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             Federal Communications Commission      DA 12-1844
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
CSDVRS, LLC d/b/a ZVRS
)
)
)
)
)
)
)
File No.:  EB-TCD-12-00000229
1
File No.:  EB-TCD-12-00000346
2
Acct. No.:  201332170004
FRN:  0016043143
ADOPTING ORDER
Adopted:  November 19, 2012           Released:  November 20, 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 CSDVRS, 
LLC (CSDVRS).  The Consent Decree terminates the investigations initiated by the Bureau regarding 
CSDVRS’s compliance with Section 225 of the Communications Act of 1934, as amended,
3
and Sections 
64.604 and 64.605 of the Commission’s rules
4
concerning the provision of Telecommunications Relay 
Services and compensation from the TRS Fund.
2. The Bureau and CSDVRS have negotiated the terms of the Consent Decree that resolves 
these matters.  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 
referenced investigations.
4. In the absence of material new evidence relating to this matter, we conclude that our 
investigations raise no substantial or material questions of fact as to whether CSDVRS possesses the basic 
qualifications, including those related to character, to hold or obtain any Commission license, 
certification, or authorization.
5. Accordingly, IT IS ORDERED, pursuant to Sections 4(i) and 503(b) of the 
Communications Act of 1934, as amended,
5
and Sections 0.111 and 0.311 of the Commission’s rules,
6
the 
attached Consent Decree IS ADOPTED.
                                                
1
The investigation was originally identified as file number EB-11-TC-075.
2
The investigation was originally identified as file number EB-11-TC-024.
3
47 U.S.C. § 225.
4
47 C.F.R. §§ 64.604, 64.605.  
5
47 U.S.C. §§ 154(i), 503(b).
6
47 C.F.R. §§ 0.111, 0.311.
             Federal Communications Commission       DA 12-1844
6. IT IS FURTHER ORDERED that the above-captioned investigations ARE 
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 Jeff Rosen, General Counsel for 
CSDVRS, 600 Cleveland Street, Suite 1000, Clearwater, FL 33755.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief
Enforcement Bureau
             Federal Communications Commission      DA 12-1844
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
CSDVRS, LLC d/b/a ZVRS
)
)
)
)
)
)
)
File No.:  EB-TCD-12-00000229
1
File No.:  EB-TCD-12-00000346
2
Acct. No.:  201332170004
FRN:  0016043143
CONSENT DECREE
The Enforcement Bureau of the Federal Communications Commission and CSDVRS, LLC, by 
their authorized representatives, hereby enter into this Consent Decree that resolves and terminates the 
Enforcement Bureau investigations into CSDVRS, LLC’s compliance with Section 225 of the 
Communications Act of 1934, as amended,
3
and Sections 64.604 and 64.605 of the Commission’s rules 
concerning the provision of Telecommunications Relay Services and compensation from the TRS Fund.
4
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. § 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) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 11.
(f) “Compliance Reports” mean the reports CSDVRS is required to file with the 
Commission pursuant to paragraph 13.
                                                
1
The investigation was originally identified as file number EB-11-TC-075.
2
The investigation was originally identified as file number EB-11-TC-024.
3
47 U.S.C. § 225.
4
47 C.F.R. §§ 64.604, 64.605.  
             Federal Communications Commission       DA 12-1844
(g) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which CSDVRS is 
subject by virtue of its business activities conducted pursuant to its certification as 
a VRS provider eligible to receive reimbursements from the TRS Fund.
(h) “Covered Personnel” means all employees, independent contractors, and agents of 
CSDVRS who perform, supervise, oversee, or manage duties that relate to the 
Company’s responsibilities under, and compliance with, Section 225 of the Act and 
the TRS Rules.
(i) “CSDVRS”, “ZVRS”, or “Company” means CSDVRS, LLC, and its predecessors-
in-interest and successors-in-interest.
(j) “Effective Date” means the date on which the Bureau releases the Adopting Order.
(k) “FCC Compliance Assessments” means a review conducted by CSDVRS to ensure 
that any Product offered to TRS users that generates minutes for which 
reimbursement will be sought from the TRS Fund complies with the 
Communications Laws.
(l) “Investigations” means the inquiries undertaken by the Enforcement Bureau 
regarding the Company’s compliance with Section 225 of the Act, 47 U.S.C. § 225,
and the TRS Rules, in File No.: EB-TCD-12-00000229 (formerly EB-11-TCD-
075) and File No.: EB-TC-12-00000346 (formerly EB-11-TC-024).
(m) “Operating Procedures” means the standard, internal operating procedures and 
compliance policies established by CSDVRS to implement the Compliance Plan.
