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                       Federal Communications Commission

                             Washington, D.C. 20554


                        )                                
                                                         
                        )   File No.: EB-12-IH-0076      
     In the Matter of                                    
                        )   NAL/Acct. No.: 201332080008  
     StanaCard, LLC                                      
                        )   FRN: 0018463380              
                                                         
                        )                                


                  NOTICE OF APPARENT LIABILITY FOR FORFEITURE

   Adopted: January 24, 2013 Released: January 24, 2013

   By the Chief, Investigations and Hearings Division, Enforcement Bureau:

   I. INTRODUCTION

    1. In this Notice of Apparent Liability for Forfeiture (NAL), we find
       that StanaCard, LLC (StanaCard) apparently violated Section 214 of the
       Communications Act of 1934, as amended and Sections 63.03, 63.04,
       63.18, and 63.24 of the Commission's rules (Rules) in connection with
       StanaCard's unauthorized transfer of control of its domestic and
       international Section 214 authority.  Based on our review of the facts
       and circumstances surrounding these matters, and for the reasons
       discussed below, we find that StanaCard is apparently liable for
       forfeiture penalties totaling twenty-one thousand dollars ($21,000).

   II. BACKGROUND

    2. Section 214 of the Act requires telecommunications carriers to obtain
       a certificate of public convenience and necessity from the Commission
       before constructing, acquiring, operating, or engaging in the
       transmission of common carrier communications services over
       communications lines, and before discontinuing, reducing, or impairing
       service to a community. In accordance with Sections 63.03 and 63.24 of
       the Rules, any "substantial" transfer of control of a carrier's lines
       or of Section 214 authority requires application to and prior approval
       from the Commission. Sections 63.04 and 63.18 of the Rules set forth
       the information that must be included in the domestic and
       international transfer of control applications.

    3. "Non-substantial" (or "pro forma")  transfers of a carrier's lines or
       of Section 214 authority do not require Commission approval prior to
       consummation. A carrier that consummates a pro forma international
       Section 214 transaction, however, must provide notice of that
       transaction to the Commission no later than 30 days after
       consummation. This notification requirement generally does not extend
       to pro forma domestic Section 214 transactions.

    4. StanaCard, a Delaware limited liability company, is a resale provider
       primarily of prepaid international telecommunications services. On
       February 1, 2010, the Commission's International Bureau (IB) granted
       international Section 214 authority to StanaCard. At that time, the
       Company also obtained blanket domestic Section 214 authority by
       operation of the Rules.

    5. On January 27, 2012, StanaCard self-disclosed to the Enforcement
       Bureau (Bureau) that it apparently had: (a) failed to timely notify
       the Commission of a pro forma transfer of control of international
       Section 214 authority during 2010 and (b) had not obtained Commission
       approval before consummating a substantial transfer of control of
       domestic and international Section 214 authority during 2010. In
       response, the Bureau launched an investigation.

    6. Prior to October 23, 2010, Michael Choupak held an 88.88 percent
       membership interest (8000 out of a total of 9000 Class A Units) in
       StanaCard and was its managing member. On October 23, 2010, Mr.
       Choupak transferred half of that membership interest (44.44 percent or
       4000 Class A Units) to Anastasia Koroleva. Mr. Choupak retained a
       44.44 percent membership interest in StanaCard and remained its
       managing member. StanaCard did not notify the Commission of this
       transaction until February 15, 2012. On February 16, 2012, IB granted
       StanaCard's application for approval of this transaction.

    7. In a separate transaction, on June 21, 2011 Mr. Choupak transferred
       his remaining 44.44 percent membership interest in StanaCard to Ms.
       Koroleva, who then held an 88.88 percent membership interest (8000
       Class A Units) in StanaCard.  On the same day, Mr. Choupak resigned
       his role as managing member and Ms. Koroleva was elected as his
       replacement, putting her in control of the Company. On January 17,
       2012, StanaCard filed an application for a substantial transfer of
       control of StanaCard's domestic and international Section 214
       authority from Mr. Choupak to Ms. Koroleva as well as requests for
       Special Temporary Authority (STA) to continue providing domestic and
       international service while its transfer of control application was
       pending.  On January 26, 2012, IB and the Commission's Wireline
       Competition Bureau (WCB) granted StanaCard's STA requests. On March 2,
       2012 and March 9, 2012, IB and WCB respectively approved the transfer
       of control of StanaCard's international and domestic Section 214
       authority from Mr. Choupak to Ms. Koroleva.

