule on which such remedial actions will be taken; and (iv)
       the steps that TelAlaska has taken or will take to prevent the
       recurrence of any such noncompliance. All reports of noncompliance
       shall be submitted to the Chief, Spectrum Enforcement Division,
       Enforcement Bureau, Federal Communications Commission, Room 3-C366,
       445 12th Street, S.W. Washington, D.C. 20554, with a copy submitted
       electronically to Kevin Pittman at Kevin.Pittman@fcc.gov and to Pamera
       Hairston at Pamera.Hairston@fcc.gov.

   12. Compliance Reports. TelAlaska 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.

    a. Each compliance report shall include a detailed description of
       TelAlaska's efforts during the relevant period to comply with the
       terms and conditions of this Consent Decree and the Hearing Aid
       Compatibility Rules. In addition, each Compliance Report shall include
       a certification by the Compliance Officer, as an agent of and on
       behalf of TelAlaska, stating that the Compliance Officer has personal
       knowledge that TelAlaska (i) has established and implemented the
       Compliance Plan; (ii) has utilized the Operating Procedures since the
       implementation of the Compliance Plan; and (iii) is not aware of any
       instances of noncompliance with the terms and conditions of this
       Consent Decree, including the reporting obligations set forth in
       paragraph 11 hereof.

    b. The Compliance Officer's certification shall be accompanied by a
       statement explaining the basis for such 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.

    c. If the Compliance Officer cannot provide the requisite certification,
       the Compliance Officer, as an agent of and on behalf of TelAlaska,
       shall provide the Commission with a detailed explanation of the
       reason(s) why and describe fully (i) each instance of noncompliance;
       (ii) the steps that TelAlaska has taken or will take to remedy such
       noncompliance, including the schedule on which proposed remedial
       actions will be taken; and (iii) the steps that TelAlaska has taken or
       will take to prevent the recurrence of any such noncompliance,
       including the schedule on which such preventive action will be taken.

    d. All Compliance Reports 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 Kevin Pittman at Kevin.Pittman@fcc.gov and
       to Pamera Hairston at Pamera.Hairston@fcc.gov.

   13. Termination Date. The obligations set forth in paragraphs 9 through 12
       of this Consent Decree shall expire twenty-four (24) months after the
       Effective Date.

   14. 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 TelAlaska 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
       complaints 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 TelAlaska with the Communications Laws.

   15. Voluntary Contribution. TelAlaska agrees that it will make a voluntary
       contribution to the United States Treasury in the amount of fifty-five
       thousand dollars ($55,000) within thirty (30) calendar days after the
       Effective Date. TelAlaska shall also send electronic notification of
       payment to Kevin Pittman at Kevin.Pittman@fcc.gov, Pamera Hairston at
       Pamera.Hairston@fcc.gov, and Samantha Peoples at Sam.Peoples@fcc.gov
       on the date said payment is made. The payment must be made by check or
       similar instrument, wire transfer, or credit card and must include the
       NAL/Account Number and FRN referenced above. Regardless of the form of
       payment, a completed 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). Below are additional
       instructions you should follow based on the form of payment you
       select:

     * Payment by check or money order must be made payable to the order of
       the Federal Communications Commission. Such payments (along with the
       completed Form 159) must be mailed to Federal Communications
       Commission, P.O. Box 979088, St. Louis, MO 63197-9000, or sent via
       overnight mail to U.S. Bank - Government Lockbox #979088, SL-MO-C2-GL,
       1005 Convention Plaza, St. Louis, MO 63101.

     * Payment by wire transfer must be made to ABA Number 021030004,
       receiving bank TREAS/NYC, and Account Number 27000001. To complete the
       wire transfer and ensure appropriate crediting of the wired funds, a
       completed Form 159 must be faxed to U.S. Bank at (314) 418-4232 on the
       same business day the wire transfer is initiated.

     * Payment by credit card must be made by providing the required credit
       card information on FCC Form 159 and signing and dating the Form 159
       to authorize the credit card payment. The completed Form 159 must then
       be mailed to Federal Communications Commission, P.O. Box 979088, St.
       Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank -
       Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
       Louis, MO 63101.

   If you have questions regarding payment procedures, please contact the
   Financial Operations Group Help Desk by phone, 1-877-480-3201, or by
   e-mail, ARINQUIRIES@fcc.gov.

   16. Waivers. TelAlaska 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 as defined herein. TelAlaska 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 TelAlaska nor the Commission shall contest the
       validity of the Consent Decree or of the Adopting Order, and TelAlaska
       shall waive any statutory right to a trial de novo. TelAlaska hereby
       agrees to waive any claims it may have under the Equal Access to
       Justice Act relating to the matters addressed in this Consent Decree.

   17. 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.

   18. 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 TelAlaska does not expressly
       consent) that provision will be superseded by such Rule or Commission
       order.

