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Before the
Federal Communications Commission
Washington, D.C. 20554
)
In the Matter of )
File No.: EB-08-IH-1203
FISHER BROADCASTING - SEATTLE RADIO, )
L.L.C. Acct. No.: 201232080021
)
Licensee of Station KVI(AM), FRN: 0005848080
)
Seattle, Washington Facility ID No.: 35853
)
)
ORDER
Adopted: May 24, 2012 Released: May 25, 2012
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered into
between the Enforcement Bureau (Bureau) and Fisher Broadcasting -
Seattle Radio, L.L.C. (Licensee). The Consent Decree terminates an
investigation by the Bureau against the Licensee for possible
violations of Section 508 of the Communications Act of 1934, as
amended (Act), and Section 73.1216 of the Commission's rules (Rules),
in connection with a licensee-conducted contest broadcast by the
Licensee on Station KVI(AM), Seattle, Washington (Station) in 2007.
2. The Bureau and the Licensee have negotiated the terms of the Consent
Decree that resolve this matter. 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 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 the Licensee 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 Section 4(i) of the Act,
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, as to
the Station and/or the Licensee, IS TERMINATED.
7. IT IS FURTHER ORDERED that any third-party complaints and allegations
against the Station and/or the Licensee before the Enforcement Bureau
related to the above-captioned investigation as of the date of this
Consent Decree ARE DISMISSED.
8. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
shall be sent by both First Class mail and Certified Mail, Return
Receipt Requested, to Licensee's counsel, Clifford M. Harrington,
Esq., Pillsbury Winthrop Shaw Pittman LLP, 2300 N Street, N.W.,
Washington, D.C. 20037-1128.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Before the
Federal Communications Commission
Washington, D.C. 20554
)
In the Matter of )
File No.: EB-08-IH-1203
FISHER BROADCASTING - SEATTLE RADIO, )
L.L.C. Acct. No.: 201232080021
)
Licensee of Station KVI(AM), FRN: 0005848080
)
Seattle, Washington Facility ID No.: 35853
)
)
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and
Fisher Broadcasting - Seattle Radio, L.L.C., by their authorized
representatives, hereby enter into this Consent Decree for the purpose
of terminating the Bureau's investigation into possible violations of
Section 508 of the Communications Act of 1934, as amended, and Section
73.1216 of the Commission's rules, pertaining to Licensee-Conducted
contests.
I. DEFINITIONS
2. 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 Fisher is subject by virtue of it being a Commission licensee,
including but not limited to Section 508 of the Act and Section
73.1216 of the Commission's 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 Fisher who
perform, or supervise, oversee, or manage the performance of, duties
that relate to Fisher's responsibilities under Section 508 of the Act
and the Licensee-Conducted Contest Rule.
h. "Effective Date" means the date on which the Commission releases the
Adopting Order.
i. "Investigation" means the investigation commenced by the Bureau in
response to Fisher's April 18, 2008, letter to the Commission
regarding Fisher's "Secret Listener Salute" contest.
j. "Fisher" means Fisher Broadcasting - Seattle Radio, L.L.C. and its
predecessors-in-interest and successors-in-interest.
k. "Licensee-Conducted Contest Rule" means Section 73.1216 of the Rules,
47 C.F.R. S: 73.1216, governing how Commission licensees conduct
contests that are broadcast or advertised.
l. "Operating Procedures" means the standard, internal operating
procedures and compliance policies established by Fisher to implement
the Compliance Plan.
m. "Parties" means Fisher and the Bureau, each of which is a "Party."
n. "Rules" means the Commission's regulations found in Title 47 of the
Code of Federal Regulations.
o. "Section 508" means Section 508 of the Communications Act of 1934, as
amended, which prohibits a licensee from knowingly deceiving the
public by engaging "in any artifice or scheme for the purpose of
prearranging or predetermining in whole or in part the outcome of a
purportedly bona fide contest . . . [of] chance." 47 U.S.C. S:
509(a)(3). In addition, Section 508 also prohibits: (1) the production
for broadcast of a contest of chance wherein the person has reasonable
ground for believing that the contest outcome has been predetermined;
and (2) conspiring with any other person or persons to violate the
statute. 47 U.S.C. S:S: 509(a)(4)-(5).
p. "Station" means radio Station KVI(AM), Seattle, Washington (Facility
ID No. 35853).
