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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554

   In the Matter of Daniel K. Roberts a/k/a "Monkey Man" a/k/a "Monkey" San
   Francisco, California ) ) ) ) ) ) ) File Number: EB-09-SF-0031 NAL/Acct.
   No.: 200932960004 FRN: 0019070572




                          Memorandum opinion and order

   Adopted: February 7, 2014 Released: February 7, 2014

   By the Chief, Enforcement Bureau:

   I. Introduction

    1. In this Memorandum Opinion and Order (MO&O), issued pursuant to
       Section 405 of the Communications Act of 1934, as amended (Act),^ we
       deny the petition for reconsideration (Petition)^ filed by Daniel K.
       Roberts a/k/a "Monkey Man" a/k/a "Monkey" (Mr. Roberts) of the
       Forfeiture Order issued by the Enforcement Bureau's Western Region
       (Region) on October 21, 2011.^ The Forfeiture Order imposed a monetary
       forfeiture in the amount of ten thousand dollars ($10,000) for
       willfully and repeatedly violating Section 301 of the Communications
       Act of 1934, as amended (Act)^ by engaging in unlicensed operation of
       a radio broadcast station.^

   II. Background

    2. This case concerns Mr. Roberts's operation of Pirate Cat Radio (PCR),
       which operated a radio broadcast station on frequency 87.9 MHz in San
       Francisco, California, without a license issued by the FCC. As
       detailed in the Forfeiture Order, Mr. Roberts was the executive of the
       Pirate Cat Cafe and Studio located at 2781 21^st Street, San
       Francisco, California. In 2008, Mr. Roberts began operating PCR from a
       radio studio located at the Pirate Cat Cafe and Studio. At the time
       the Notice of Apparent Liability for Forfeiture (NAL)  was issued in
       this proceeding, PCR's website prominently featured Mr. Roberts; in
       addition, PCR described itself as an "unlicensed low powered community
       radio" located at the same address as the Pirate Cat Cafe and Studio.^
       The Enforcement Bureau's San Francisco Office issued numerous warnings
       and Notices of Unlicensed Operation (NOUOs) to Mr. Roberts and PCR
       concerning unlicensed radio operations that detailed the potential
       penalties for operating an unlicensed radio station and for further
       violations of the Act and the Commission's rules (Rules).^

    3. On April 28, 2009, and April 29, 2009, agents from the San Francisco
       Office, using radio direction-finding methods, determined that the
       transmission source of a radio signal on frequency 87.9 MHz was an
       antenna on the roof of a residence at 841 Corbett Avenue, San
       Francisco, California. The agents took field strength measurements of
       the signals and determined that the signals being broadcast exceeded
       the limits for operation under Part 15 of the Rules^ and therefore
       required a license. A review of the Commission's records found no
       evidence of an FCC authorization for operation on frequency 87.9 MHz
       in San Francisco, California. Also on April 29, 2009, the agents
       observed Mr. Roberts operating and controlling the unlicensed radio
       station on frequency 87.9 MHz from the Pirate Cat Cafe and Studio. The
       agents subsequently monitored PCR and again determined that the
       transmission source of the unauthorized radio signal was 841 Corbett
       Avenue, San Francisco, California. The agents recognized and
       identified Mr. Roberts as the voice on the unlicensed transmissions
       carried on PCR.^

    4. On August 31, 2009, the Enforcement Bureau's San Francisco Office
       issued the NAL in the amount of $10,000 to Mr. Roberts, finding that
       Mr. Roberts apparently willfully and repeatedly violated Section 301
       of the Act by operating an unlicensed broadcast station.^ After the
       issuance of the NAL, PCR's broadcasts on frequency 87.9 MHz in San
       Francisco ceased.^ On October 23, 2009, after receiving an extension
       of time from the San Francisco Office, Mr. Roberts filed a response to
       the NAL (NAL Response).^ In the NAL Response, Mr. Roberts
       "acknowledge[d] his involvement in extra-legal broadcasting years
       ago," but denied that "transmissions ha[d] ever emanated from the
       location admittedly under his control, the Pirate Cat Radio cafe and
       studio at 2781 21^st Street in San Francisco."^ Mr. Roberts also
       denied "`operating' or `controlling' any `unlicensed radio station on
       87.9 MHz' or any transmission of energy on any frequency."^ By
       contrast, Mr. Roberts conceded that "on April 28 and 29, 2009, when
       agents observed [him] at the Pirate Cat Radio address, [he] was
       operating the board, mixers and espresso machine."^ Mr. Roberts
       alleged that PCR's internet-streamed program service is downloaded and
       broadcast by third parties, but acknowledged that PCR's website
       described his facility as an "unlicensed low powered community
       radio.'"^ However, Mr. Roberts stated that "[t]his statement does not
       currently appear on the website, and is inaccurate because Pirate Cat
       Radio, while certainly unlicensed, ha[d] never originated broadcast
       transmissions or extra legal transmission of any kind."^