   III. DISCUSSION

    8. Under Section 503(b)(1) of the Act, any person who is determined by
       the Commission to have willfully or repeatedly failed to comply with
       any provision of the Act or any rule, regulation, or order issued by
       the Commission shall be liable to the United States for a forfeiture
       penalty. Section 312(f)(1) of the Act defines willful as "the
       conscious and deliberate commission or omission of [any] act,
       irrespective of any intent to violate" the law. The legislative
       history to Section 312(f)(1) of the Act clarifies that this definition
       of willful applies to both Sections 312 and 503(b) of the Act, and the
       Commission has so interpreted the term in the Section 503(b) context.
       The Commission may also assess a forfeiture for violations that are
       merely repeated, and not willful. "Repeated" means that the act was
       committed or omitted more than once, or lasts more than one day. To
       impose such a forfeiture penalty, the Commission must issue a notice
       of apparent liability, and the person against whom the notice has been
       issued must have an opportunity to show, in writing, why no such
       forfeiture penalty should be imposed. The Commission will then issue a
       forfeiture if it finds, based on the evidence, that the person has
       violated the Act or a Rule.

    9. The issues in this case are whether StanaCard apparently violated
       Section 214 of the Act and Sections 63.03, 63.04, 63.18, and 63.24 of
       the Rules by willfully or repeatedly failing to provide timely notice
       of a pro forma transfer of control of international Section 214
       authority and by willfully or repeatedly engaging in unauthorized
       transfers of control of its domestic and international Section 214
       authority. We answer these questions in the affirmative. StanaCard
       apparently failed to give timely notice of a pro forma transfer of
       control of international Section 214 authority and apparently
       neglected to obtain prior authority for the substantial transfers of
       control of domestic and international Section 214 authority. Based on
       the facts and circumstances before us, we conclude that StanaCard is
       apparently liable for forfeiture penalties totaling twenty-one
       thousand dollars ($21,000).

   10. Section 63.24(f) of the Rules requires that a carrier provide notice
       to the Commission that it has consummated a pro forma international
       Section 214 transaction no later than 30 days after such consummation.
       We conclude that StanaCard apparently willfully or repeatedly violated
       this Rule in connection with Mr. Choupak's October 23, 2010 assignment
       of half of his 88.88 percent membership interest in StanaCard to Ms.
       Koroleva, giving her a 44.44 percent membership interest in the
       Company. As a result of this transaction, Mr. Choupak and Ms. Koroleva
       held equal membership interests in StanaCard, but Mr. Choupak retained
       his position as the managing member, which kept him in de facto
       control of the Company. StanaCard apparently failed to provide notice
       to the Commission of this pro forma transfer of control of an
       international Section 214 authorization within 30 days after the
       October 23, 2010 transaction. StanaCard did not notify the Commission
       of this pro forma international Section 214 transaction until nearly
       15 months after the date the transaction notification was due.  Based
       on a preponderance of the evidence, we find that StanaCard apparently
       willfully or repeatedly violated Section 214 of the Act and Section
       63.24(f) of the Rules.

   11. We also conclude that StanaCard apparently violated Section 214 and
       related Rules by consummating substantial transfers of control of a
       domestic Section 214 authority and an international Section 214
       authority without prior Commission approval. These two apparent
       violations arose from the June 21, 2011 transfer by Mr. Choupak of all
       of his membership interest in StanaCard to Ms. Koroleva, his
       resignation as manager of the Company, and the election of Ms.
       Koroleva as StanaCard's managing member. These transactions
       transferred ultimate control of domestic and international Section 214
       authority from Mr. Choupak to Ms. Koroleva. These apparent violations
       persisted for over six months before StanaCard filed corrective
       applications. Based on a preponderance of the evidence, we therefore
       find that in two instances StanaCard apparently willfully or
       repeatedly violated Section 214 of the Act and Sections 63.03, 63.04,
       63.18, and 63.24 of the Rules.