II. BACKGROUND
2. Section 508 of the Act prohibits a licensee from knowingly deceiving
the public by engaging "in any artifice or scheme for the purpose of
prearranging or predetermining in whole or in part the outcome of a
purportedly bona fide contest . . . [of] chance." Under Section
73.1216 of the Rules, a broadcast licensee "that broadcasts or
advertises information about a contest it conducts shall fully and
accurately disclose the material terms of the contest, and shall
conduct the contest substantially as announced or advertised. No
contest description shall be false, misleading or deceptive with
respect to any material term." Material terms, among other things,
include any eligibility restrictions, means of selection of winners,
and the extent, nature, and value of prizes.
3. On April 18, 2008, Fisher, through its Counsel, filed a letter with
the Commission regarding its own Contest, called the "Secret Listener
Salute" that aired on Station KVI(AM) between February 6, 2007, and
March 30, 2007. The Licensee asserts that, as part of an internal year
end audit in 2008, it discovered that a former employee may have taken
actions to manipulate the outcome of the Contest by placing the names
of suspected friends and acquaintances on the list of names to be
announced on air, thus making them potential winners. Fisher indicates
that winnings may have been shared between the former employee and the
winners. Fisher states that it discovered this problem after the
employee left Fisher's employ, and that Fisher subsequently contacted
the Seattle Police Department. On June 24, 2008, the Bureau sent a
letter to Fisher regarding the Contest, and Fisher responded on July
30, 2008. The Bureau subsequently sent a second letter to Fisher on
May 7, 2010, to which Fisher responded on June 3, 2010. Fisher
contends that it was unaware of the former employee's actions until
after she had left the Station's employ, that it was an unwitting
victim in this situation, and that it alerted the Commission and law
enforcement once it determined what had happened. Fisher contends that
the actions of the former employee violated the Station's Code of
Conduct and Conflict of Interest Policies that were in place at the
time the alleged violations occurred. Fisher claims that it will
create added oversight to all future contests and monitor their
implementation to safeguard against any future manipulations by any
party. The terms of this Consent Decree reflect the Bureau's
consideration of the Licensee's self-disclosure of this matter and the
Licensee's prior history of compliance with Commission rules.
III. TERMS OF AGREEMENT
4. 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.
5. Jurisdiction. Fisher 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.
6. 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.
7. 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, Fisher 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 this
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
Fisher 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 Fisher with
respect to Fisher's basic qualifications, including its character
qualifications, to be a Commission licensee or to hold Commission
licenses or authorizations.
8. Compliance Officer. Within thirty (30) calendar days after the
Effective Date, Fisher 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
person designated as the Compliance Officer shall be responsible for
developing, implementing, and administering the Compliance Plan and
ensuring that Fisher 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 Section 508 of the Act and the
Licensee-Conducted Contest Rule prior to assuming his/her duties.
9. Compliance Plan. For purposes of settling the matters set forth
herein, Fisher agrees that it shall, within sixty (60) calendar days
of the Effective Date, develop and implement a Compliance Plan
designed to ensure future compliance with the Communications Laws,
including Section 508 of the Act and Section 73.1216 of the
Commission's rules, and with the terms and conditions of this Consent
Decree. The Compliance Plan shall include, without limitation, the
following components:
a. Operating Procedures for Licensee-Conducted Contests. Within sixty (60)
calendar days after the Effective Date, Fisher shall establish Operating
Procedures that all Covered Employees must follow to help ensure Fisher's
compliance with Section 508 of the Act and the Licensee-Conducted Contest
Rule. Fisher's Operating Procedures shall include internal procedures and
policies specifically designed to ensure that the outcomes of Fisher's
Licensee- Conducted contests are not predetermined or prearranged, in
violation of Section 508 of the Act, and that Fisher fully and accurately
discloses the material terms of its contests, and conducts the contests
substantially as announced or advertised, consistent with Section 73.1216
of the Commission's rules. Fisher also shall develop a Compliance
Checklist that describes the steps that a Covered Employee must follow to
ensure that Licensee-Conducted contests will not result in a violation of
the Commission's Laws regarding Licensee-Conducted contests. At a minimum,
the Compliance Checklist shall require at all times that at least two
station employees, one of which shall be a management-level employee, be
involved in all aspects of the selection of winners and the award of
prizes to participants in Licensee-Conducted contests.