    5. The Region determined that Mr. Roberts's arguments that Section 301
       requires that the violator actually operate a transmitter at the
       location of the studio were invalid, and stated that (for purposes of
       Section 301) "the word `operate' has been interpreted to mean `the
       general conduct or management of a station as a whole, as distinct
       from the specific technical work involved in the actual transmission
       of signals.'"^ The Region stated that, consistent with precedent, the
       use of the word "operate" in Section 301 of the Act captures not just
       the "`actual, mechanical manipulation of radio apparatus,' but also
       operation of a radio station generally."^ The Region further noted
       that the Commission can consider whether an individual exercises "any
       means of actual working control over the operation of the [station] in
       whatever manner exercised'" when determining whether such individual
       is involved in the general conduct or management of an unlicensed
       station.^

    6. The Region observed that while Mr. Roberts stated that he had no
       control over PCR's unlicensed transmissions, Mr. Roberts held himself
       out publicly as PCR's manager and described PCR as a broadcast
       station, not just a source of internet programming.^ The Region
       determined that Mr. Roberts solicited funds on the PCR website,
       stating that "[d]onations go towards monthly station cost of running
       the FM transmitter and help Pirate Cat Radio buy new radio station
       equipment."^ In addition, in August 2009, Mr. Roberts accepted a
       certificate from the San Francisco Board of Supervisors which
       recognized PCR for its "trailblazing efforts toward freeing the
       airwaves from corporate control, providing the community with training
       in radio broadcast skills, empowering voices ignored by traditional
       media outlets, and contributing to the advancement of the city's
       coffee culture."^ The Region also determined that Mr. Roberts admitted
       operation of PCR as an unlicensed radio broadcast station in response
       to the NAL on October 31, 2009, when he issued a press release stating
       that "Pirate Cat Radio . . . has ceased its terrestrial broadcast on
       87.9FM in response to the latest demands of the Federal Communications
       Commission."^ The Region found that "[c]oncurrent with the issuance of
       Roberts' press release, broadcasts of PCR on frequency 87.9 MHz in the
       San Francisco area did cease."^

    7. In his Petition, Mr. Roberts again argues that no facts connect him
       with the transmissions from the transmitter located at 841 Corbett
       Avenue; the "allegations" contained in the Forfeiture Order do not
       meet the requirements of Section 301 of the Act; precedent does not
       support the Region's violation determination; and the Forfeiture Order
       "constitutes an unlawful infringement on protected speech."^ We
       address these arguments below.

   III. Discussion

    8. Reconsideration is appropriate only where the petitioner either
       demonstrates a material error or omission in the underlying order or
       raises additional facts not known or not existing until after the
       petitioner's last opportunity to present such matters.^ A petition for
       reconsideration that reiterates arguments that were previously
       considered and rejected will be denied.^ As discussed below, we find
       that Mr. Roberts has not provided any basis to warrant reconsideration
       of the Forfeiture Order. We therefore affirm the Region's findings.^

    9. In his Petition, Mr. Roberts essentially repeats the arguments
       considered (and rejected) by the Region in the Forfeiture Order. Mr.
       Roberts primarily argues that the Region cannot support a Section 301
       violation finding against him because it cannot show that he
       physically operated a transmitter without a license.^  Specifically,
       Mr. Roberts disagrees with the Region's application of Campbell v.
       United States,^ which established that the term "operate" under
       Section 301 refers to "the general conduct or management of a station
       as a whole, as distinct from the specific technical work involved in
       the actual transmission of signals."^ Mr. Roberts maintains that this
       distinction depends upon whether a subject was operating a station
       without an operator's license as opposed to a station operation
       without a license, and argues that the Region incorrectly applied a
       vague "management" standard in support of its violation finding.^ We
       disagree. The Campbell court  determined that a Section 301 violation
       encompasses the broader "management" definition of "operate" when it
       refused to limit the term to cover only "the actual, mechanical
       manipulation of radio apparatus."^ Instead, the court found that the
       term "operate," as used in Section 301, encompasses "the general
       conduct or management of a station as a whole."^ The court concluded
       that Section 301's prohibition of unlicensed broadcast operations "is
       intended to cover generally both radio stations and radio operators."^
       As a result, the Region correctly concluded that Mr. Roberts's actions
       involved the general conduct or management of PCR as a whole,
       resulting in the operation of a radio broadcast station without an FCC
       license in violation of Section 301 of the Act.