   12. Section 503(b)(1) of the Act provides that any person who willfully or
       repeatedly fails to comply with any provision of the Act or any rule,
       regulation, or order issued by the Commission shall be liable to the
       United States for a forfeiture penalty. Section 503(b)(2)(B) of the
       Act authorizes the Commission to assess a forfeiture of up to $150,000
       for each violation or each day of a continuing violation by a common
       carrier, up to a statutory maximum of $1,500,000 for a single act or
       failure to act. In determining the appropriate forfeiture amount, we
       consider the factors enumerated in Section 503(b)(2)(E) of the Act,
       including "the nature, circumstances, extent, and gravity of the
       violation and, with respect to the violator, the degree of
       culpability, any history of prior offenses, ability to pay, and such
       other matters as justice may require," as well as our forfeiture
       guidelines.

   13. Section 1.80 of the Rules establishes a base forfeiture amount of
       $1,000 for an "unauthorized pro forma transfer of control." We find
       that StanaCard apparently engaged in one unauthorized pro forma
       international Section 214 transfer of control. Accordingly, we find
       that StanaCard is apparently liable for a forfeiture of one thousand
       dollars ($1,000) for its willful or repeated failure to timely notify
       the Commission of one pro forma international Section 214 transfers of
       control.

   14. Section 1.80 of the Rules establishes a base forfeiture amount of
       $8,000 for an "unauthorized substantial transfer of control." The
       Commission has applied that same forfeiture amount to substantial
       transfers of international Section 214 authority. StanaCard engaged in
       two unauthorized substantial transfers of control. These two
       unauthorized Section 214 transactions persisted for more than six
       months before StanaCard filed corrective STA requests, which were
       granted. Taking the duration of these delays into account and applying
       the factors set forth in Section 503(b)(2)(E) of the Act as well as
       Commission precedent, we find that the appropriate forfeiture amount
       for the two unauthorized substantial transfers of control is twenty
       thousand dollars ($20,000).

   IV. CONCLUSION

   15. In light of the seriousness, duration, and scope of the apparent
       violations, we propose forfeitures totaling twenty-one thousand
       dollars ($21,000) against StanaCard, consisting of one thousand
       dollars ($1,000) for failure to timely notify the Commission of one
       pro forma transfer of control of international Section 214 authority
       and twenty thousand dollars ($20,000) for two unauthorized substantial
       transfers of control of domestic and international Section 214
       authority.

   V. ORDERING CLAUSES

   16. ACCORDINGLY, IT IS ORDERED that, pursuant to Section 503(b) of the
       Act, and Section 1.80 of the Rules, StanaCard, LLC is hereby NOTIFIED
       OF ITS APPARENT LIABILITY FOR A FORFEITURE in the amount of twenty-one
       thousand dollars ($21,000) for willfully or repeatedly violating
       Section 214(a) of the Communications Act of 1934, as amended, 47
       U.S.C. S: 214(a), and Sections 63.03, 63.04, 63.18, and 63.24 of the
       Rules, 47 C.F.R. S:S: 63.03, 63.04, 63.18, and 63.24.

   17. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Rules,
       within thirty (30) calendar days of the release date of this Notice of
       Apparent Liability for Forfeiture, StanaCard SHALL PAY the full amount
       of the proposed forfeitures or SHALL FILE a written statement seeking
       reduction or cancellation of the proposed forfeitures.

   18. Payment of the forfeiture must be made by check or similar instrument,
       wire transfer, or credit card, and must include the NAL/Account number
       and FRN referenced above. StanaCard shall also send electronic
       notification within forty-eight (48) hours of the date said payment is
       made to Terry.Cavanaugh@fcc.gov, Pamela.Kane@fcc.gov,
       William.Kehoe@fcc.gov, and Robert.Krinsky@fcc.gov. 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 regarding the form of payment:

     * 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.