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
Section 508 of the Act and the Licensee-Conducted Contest Rule, and set
forth the Operating Procedures that Covered Employees shall follow to help
ensure Fisher's compliance with the Communications Laws. Fisher shall
periodically review and revise the Compliance Manual as necessary to
ensure that the information set forth therein remains current and
complete. Fisher shall distribute any revisions to the Compliance Manual
promptly to all Covered Employees.
c. Compliance Training Program. Fisher shall establish and implement a
Compliance Training Program on compliance with Section 508 of the Act, the
Licensee-Conducted Contest Rule and the Operating Procedures. As part of
the Compliance Training Program, Covered Employees shall be advised of
Fisher's obligation to report any noncompliance with Section 508 of the
Act or the Licensee-Conducted Contest Rule 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 ninety (90) 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.
Fisher 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.
10. Reporting Noncompliance. Fisher shall report any noncompliance with
Section 508 of the Act, the Licensee-Conducted Contest Rule, and with
the terms and conditions of this Consent Decree within thirty (30)
calendar days after discovery of such noncompliance. Such reports
shall include a detailed explanation of (i) each instance of
noncompliance; (ii) the steps that Fisher 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 Fisher has taken or
will take to prevent the recurrence of any such noncompliance. All
reports of noncompliance shall be submitted to the Chief,
Investigations and Hearings Division, Enforcement Bureau, Federal
Communications Commission, Room 4-C330, 445 12th Street, S.W.,
Washington, D.C. 20554, with a copy submitted electronically to
Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov, Jeffrey J. Gee at
Jeffrey.Gee@fcc.gov, Kenneth M. Scheibel, Jr. at
Kenneth.Scheibel@fcc.gov, and to Amelia Brown at Amelia.Brown@fcc.gov.
The reporting obligations set forth in this paragraph 11 shall expire
thirty-six (36) months after the Effective Date.
11. Compliance Reports. Fisher shall file Compliance Reports with the
Commission ninety (90) days after the Effective Date, twelve (12)
months after the Effective Date, twenty-four (24) months after the
Effective Date, and thirty six (36) months after the Effective Date.
a. Each compliance report shall include a detailed description of Fisher's
efforts during the relevant period to comply with the terms and conditions
of this Consent Decree, Section 508 of the Act, and the Licensee-Conducted
Contest Rule. In addition, each Compliance Report shall include a
certification by the Compliance Officer, as an agent of and on behalf of
Fisher, stating that the Compliance Officer has personal knowledge that
Fisher (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 Fisher, 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 Fisher has taken or will take to remedy such noncompliance, including
the schedule on which proposed remedial action will be taken; and (iii)
the steps that Fisher 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, Investigations
and Hearings Division, Enforcement Bureau, Federal Communications
Commission, Room 4-C330, 445 12th Street, S.W., Washington, D.C. 20554,
with a copy submitted electronically to Theresa Z. Cavanaugh at
Terry.Cavanaugh@fcc.gov, Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, Kenneth M.
Scheibel, Jr. at Kenneth.Scheibel@fcc.gov, and to Amelia Brown at
Amelia.Brown@fcc.gov.
12. Termination Date. Unless stated otherwise, the requirements set forth
in paragraphs 9 through 12 of this Consent Decree shall expire
thirty-six (36) months after the Effective Date.
13. Section 508 and Section 73.1216 Complaints; Subsequent Investigations.
Nothing in this Consent Decree shall prevent the Commission or its
delegated authority from adjudicating complaints filed pursuant to
Section 508 of the Act or Section 73.1216 of the Commission's rules
against Fisher or its affiliates for alleged violations of the Act or
the Commission's rules 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 Fisher with the
Communications Laws.
14. Voluntary Contribution. Fisher agrees that it will make a voluntary
contribution to the United States Treasury in the amount of seven
thousand dollars ($7,000). The payment must be made within thirty (30)
days after the Effective Date. The payment must be made by check or
similar instrument, payable to the order of the Federal Communications
Commission. The payment must include the Account Number and FRN
referenced in the caption to the Adopting Order. 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. Payment by credit card may be made by submitting
credit card account information and an authorized signature on FCC
Form 159 (Remittance Advice). Regardless of the form of payment, a
completed FCC Form 159 must be submitted at the time of payment. 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). Fisher shall also send electronic
notification to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov,
Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, Kenneth M. Scheibel, Jr. at
Kenneth.Scheibel@fcc.gov, and to Amelia Brown at Amelia.Brown@fcc.gov
on the date said payment is made.
15. Waivers. Fisher 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. Fisher 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 Fisher nor the Commission shall contest the
validity of the Consent Decree or the Adopting Order, and Fisher shall
waive any statutory right to a trial de novo. Fisher hereby agrees to
waive any claims it may have under the Equal Access to Justice Act, 5
U.S.C. S: 504 and 47 C.F.R. S: 1.1501 et seq., relating to the matters
addressed in this Consent Decree.