   10. We find no merit to Mr. Roberts's argument that the Forfeiture Order
       was an unlawful infringement on protected speech.^ As noted in his
       Petition, Mr. Roberts concedes that "Congress acted within its powers
       in creating a regime of licensing for broadcast . . . providing that
       unlicensed transmissions must be banned from the airwaves."^ Mr.
       Roberts's suggestion that the enforcement action taken against him
       results from the content of the unlicensed broadcasts and his
       promotional activity in support of PCR's operations is unfounded.^
       Rather, it is Mr. Roberts's operation of an unlicensed broadcast radio
       station that formed the basis of the Section 301 violation.

   11. Based on the overall record in this case, we find that the Region
       correctly determined that Mr. Roberts was engaged in the management
       and operation of PCR in violation of Section 301 of the Act and that
       such operation was supported by a preponderance of the evidence.^ This
       included Mr. Roberts's fundraising for the PCR FM transmitter, his
       long history of promoting PCR and himself, and the physical control of
       the PCR broadcast transmission on frequency 87.9 MHz, which he
       announced he was stopping after the issuance of the NAL.^  Therefore,
       we find that the Petition fails to demonstrate a material error or
       omission in the underlying Forfeiture Order or raise additional facts
       not known or not existing until after Mr. Roberts's last opportunity
       to present such matters. Accordingly, we affirm the Forfeiture Order
       and find Mr. Roberts liable for a monetary forfeiture in the amount of
       ten thousand dollars ($10,000) for willfully and repeatedly violating
       Section 301 of the Act.

   IV. ordering clauses

   12. Accordingly, IT IS ORDERED that, pursuant to Section 405 of the
       Communications Act of 1934, as amended,^ and Section 1.106 of the
       Rules,^ the Petition for Reconsideration filed by Daniel K. Roberts
       a/k/a "Monkey Man" a/k/a "Monkey" IS DENIED and the Forfeiture Order
       IS AFFIRMED.

   13. IT IS ALSO ORDERED that, pursuant to Section 503(b) of the Act, and
       Sections 0.111, 0.311 and 1.80(f)(4) of the Rules, Daniel K. Roberts
       a/k/a "Monkey Man" a/k/a "Monkey" IS LIABLE FOR A MONETARY FORFEITURE
       in the amount of ten thousand dollars ($10,000) for willfully and
       repeatedly violating Section 301 of the Act.^

   14. Payment of the forfeiture shall be made in the manner provided for in
       Section 1.80 of the Rules immediately and no later than thirty (30)
       calendar days after the release date of this Memorandum Opinion and
       Order.^  If the forfeiture is not paid within the period specified,
       the case may be referred to the U.S. Department of Justice for
       enforcement of the forfeiture pursuant to Section 504(a) of the Act.^
       Daniel K. Roberts a/k/a "Monkey Man" a/k/a "Monkey" shall send
       electronic notification of payment to WR-Response@fcc.gov on the date
       said payment is made.

   15. The payment must be made by check or similar instrument, wire
       transfer, or credit card, and must include the NAL/Account number and
       FRN referenced above. Regardless of the form of payment, a completed
       FCC Form 159 (Remittance Advice) must be submitted.^ When completing
       the FCC Form 159, enter the Account Number in block number 23A (call
       sign/other ID) and enter the letters "FORF" in block number 24A
       (payment type code).   Below are additional instructions you should
       follow based on the form of payment you select:

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

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

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

   16. Any request for making full payment over time under an installment
       plan should be sent to:  Chief Financial Officer--Financial
       Operations, Federal Communications Commission, 445 12th Street, S.W.,
       Room 1-A625, Washington, D.C.  20554.^  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.

   17. IT IS FURTHER ORDERED that this Memorandum Opinion and Order shall be
       sent by both regular mail and by certified mail, return receipt
       requested, to Daniel K. Roberts a/k/a "Monkey Man" a/k/a "Monkey" at
       his address of record, and to his counsel, Michael Couzens, Esquire,
       Michael Couzens Law Office, 6536 Telegraph Ave., Suite B201, Oakland,
       CA 94609.

   FEDERAL COMMUNICATIONS COMMISSION

   P. Michele Ellison

   Chief, Enforcement Bureau

   ^ See 47 U.S.C. S 405.

   ^ See Daniel K. Roberts, Petition for Reconsideration (filed Nov. 21,
   2011) (on file in EB-09-SF-0031) (Petition).