   19. Any request for full payment under an installment plan should be sent
       to: Chief Financial Officer - Financial Operations, Federal
       Communications Commission, 445 12th Street, SW, Room 1-A625,
       Washington, DC 20554. Questions regarding payment procedures should be
       addressed to the Financial Operations Group Help Desk by phone,
       1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.

   20. The written statement seeking reduction or cancellation of the
       proposed forfeitures, if any, must include a detailed factual
       statement supported by appropriate documentation and affidavits
       pursuant to Sections 1.80(f)(3) and 1.16 of the Rules. The written
       statement must be mailed to Theresa Z. Cavanaugh, Chief,
       Investigations and Hearings Division, Enforcement Bureau, Federal
       Communications Commission, 445 12th Street, SW, Room 4-C330,
       Washington, DC 20554 and must include the NAL/Account number
       referenced above. The written statement shall also be e-mailed to
       Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov and to Robert B.
       Krinsky at Robert.Krinsky@fcc.gov.

   21. The Commission will not consider reducing or canceling a forfeiture in
       response to a claim of inability to pay unless the petitioner submits:
       (1) federal tax returns for the most recent three-year period; (2)
       financial statements prepared according to generally accepted
       accounting practices (GAAP); or (3) some other reliable and objective
       documentation that accurately reflects the petitioner's current
       financial status. Any claim of inability to pay must specifically
       identify the basis for the claim by reference to the financial
       documentation submitted.

   22. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability
       for Forfeiture shall be sent by first class mail and certified mail,
       return receipt requested, to: Manlio Carrelli, Chief Executive
       Officer, StanaCard, LLC, 424 West 33rd Street, Suite 410, New York, NY
       10001; Michael Choupak, StanaCard, LLC, 424 West 33rd Street, Suite
       410, New York, NY 10001; Anastasia Koroleva, StanaCard, LLC, 424 West
       33rd Street, Suite 410, New York, NY 10001; and David E. Bronston,
       Esq., Phillips Lytle LLP, 437 Madison Avenue, 34th Floor, New York, NY
       10022-7021.

   FEDERAL COMMUNICATIONS COMMISSION

   Theresa Z. Cavanaugh

   Chief, Investigations and Hearings Division

   Enforcement Bureau

   47 U.S.C. S: 214.

   47 C.F.R. S:S: 63.03, 63.04, 63.18, 63.24.

   See 47 U.S.C. S: 214(a). In 1999, the Commission granted all
   telecommunications carriers blanket authority under Section 214 to provide
   domestic interstate services and to construct or operate any domestic
   transmission line. Implementation of Section 402(b)(2)(A) of the Telecomm.
   Act of 1996, Report and Order in CC Docket No. 97-11, Second Memorandum
   Opinion and Order in AAD File No. 98-43, 14 FCC Rcd 11364, 11365-66, para.
   2 (1999) (Section 402 Implementation Order); 47 C.F.R. S: 63.01. This
   authority does not extend to the provision of international services. See
   Section 402 Implementation Order, 14 FCC Rcd at 11365-66, para. 2.

   47 C.F.R. S:S: 63.03; 63.24. A transfer of control of domestic lines or of
   a domestic Section 214 authority is considered "substantial" if it results
   in a change in ultimate ownership or control of those lines or that
   authority. See 47 C.F.R. S: 63.03(d). A transfer of control of
   international lines or of an international Section 214 authority is
   considered "substantial" if it results in a change in the actual
   controlling party of those lines or that authority. 47 C.F.R. S: 63.24(a).

   See 47 C.F.R. S:S: 63.04, 63.18.

   See 47 C.F.R. S:S: 63.03(d); 63.24(f).

   47 C.F.R. S: 63.24(f).

   47 C.F.R. S: 63.03(d)(1). Notification must be given of pro forma
   transfers of control of domestic Section 214 authority that are
   consummated as part of a bankruptcy proceeding. See 47 C.F.R. S:
   63.03(d)(2).