16. Liability. Fisher admits, solely for the purpose of this Consent
Decree and for Commission civil enforcement purposes, and in express
reliance on the provisions of paragraph 8 hereof, that the broadcast
material at issue in this Consent Decree is in violation of 47 U.S.C.
S: 509 and 47 C.F.R. S: 73.1216, assuming construction of these terms
as they are construed by the Bureau as of the date hereof.
Notwithstanding any other provision of this Consent Decree, it is
expressly agreed and understood that if this Consent Decree, or
paragraph 8 hereof, or both, are breached by the Bureau, or are
invalidated or modified to Fisher's prejudice by the Commission,
Bureau, or any court, then and in that event the provisions of the
immediately-preceding sentence shall be of no force or effect
whatever, and Fisher shall not, by virtue of that sentence or any
other provision of this Consent Decree, be deemed to have made any
admission concerning violations of 47 U.S.C. S: 509 or 47 C.F.R. S:
73.1216.
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 Fisher does not expressly
consent) that provision will be superseded by such rule or Commission
order.
19. Successors and Assigns. Fisher 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.
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 Fisher represents and warrants that he is authorized by
Fisher to execute this Consent Decree and to bind Fisher 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
________________________________
Robert I. Dunlop
Executive Vice President Operations
Fisher Broadcasting - Seattle Radio, L.L.C.
________________________________
Date
See 47 U.S.C. S: 509 (titled "Prohibited Practices in Case of Contests of
Intellectual Knowledge, Intellectual Skill, or Chance").
See 47 C.F.R. S: 73.1216 (titled "Licensee-Conducted Contests").
See 47 U.S.C. S: 154(i).
See 47 C.F.R. S:S: 0.111, 0.311.
See 47 U.S.C. S: 509.
See 47 C.F.R. S: 73.1216.
47 U.S.C. S: 509(a)(3). Section 508 also prohibits: (1) the production for
broadcast of a contest of chance wherein the person has reasonable ground
for believing that the contest outcome has been predetermined; (2)
conspiring with any other person or persons to violate the statute. 47
U.S.C. S:S: 509(a)(4)-(5).
47 C.F.R. S: 73.1216.
See id., Notes 1(b), 2.
See Letter from Clifford M. Harrington, Esq., Pillsbury Winthrop Shaw
Pittman LLP, Counsel for Fisher Broadcasting - Seattle Radio, L.L.C.
(Counsel) to Hillary S. DeNigro, Chief, Investigations and Hearings
Division, FCC Enforcement Bureau (April 18, 2008) (on file in
EB-08-IH-1203) (Fisher April 18 Letter).
Id. at 1.
Id.
Id.
See Letter from Kenneth M. Scheibel, Jr., Assistant Chief, Investigations
and Hearings Division, FCC Enforcement Bureau, to Counsel (June 24, 2008)
(on file in EB-08-IH-1203).
See Letter from Counsel to Marlene Dortch, Secretary, Federal
Communications Commission (July 30, 2008) (on file in EB-08-IH-1203)
(Fisher July 30 Letter).
See Letter from Anjali K. Singh, Acting Assistant Chief, Investigations
and Hearings Division, FCC Enforcement Bureau, to Counsel (May 7, 2010)
(on file in EB-08-IH-1203).
See Letter from Counsel to Marlene Dortch, Secretary, Federal
Communications Commission (June 3, 2010) (on file in EB-08-IH-1203).
See Fisher April 18 Letter at 1. According to court records, Ms. Ryan
Keeley, Fisher's former Promotions Coordinator at the Station, was
convicted by a King County, Washington, court and ordered to pay $14,000
in restitution after pleading guilty to second-degree theft for her role
in the Contest. Washington v. Keeley, et al., No. 10C-00364-5 SEA (King
Cnty. Sup. Ct. 2010). Keeley pled guilty to violating RCW 9A.56.040(1)(a)
and 9A.56.020(1)(b) of the Revised Washington criminal code. See also
Jennifer Sullivan, KVI Ex-employee Sentenced for Rigging Radio Contest,
Seattle Times online edition, July 30, 2010,
http://seattletimes.nwsource.com/html/localnews/2012494429_riggedcontest31m.html
(last visited Sept. 16, 2011).
See Fisher July 30 Letter at 16-17.
See Fisher April 18 Letter at 1-2.
47 C.F.R. S: 1.16
Federal Communications Commission DA 12-773
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Federal Communications Commission DA 12-773