(n) “Parties” means CSDVRS and the Bureau, each of which is a “Party.”
(o) “Products” means products, services, equipment, and software offered by CSDVRS 
to TRS users.
(p) “Refund Payment” means the payment to be made by CSDVRS to the TRS Fund 
and pursuant to this Consent Decree and described at paragraph 16.
(q) “Reimbursement Dates” means the dates on which CSDVRS received 
reimbursement from the TRS Fund for minutes handled.
(r) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(s) “TRS” means Telecommunications Relay Services, 47 C.F.R. § 64.601(a)(21).
(t) “TRS Fund” or “Fund” means the Telecommunications Relay Services Fund, 47 
C.F.R. § 64.604(c)(5)(iii).
(u) “TRS Fund administrator” or “Administrator” means the entity selected by the 
Commission to administer the TRS Fund, 47 C.F.R. § 64.604(c)(5)(iii).
(v) “TRS Rules” means the regulations set forth at Section 64.601 through Section 
64.613 of the Rules, 47 C.F.R. §§ 64.601 et. seq. and Commission orders 
             Federal Communications Commission       DA 12-1844
implementing and interpreting 47 U.S.C. § 225 of the Act, and any other 
Commission rules and orders applicable to TRS providers.
(w) “Voluntary Contribution” means the payment made by CSDVRS to the United 
States Treasury pursuant to this Consent Decree and described at paragraph 15.
(x) “VRS” means video relay service, 47 C.F.R. § 64.601(a)(27).
(y) “Work Number” means a ten-digit telephone number assigned to Covered Personnel 
in their capacity of working for or on behalf of the Company.
II. BACKGROUND
2. Section 225 of the Act requires the Commission to ensure that TRS is “available, to the 
extent possible and in the most efficient manner” to persons with hearing or speech disabilities in the 
United States.
5
  TRS provides “functionally equivalent” telephone service for persons with hearing or 
speech disabilities,
6
  but the cost of the services is recovered from the TRS Fund rather than from users of 
the service.
7
  The TRS Rules established the mandatory minimum standards for compensable services
8
and safeguards aimed at preventing reimbursement for minutes not handled in accordance with the TRS 
Rules.
9
   
3. Video Relay Service (VRS) is a form of Internet-based TRS.  VRS providers must be 
certified by the Commission to offer VRS to the public and receive compensation from the TRS Fund.
10   
Non-compensable call minutes include any minutes that were not handled in compliance with the 
Commission’s rules and orders.   
4. To ensure that proper payments are made from the TRS Fund, TRS providers seeking 
compensation from the Fund are required to submit true and adequate data to the TRS Fund administrator
about the calls for which they seek compensation.
11
  Effective February 15, 2011, VRS providers are also 
required to file a certification of compliance with all requests for reimbursement submitted to the 
                                                
5
47 U.S.C. § 225(b)(1); see Americans with Disabilities Act of 1990, Pub. L. No. 101-336, § 401, 104 Stat. 327, 
336-69 (1990). 
6
47 U.S.C. § 225(a)(3).  Relay services offered by providers shall be capable of handling any type of call normally 
provided by telecommunications carriers unless the Commission determines that it is technologically infeasible to 
do so.  Providers have the burden of proving technical infeasibility.  47 U.S.C. § 64.604(a)(3)(ii).
7
See 47 U.S.C. § 225(d)(1)(D) (regulations “require that users of [TRS] pay rates no greater than the rates paid for 
functionally equivalent voice communication services with respect to such factors as the duration of the call, the 
time of day, and the distance from point of origination to point of termination”); 47 C.F.R. § 64.604(c)(4).
8
See 47 C.F.R. § 64.604.  The mandatory minimum standards include provisions related to operational standards, 
technical standards, and functional standards. 
9
See, e.g., Structure and Practices of the Video Relay Service Program, Report and Order and Notice of Proposed 
Rulemaking, 26 FCC Rcd 5545 (2011).
10
47 C.F.R. § 64.604(c)(5)(iii)(N)(1)(ii) (requiring that effective June 1, only certified entities could offer VRS to 
the public and receive compensation from the TRS Fund).
11
47 C.F.R. § 64.604(c)(5)(iii)(D)(1).
             Federal Communications Commission       DA 12-1844
Administrator.
12
  This certification stipulates that the minutes being submitted for reimbursement were 
handled in compliance with the Commission’s rules and orders.
5. On March 11, 2011, the Bureau’s Telecommunications Consumers Division (TCD) 
issued a letter of inquiry (LOI) to CSDVRS seeking information on whether the Company was providing 
VRS in a manner that complied with the Commission’s rules and orders.