   See StanaCard, LLC, Joint International and Domestic Application for
   Consent to the Transfer of Control, Attach. I at 5, WC Docket No. 12-18,
   IBFS File No. ITC-T/C-20120116-00003 (filed Jan. 16, 2012) (Joint
   Domestic/International Sec. 214 Application); Domestic Section 214
   Application Filed for the Transfer of Control of StanaCard, LLC;
   Streamlined Pleading Cycle Established, WC Docket No. 12-18, Public
   Notice, 27 FCC Rcd 427 (Wireline Comp. Bur. 2012).

   International Authorizations Granted, Public Notice, 25 FCC Rcd 1860 (Int.
   Bur. 2010).

   47 C.F.R. S: 63.01; see also Section 402 Implementation Order, supra note
   3.

   Letter from Cheng-yi Liu, Law Offices of Thomas K. Crowe, P.C., Counsel to
   StanaCard, LLC, to Robert Krinsky, Attorney Advisor, Investigations and
   Hearings Div., FCC Enforcement Bureau (filed Jan. 27, 2012) (on file in
   EB-12-IH-0076).

   See Joint Domestic/International Sec. 214 Application at 3; StanaCard,
   LLC, Notification of the Pro Forma Transfer of Control of International
   Section 214 Authority, IBFS File No. ITC-T/C-20120215-00051 at 1, 3 (filed
   Feb. 15, 2012) (StanaCard Pro Forma Int'l Sec. 214 Application).

   See StanaCard Pro Forma Int'l Sec. 214 Application at Attach. 1 (Answer to
   Question 13).

   Joint Domestic/International Sec. 214 Application, Attach. 1 at 3 (stating
   that the October 23, 2010 transaction "effectively transferr[ed] control
   of the company to [Ms.] Koroleva").

   See Notification of Pro Forma Transfer of Control of International Section
   214 Authorization, IBFS File No.: ITC-T/C-20120215-00051 (filed Feb. 15,
   2012) (on file in EB-12-IH-0076) (notification of pro forma transfer of
   control of international Section 214 authority held by StanaCard) (Pro
   Forma Transfer of Control Notification).

   See International Authorizations Granted - Section 214 Applications (47
   C.F.R. 63.18); Section 310(b)(4) Requests, Public Notice, Report No.
   TEL-01546, 27 FCC Rcd 1998, 2001 (Int'l Bur. 2012) (notice of grant of
   IBFS File No. ITC-T/C-20120215-00051) (International Sec. 214 Pro Forma
   Transfer Grant Public Notice).

   See Joint Domestic/International Sec. 214 Application, Attach. at 2-3.

   Id. at 3.

   Joint Domestic/International Sec. 214 Application, supra note 9;
   Streamlined International Applications Accepted for Filing, Section 214
   Applications (47 C.F.R. S: 63.18), Public Notice, Report No. TEL-01545S,
   2012 WL 524111 ( rel. Feb. 17, 2012) (accepting for filing StanaCard's
   application for consent to transfer control of international Section 214
   authority from Mr. Choupak to Ms. Koroleva); IBFS File No.
   ITC-STA-20120116-00004 (filed Jan. 16, 2012) (Application for STA related
   to StanaCard's application for consent to transfer control of
   international Section 214 authority from Mr. Choupak to Ms. Koroleva) (on
   file in EB-12-IH-0076); Domestic Section 214 Application for the Transfer
   of Control of StanaCard, LLC, WC Docket No. 12-18 (filed Jan. 17, 2012) (
   StanaCard's application for consent to transfer control of domestic
   Section 214 authority from Mr. Choupak to Ms. Koroleva) (on file in
   EB-12-IH-0076).

   See International Authorizations Granted, Section 214 Applications (47
   C.F.R. S: 63.18), Public Notice, Report No. TEL-01548, 27 FCC Rcd 2351,
   2354 (Int'l Bur. 2012) (International Sec. 214 Grant PN) (notice of grant
   of IBFS File No. ITC-T/C-20120116-00003); Domestic Section 214 Application
   Filed for the Transfer of Control of StanaCard, LLC, Streamlined Pleading
   Cycle Established, WC Docket No. 12-18, Public Notice, 27 FCC Rcd 427 n.2
   (Wireline Comp. Bur. 2012).

