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                                   Before the

   Federal Communications Commission

   Washington, D.C. 20554


                                            )                                
                                                                             
     In the Matter of                       )                                
                                                File No.: EB-10-KC-0122      
     Insight Consulting Group of Kansas     )                                
     City, LLC                                  NAL/Acct. No.: 201132560005  
                                            )                                
     Kansas City, MO                            FRN: 0018534495              
                                            )                                
                                                                             
                                            )                                


                                FORFEITURE ORDER

   Adopted: March 23, 2012 Released: March 23, 2012

   By the Regional Director, South Central Region, Enforcement Bureau:

   I. INTRODUCTION

    1. In this Forfeiture Order (Order), we issue a monetary forfeiture in
       the amount of sixteen thousand dollars ($16,000) to Insight Consulting
       Group of Kansas City, LLC (Insight), operator of an Unlicensed
       National Information Infrastructure (U-NII) transmission system in
       Kansas City, Missouri for willful and repeated violation of Section
       301 of the Communications Act of 1934, as amended (Act) and Section
       15.1(b) of the Commission's rules (Rules). The noted violations
       involved Insight's operation of intentional radiators not in
       accordance with Part 15 of the Rules and without a license.

   II. BACKGROUND

    2. On July 29, 2011, the Enforcement Bureau's Kansas City Office (Kansas
       City Office) issued a Notice of Apparent Liability for Forfeiture 
       (NAL)  to Insight for operation of intentional radiators not in
       accordance with Part 15 of the Rules and without a license. As
       discussed in detail in the NAL, agents from the Kansas City Office
       determined that Insight operated two U-NII transmitters on frequencies
       for which they were not authorized, in violation of the devices'
       equipment authorization, and thereby requiring a license. In view of
       the record evidence and the fact that Insight's unlicensed operations
       caused interference to the Federal Aviation Administration's Terminal
       Doppler Weather Radar installation serving the Kansas City
       International Airport, the NAL proposed a $17,000 forfeiture against
       Insight for violation of Section 301 of the Act. Insight submitted
       documentation of its finances and  requested reduction of the proposed
       forfeiture.

   III. DISCUSSION

    3. The proposed forfeiture amount in this case was assessed in accordance
       with Section 503(b) of the Act, Section 1.80 of the Rules, and the
       Forfeiture Policy Statement. In examining Insight's response, Section
       503(b) of the Act requires that the Commission 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 other such matters as justice may
       require. As discussed below, we have considered Insight's response in
       light of these statutory factors, and we reduce the forfeiture to
       $16,000 based solely on its documented inability to pay.

    4. As set forth in the NAL, agents from the Kansas City Office determined
       that Insight operated two U-NII transmitters on frequencies for which
       the devices were not authorized on February 4 and 28, 2011.
       Accordingly, because Insight's operations were not consistent with the
       devices' equipment authorization and Part 15 of the Rules, its
       operations required a license. In its response to the NAL, Insight
       does not deny any of these facts. Accordingly, we find that Insight
       willfully and repeatedly violated Section 301 of the Act and Section
       15.1(b) of the Rules by operating unlicensed radio transmitters.

    5. With regard to an individual or entity's inability to pay claim, the
       Commission has determined that, in general, gross revenues are the
       best indicator of an ability to pay a forfeiture. Based on the
       financial documents and other materials provided by Insight, we find
       sufficient basis to reduce the forfeiture to $16,000.

   IV. ORDERING CLAUSES

    6. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the
       Communications Act of 1934, as amended, and Sections 0.111, 0.204,
       0.311, 0.314, and 1.80(f)(4) of the Commission's rules, Insight
       Consulting Group of Kansas City, LLC IS LIABLE FOR A MONETARY
       FORFEITURE in the amount of sixteen thousand dollars ($16,000) for
       violations of Section 301 of the Act and Section 15.1(b) of the
       Commission's rules.

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

    8. IT IS FURTHER ORDERED that a copy of this Order shall be sent by both
       First Class and Certified Mail Return Receipt Requested to Insight
       Consulting Group of Kansas City, LLC at 600 E. Admiral Blvd., Suite
       1201, Kansas City, MO 64106 and to its attorney, Lewis H. Goldman,
       P.C., 45 Dudley Court, Bethesda, MD 20814.

   FEDERAL COMMUNICATIONS COMMISSION

   Dennis P. Carlton

   Regional Director, South Central Region

   Enforcement Bureau

   47 U.S.C. S: 301; 47 C.F.R. S: 15.1(b).

   47 C.F.R. S:S: 15.1 et seq.

   Insight Consulting Group of Kansas City, LLC, Notice of Apparent Liability
   for Forfeiture, 26 FCC Rcd 10699 (Enf. Bur. 2011).

   Id. A comprehensive recitation of the facts and history of this case can
   be found in the NAL and is incorporated herein by reference.

   Id. at 2480.

   Email from Lewis H. Goldman, P.C., Attorney for Insight, to Diane Law-Hsu,
   Regional Counsel, South Central Region, Enforcement Bureau (Oct. 5, 2011
   4:20 P.M. EST).

   47 U.S.C. S: 503(b).

   47 C.F.R. S: 1.80.

   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, 15 FCC Rcd 303 (1999) (Forfeiture
   Policy Statement).

   47 U.S.C. S: 503(b)(2)(E).

   NAL at 10700-10701.

   See PJB Communications of Virginia, Inc., Forfeiture Order, 7 FCC Rcd
   2088, 2089 (1992) (forfeiture not deemed excessive where it represented
   approximately 2.02 percent of the violator's gross revenues); Local Long
   Distance, Inc., Forfeiture Order, 16 FCC Rcd 24385 (2000) (forfeiture not
   deemed excessive where it represented approximately 7.9 percent of the
   violator's gross revenues); Hoosier Broadcasting Corporation, Forfeiture
   Order, 15 FCC Rcd 8640 (2002) (forfeiture not deemed excessive where it
   represented approximately 7.6 percent of the violator's gross revenues).

   This forfeiture amount falls within the percentage range that the
   Commission has previously found acceptable. See supra note 12.

   47 U.S.C. S:S: 301, 503(b); 47 C.F.R. S:S: 0.111, 0.204, 0.311, 0.314,
   1.80(f)(4), 15.1(b).

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

   Federal Communications Commission DA 12-282

   3

   Federal Communications Commission DA 12-282