13
  CSDVRS responded to the 
LOI on April 11, 2011, by providing information on the Company’s internal operations, its various VRS 
offerings, and the processes CSDVRS implemented to comply with the Commission’s numbering orders 
and E911 requirements.
14
   On September 21, 2011, TCD initiated a second investigation into CSDVRS’s 
practices by issuing the Company a subpoena requiring the production of call detail records for VRS calls 
handled after May 31, 2011 which were routed through an External Uniform Resource Locator address 
and submitted to the TRS Fund administrator for reimbursement, in order to determine CSDVRS’s 
compliance with the Commission’s rule on the routing of VRS calls.
15
  The Company produced the 
required records on September 29, 2011.
16
  The Bureau and CSDVRS subsequently executed a tolling 
agreement to toll the statute of limitations associated with the second investigation.
17
III. TERMS OF AGREEMENT
6. 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.
7. Jurisdiction.  CSDVRS 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.
8. 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.
9. Termination of Investigations.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
                                                
12
47 C.F.R. § 64.604(c)(5)(iii)(I) (requiring that a senior executive of a provider submitting minutes to the Fund for 
compensation certify, under penalty of perjury, that the minutes were handled in compliance with Section 225 of the 
Act and the Commission's rules and orders).
13
See Letter from Richard A. Hindman, Chief, TCD, FCC Enforcement Bureau, to Sean Belanger, CEO, CSDVRS, 
LLC (March 11, 2011) (on file in EB-TCD-12-00000346).
14
See Letter from William Cobb, Vice President-Marketing, CSDVRS, LLC to Richard A. Hindman, Chief, TCD, 
FCC Enforcement Bureau (April 11, 2011) (on file in EB-TCD-12-00000346).
15
See Letter from Richard A. Hindman, Chief, TCD, FCC Enforcement Bureau, to Jeff Rosen, General Counsel, 
CSDVRS, LLC, Attach. Subpoena (Sept. 23, 2011) (on file in EB-TCD-12-00000229).
16
See Letter from Jeff Rosen, General Counsel CSDVRS, LLC, to Richard A. Hindman, Chief, TCD, FCC 
Enforcement Bureau (Sept. 29, 2011) (on file in EB-TCD-12-00000229).
17
See, Agreement, EB-TCD-12-00000229, executed by and between Richard A. Hindman, Chief, TCD, FCC 
Enforcement Bureau, and Jeff Rosen, General Counsel, CSDVRS, LLC on August 3, 2012.
             Federal Communications Commission       DA 12-1844
terminate the Investigations.  In consideration for the termination of the Investigations, CSDVRS 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 these Investigations 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 CSDVRS concerning the 
matters that were the subject of the Investigations.  The Bureau also agrees that in the absence of new 
material evidence it will not use the facts developed in these Investigations 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 CSDVRS with respect to CSDVRS’s basic qualifications, 
including its character qualifications, to be a Commission licensee or certified VRS provider, or to hold 
Commission certifications, licenses, or authorizations. The Bureau represents that, except for the 
Investigations, it has no other enforcement investigation or inquiry currently underway against CSDVRS 
that involves the same factual allegations underlying the Investigations.   
10. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, CSDVRS 
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 
CSDVRS 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 TRS Rules prior 
to assuming his/her duties.  CSDVRS’s Corporate and Regulatory Compliance Committee, comprised of 
CSDVRS senior management, will provide oversight for the Compliance Officer and the Compliance 
Plan.      
11. Compliance Plan.  For purposes of settling the matters set forth herein, CSDVRS agrees 
that it shall within sixty (60) calendar days after the Effective Date, develop, implement, and maintain a 
Compliance Plan designed to ensure future compliance with the Communications Laws and with the 
terms and conditions of this Consent Decree.  With respect to the TRS Rules, CSDVRS shall implement 
the following:
(a) Operating Procedures.   Within sixty (60) calendar days after the Effective Date, 
CSDVRS shall establish and maintain Operating Procedures that the Compliance 
Officer and all Covered Personnel must follow to help ensure CSDVRS’s 
compliance with the TRS Rules.  CSDVRS’s Operating Procedures shall, at a 
minimum, include internal procedures and policies specifically designed to ensure 
that CSDVRS operations are in compliance Section 225 of the Act and the TRS 
Rules applicable to any form of TRS offered or provided by CSDVRS.  In addition, 
the Operating Procedures must include procedures for conducting annual 
compliance training and documenting Covered Personnel participation in 
compliance training, procedures for conducting and maintaining documentation of 
FCC Compliance Assessments for all new Products, and procedures for reviewing 
requests for reimbursements from the TRS Fund prior to submissions to the TRS 
Fund administrator. 