   See Domestic Section 214 Granted, Domestic Sec. 214 Application Filed for
   the Transfer of Control of StanaCard, LLC, WC Docket No. 12-18, Public
   Notice, 27 FCC Rcd 2381  (Wireline Comp. Bur. 2012); International Sec.
   214 Grant PN, 27 FCC Rcd at 2354.

   See 47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(1).

   47 U.S.C. S: 312(f)(1).

   See H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).

   See, e.g., Southern California Broadcasting Co., Memorandum Opinion and
   Order, 6 FCC Rcd 4387, 4388, para. 5 (1991) (Southern California
   Broadcasting).

   See, e.g., Callais Cablevision, Inc.,  Notice of Apparent Liability for
   Monetary Forfeiture, 16 FCC Rcd 1359, 1362, para. 10 (2001) (Callais
   Cablevision) (issuing an NAL for, inter alia, a cable television
   operator's repeated violation of the cable signal leakage rules).

   Southern California Broadcasting,  6 FCC Rcd at 4388, para. 5; Callais
   Cablevision,  16 FCC Rcd at 1362, para. 9.

   47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).

   See, e.g., SBC Communications, Inc.,  Forfeiture Order, 17 FCC Rcd 7589,
   7591, para. 4 (2002).

   See 47 C.F.R. S: 63.24(f).

   See supra paragraph 6.

   See Pro Forma Transfer of Control Notification, supra note 16;
   International Sec. 214 Pro Forma Transfer Grant Public Notice, 27 FCC Rcd
   at 2001; see also 47 C.F.R. S: 63.24(d) (defining pro forma assignments
   and transfers of control as transactions that "do not result in a change
   in the actual controlling party. . . .").

   Id.

   47 U.S.C. S: 214; 47 C.F.R. S:S: 63.03, 63.04, 63.18, 63.24; see also
   supra paragraph 2.

   See supra paragraph 7.

   Id.

   47 U.S.C. S: 503(b)(1)(B).

   47 U.S.C. S: 503(b)(2)(B); see also 47 C.F.R. S: 1.80(b)(2). The
   Commission has amended Section 1.80(b)(2) of the Rules three times to
   increase the maximum forfeiture amounts, in accordance with the inflation
   adjustment requirements contained in the Federal Civil Penalties Inflation
   Adjustment Act of 1990, 28 U.S.C. S: 2461 note, as amended by the Debt
   Collection Improvement Act of 1996, 31 U.S.C. S: 3701 note. The most
   recent inflation adjustment took effect September 2, 2008 and applies to
   violations that occur after that date. See Amendment of Section 1.80(b) of
   the Commission's Rules, Adjustment of Forfeiture Maxima to Reflect
   Inflation, Order, 23 FCC Rcd 9845 (2008) (adjusting the maximum statutory
   amounts for common carriers from $130,000/$1,325,000 to
   $150,000/$1,500,000).

   See 47 U.S.C. S: 503(b)(2)(E); see also 47 C.F.R. S: 1.80(b)(6), Note to
   paragraph (b)(6): Guidelines for Assessing Forfeitures.

   See 47 C.F.R. S: 1.80(b)(6), Note to paragraph (b)(6).

   See id.

   See Kajeet Inc. and Kajeet/Airlink, LLC, Notice of Apparent Liability for
   Forfeiture and Order, 26 FCC Rcd 16684, 16697, para. 29 (2011) (Kajeet
   NAL).

   See supra paragraph 7.

   See 47 U.S.C. S: 503(b)(2)(E);  Kajeet NAL, 26 FCC Rcd at 16697, para. 29
   (upwardly adjusting the $8,000 base forfeiture to $16,000 in response to a
   two-year delay in seeking Commission approval of a substantial
   unauthorized assignment of international Section 214 authority).

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

   47 C.F.R. S: 1.80.

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

   See 47 C.F.R. S: 1.1914.

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

   Federal Communications Commission DA 13-14

                                       8

   Federal Communications Commission DA 13-14