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

   20. Final Settlement. The Parties agree and acknowledge that this Consent
       Decree shall constitute a final settlement between the Parties with
       respect to the Investigation. 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 Communications Laws.

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

   22. 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.

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

   24. 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

   ________________________________

   Brenda C. Shepard

   Chief Executive Officer

   TelAlaska Cellular, Inc.

   ______________________________

   Date

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

   47 U.S.C. S:S: 154(i), 503(b).

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

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

   Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division, FCC
   Enforcement Bureau, to Robert. W. Dunn, Director of Regulatory Affairs,
   TelAlaska Cellular, Inc. (Sept. 10, 2010) (on file in EB-10-SE-124).

   The Commission adopted these requirements for digital wireless telephones
   under the authority of the Hearing Aid Compatibility Act of 1988, codified
   at Section 710(b)(2)(C) of the Communications Act of 1934, as amended
   (Act), 47 U.S.C. S: 610(b)(2)(C). See Section 68.4(a) of the Commission's
   Rules Governing Hearing Aid-Compatible Telephones, Report and Order, 18
   FCC Rcd 16753, 16787, para. 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).

   As subsequently amended, Section 20.19(b)(1) provides that, for the period
   beginning June 6, 2008 and ending December 31, 2009, a newly certified
   wireless handset is deemed hearing aid-compatible for radio frequency
   interference if, at minimum, it meets the M3 rating associated with the
   technical standard set forth in either the standard document "American
   National Standard Methods of Measurement of Compatibility between Wireless
   Communication Devices and Hearing Aids," ANSI C63.19-2006 (June 12, 2006)
   or ANSI C63.19-2007 (June 8, 2007). Beginning January 1, 2010, a newly
   certified handset must meet at least an M3 rating under ANSI C63.19-2007
   to be considered hearing aid-compatible for radio frequency interference.
   47 C.F.R. S: 20.19(b)(1). Section 20.19(b)(2) provides that, for the
   period beginning June 6, 2008 and ending December 31, 2009, a newly
   certified wireless handset is deemed hearing aid-compatible for inductive
   coupling if, at minimum, it meets the T3 rating associated with the
   technical standard as set forth in ANSI C63.19-2006 or ANSI C63.19-2007,
   and beginning January 1, 2010, it is deemed hearing aid-compatible for
   inductive coupling if it meets at least a T3 rating under ANSI
   C63.19-2007. 47 C.F.R. S: 20.19(b)(2). Grants of certification issued
   before June 6, 2008, under previous versions of ANSI C63.19 remain valid
   for hearing aid compatibility purposes. A recently adopted further
   amendment to Section 20.19(b) of the Rules will permit manufacturers to
   test handsets for hearing aid compatibility using the 2011 version of the
   ANSI standard (ANSI C63.19-2011) as an alternative to ANSI C63.19-2007. 
   See Amendment of the Commission's Rules Governing Hearing Aid-Compatible
   Mobile Handsets, Third Report and Order, 27 FCC Rcd 3732 (WTB/OET 2012).

   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, para. 65; 47
   C.F.R. S: 20.19(c), (d).

   See Amendment of the Commission's Rules Governing Hearing Aid-Compatible
   Mobile Handsets, First Report and Order, 23 FCC Rcd 3406 (2008) (Hearing
   Aid Compatibility First Report and Order), Order on Reconsideration and
   Erratum, 23 FCC Rcd 7249 (2008). These handset deployment requirements do
   not apply to service providers and manufacturers that meet the de minimis
   exception. 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. Id. 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, paras. 35-59 (2010).

   See TelAlaska Cellular, Inc. Hearing Aid Compatibility Report, Docket No.
   07-250 (Jan. 14, 2010) available at
   http://wireless.fcc.gov/hac_documents/100317/TelAlaska%20Cellular,%20_213.PDF.

   See supra note 2.

   See Letter from Marnie Brennan, Vice President Marketing, TelAlaska
   Cellular, Inc. to Marlene H. Dortch, Secretary, Federal Communications
   Commission (Sept. 28, 2010) (on file in EB-10-SE-124) (LOI Response).

   Id. at 6.

   Id. at 2-3.

   See, e.g., Tolling Agreement Extension, File No. EB-10-SE-115, executed by
   and between John D. Poutasse, Chief, Spectrum Enforcement Division, FCC
   Enforcement Bureau, and Brenda Shepard, Chief Executive Officer, TelAlaska
   Cellular, Inc. (May 1, 2012).

   47 C.F.R. S: 1.16.

   An FCC Form 159 and detailed instructions for completing the form may be
   obtained at http://www.fcc.gov/Forms/Form159/159.pdf.

   Equal Access to Justice Act, Pub L. No. 96-481, 94 Stat. 2325 (1980)
   (codified at 5 U.S.C. S: 504); see also 47 C.F.R. S:S: 1.1501-1.1530.

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