(b) Compliance Manual.  Within sixty (60) calendar days after the Effective Date, the 
Compliance Officer shall develop and maintain a Compliance Manual and 
distribute the Compliance Manual to all Covered Personnel.  For any person who 
becomes Covered Personnel after the Effective Date, CSDVRS shall distribute the 
Compliance Manual to that person within thirty (30) calendar days after the date 
such person becomes Covered Personnel.  The Compliance Manual shall explain 
the TRS Rules related to any form of TRS offered by CSDVRS and the Operating 
             Federal Communications Commission       DA 12-1844
Procedures, and shall include information on how Covered Personnel may report 
waste, fraud, or abuse through the general hotline number and website address for 
the FCC’s Office of the Inspector General.  CSDVRS shall periodically review and 
revise the Compliance Manual as necessary to ensure that the information set forth 
therein remains current and complete.  CSDVRS shall distribute any revisions to 
the Compliance Manual to all Covered Personnel within thirty (30) calendar days 
of any revisions having been made.  
(c) Compliance Training Program. Within sixty (60) calendar days of the Effective 
Date, CSDVRS shall establish, implement, and maintain a Compliance Training 
Program to ensure compliance with the TRS Rules and the Operating Procedures.  
As part of the Compliance Training Program, Covered Personnel shall be advised 
of CSDVRS’s obligation to report any noncompliance with the TRS Rules under 
paragraph 12 of this Consent Decree and shall be instructed on how to disclose 
noncompliance to the Compliance Officer.  All Covered Personnel shall be trained 
pursuant to the Compliance Training Program within sixty (60) calendar days after 
the Effective Date, except that any person who becomes Covered Personnel at any 
time after the Effective Date shall be trained within thirty (30) calendar days after 
the date such person becomes Covered Personnel. CSDVRS 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.  
(d) Additional Compliance Measures.  Within sixty (60) calendar days after the 
Effective Date, the Company shall have assigned all Covered Personnel a Work 
Number, and shall have instructed all Covered Personnel in writing that they must 
use the Work Number whenever they access or use VRS for a business purpose, 
whether or not at the workplace.  The Company shall segregate and keep the call 
detail records for all Work Numbers to ensure that calls made by Covered 
Personnel in connection with business activities are identifiable as such and are not 
submitted to the TRS Fund administrator for compensation from the TRS Fund.  In 
addition, within sixty (60) calendar days after the Effective Date, CSDVRS shall: 
(i) revise the Company’s website to advise VRS users about how to make
emergency calls using any Product offered by the Company for which it seeks 
compensation from the TRS Fund; (ii) establish and maintain procedures for 
modifying or adding emergency calling advisories to all Product literature provided 
to the public; (iii)  develop and maintain a record of when Product literature was 
modified and used; and (iv) establish and maintain procedures for documenting and 
retaining FCC Compliance Assessments on new Products. 
12. Reporting Noncompliance.  CSDVRS shall report any noncompliance with the TRS 
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 CSDVRS 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 CSDVRS has taken or 
will take to prevent the recurrence of any such noncompliance.  All reports of noncompliance shall be 
submitted to the Chief, Telecommunications Consumers Division, Enforcement Bureau, Federal 
Communications Commission, Room 3-C366, 445 12th Street, S.W. Washington, D.C. 20554, with a 
copy submitted electronically to Sharon Lee at Sharon.Lee@fcc.gov and to fccebaccess@fcc.gov. 
             Federal Communications Commission       DA 12-1844
13. Compliance Reports.  CSDVRS 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 CSDVRS’s efforts 
during the relevant period to comply with the terms and conditions of this Consent 
Decree and the TRS Rules.  In addition, each Compliance Report shall include a 
certification by the Compliance Officer, as an agent of and on behalf of CSDVRS, 
stating that the Compliance Officer has personal knowledge that CSDVRS: (i) has 
established, implemented, and is maintaining 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 
12 herein.
(b) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and must be in the form set forth in 
Section 1.16 of the Rules
18
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 CSDVRS, 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 CSDVRS 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 CSDVRS 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, Telecommunications 
Consumers Division, Enforcement Bureau, Federal Communications Commission, 
445 12th Street, S.W., Washington, D.C. 20554, with a copy submitted 
electronically to Sharon Lee at Sharon.Lee@fcc.gov and to fccebaccess@fcc.gov.
14. Termination Date.  Unless stated otherwise, the obligations set forth in paragraphs 10
through 13 of this Consent Decree shall expire twenty-four (24) months after the Effective Date.
15. Voluntary Contribution.   CSDVRS agrees that it will make a Voluntary Contribution 
to the United States Treasury in the amount of nine hundred thousand dollars ($900,000) within thirty 
(30) calendar days after the Effective Date.  CSDVRS acknowledges and agrees that upon execution of 
this Consent Decree, the Voluntary Contribution shall become a “Claim” or “Debt” as defined in 31 
U.S.C. § 3701(b)(1).
19
Accordingly, and without further notice, demand, or presentment, upon an event of 
default by nonpayment of the contribution amount (as described below in paragraph 17), all procedures 
for collection permitted by the Debt Collection Improvement Act of 1996
20
and other provisions of law
21
                                                
18
47 C.F.R. § 1.16.
19
Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996).
20
Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (1996) (DCIA), codified in 
part at 31 U.S.C. §§ 3711, 3716, 3717, 3720B. 
21
See 31 C.F.R. Part 900, et seq.; 47 C.F.R. § 1.1901, et seq.
             Federal Communications Commission       DA 12-1844
may, at the Commission’s discretion, be initiated.  CSDVRS shall also send electronic notification of 
payment to Sharon Lee at Sharon.Lee@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 Account Number 
and FRN referenced above.  Regardless of the form of payment, a completed FCC Form 159 (Remittance 
Advice) must be submitted.
22
  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. Reimbursement to the TRS Fund.  CSDVRS agrees that it shall make a Refund 
Payment to the TRS Fund within thirty (30) calendar days after the Effective Date totaling $483,070.32,
which includes accrued interest calculated from the Reimbursement Date. CSDVRS acknowledges and 
agrees that upon execution of this Consent Decree, the amount of the Refund Payment is a “Claim” or 
“Debt” as defined in 31 U.S.C. § 3701(b)(1).  
17. Interest and Charges for Collection.  Upon an event of default under this Consent 
Decree, automatically and without further notice, the then entire unpaid amount of the Voluntary 
Contribution and Refund Payment shall accrue interest at a rate of 15.75% per annum from the date of the 
event of default until payment in full.  An event of default on either payment of the Voluntary 
Contribution or the Refund Payment will result in a cross default on both amounts. Upon an event of 
default, the then unpaid amount of the Voluntary Contribution and Refund Payment, together with 
interest, as aforesaid, any penalties permitted and/or required by the law, including but not limited to 
31 U.S.C. § 3717 and administrative charge(s), plus the costs of collection, litigation, and attorneys’ fees, 
is accelerated and shall become immediately due and payable, without notice, presentment, demand, 
protest, or notice of protest of any kind, all of which are waived by CSDVRS.
18. Waivers.  CSDVRS 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.  CSDVRS 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 
                                                
22
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
             Federal Communications Commission       DA 12-1844
judicial action to enforce the terms of the Adopting Order, neither CSDVRS nor the Commission shall 
contest the validity of the Consent Decree or of the Adopting Order, and CSDVRS shall waive any 
statutory right to a trial de novo.  CSDVRS hereby agrees to waive any claims it may have under the 
Equal Access to Justice Act, 5 U.S.C. § 504 and 47 C.F.R. § 1.1501 et seq., relating to the matters 
addressed in this Consent Decree.
19. Invalidity.  The Parties agree that if a court of competent jurisdiction renders any of the 
provisions of the Adopting Order or the Consent Decree  invalid or unenforceable, such invalidity or 
unenforceability shall not invalidate or render unenforceable the entire Adopting Order or Consent 
Decree, but rather the entire Adopting Order or Consent Decree shall be construed as if not containing the 
particular invalid or unenforceable provision or provisions, and the rights and obligations of the Parties 
shall be construed and enforced accordingly.  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.
20. 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 CSDVRS does not expressly 
consent) that provision will be superseded by such Rule or Commission order.
21. Successors and Assigns.  CSDVRS agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.  
22. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigations.  The Parties further 
agree that this Consent Decree does not constitute an admission or denial of liability, an adjudication on 
the merits, or a factual or legal finding or determination regarding any compliance or noncompliance with 
the Communications Laws.
23. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
24. 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.
25. Authorized Representative.  The individual signing this Consent Decree on behalf of 
CSDVRS represents and warrants that he is authorized by CSDVRS to execute this Consent Decree and 
to bind CSDVRS to the obligations, including all payment 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.
             Federal Communications Commission       DA 12-1844
26. 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
_______________________________
Sean Belanger
Chief Executive Officer
CSDVRS, LLC
______________________________
Date