   ^ Daniel K. Roberts,  Forfeiture Order, 26 FCC Rcd 14484 (Enf. Bur. 2011)
   (Forfeiture Order), aff'g Notice of Apparent Liability for Forfeiture,
   NAL/Acct. No. 200932960004 (Enf. Bur. Aug. 31, 2009) (NAL).

   ^ 47 U.S.C. S 301.

   ^ Forfeiture Order, 26 FCC Rcd  at 14488, para. 13.

   ^ Subsequent to the issuance of the NAL, the PCR website underwent various
   changes that eliminated much of the language that evidenced PCR and Mr.
   Roberts's control of the PCR broadcasts on frequency 87.9 MHz.

   ^ See, e.g., Notice of Unlicensed Operation to Daniel K. Roberts (Mar. 7,
   2006) (on file in EB-05-SF-0139); Notice of Unlicensed Operation to Jason
   Seifert (Apr. 20, 2006) (on file in EB-06-SF-0031); Notice of Unlicensed
   Operation to Josh Goodwin (June 27, 2006) (on file in EB-06-SF-0026);
   Notice of Unlicensed Operation to Alexander Ness (Mar. 29, 2007) (on file
   in EB-07-SF-0037); On-Scene Notice of Unlicensed Operation (Aug. 18, 2008)
   (on file in EB-08-SF-0269).

   ^ Section 15.239 of the Rules provides that non-licensed broadcasting in
   the 88-108 MHz frequency band is permitted only if the field strength of
   the transmission does not exceed 250 mV/m at three meters. See 47 C.F.R. S
   15.239. Fundamental emissions from intentional radiators are not permitted
   in the 76-88 MHz frequency band. See 47 C.F.R. S 15.209(a). On April 28,
   2009, the measurements indicated that the signal was more than 4,000 times
   greater than the maximum permissible level for a non-licensed Part 15
   transmitter in the 88-108 MHz frequency band and more than 10,000 times
   greater than the maximum permissible level in the 76-88 MHz band. On April
   29, 2009, the measurements indicated that the signal was more than 3,000
   times greater than the maximum permissible level for a non-licensed Part
   15 transmitter in the 88-108 MHz frequency band and more than 8,000 times
   greater than the maximum permissible level in the 76-88 MHz frequency
   band.

   ^ Forfeiture Order, 26 FCC Rcd at 14485, para. 3.

   ^ See NAL, supra note 3.

   ^ Forfeiture Order, 26 FCC Rcd at 14485, para. 4.

   ^ See Response of Daniel K. Roberts (filed Oct. 23, 2009) (on file in
   EB-09-SF-0031) (NAL Response).

   ^ Id. at 1.

   ^ Forfeiture Order,  26 FCC Rcd at 14486, para. 7.

   ^ Id.

   ^ Id.

   ^ Id. Mr. Roberts also argued that he was unable to pay the proposed
   forfeiture amount. However, Mr. Roberts failed to produce any financial
   information or documentation, and the Region consequently denied his
   request to reduce the proposed forfeiture. See id. at 14488, para. 11.

   ^ Id. at 14486, para. 8 (quoting Campbell v. United States, 167 F.2d 451,
   453 (5th Cir. 1948) (comparing the use of the words "operate" and
   "operation" in Sections 301, 307 and 318 of the Act, and concluding that
   the word "operate," as used in Section 301 of the Act, means both the
   technical operation as well as the general conduct or management of a
   broadcast radio station)).

   ^ See id.; 47 U.S.C.  S 307(c)(1).

   ^ Forfeiture Order,  26 FCC Rcd at 14486, para. 8 (quoting Revision of
   Rules and Policies for the Direct Broadcast Satellite Service, Report and
   Order, 11 FCC Rcd 9712, 9747, para. 91 (1995), aff'd sub nom. DIRECTV,
   Inc. v FCC, 110 F.3d 816 (D.C. Cir 1997). See, e.g., Vicot Chery, Notice
   of Apparent Liability for Forfeiture, 25 FCC Rcd 14596 (Enf. Bur. 2010).

   ^ See Forfeiture Order, 26 FCC Rcd at 14487, para. 9. See also Joel
   Selvin, Pirates Ride the Airwaves from Mission Redoubt, S.F. Gate, Jan. 5,
   2009, available at http://articles.sfgate.com/2009-01-05/entertainment/
   17197051_1_pirate-radio-monkey-radio-station (last visited Nov. 8, 2010)
   ("Monkey has operated Pirate Cat Radio in various locations for 12 years
   and opened the cafe in March with a novel business plan. He oversees a
   staff of 52 disc jockeys who pay a $30 monthly fee to do their air shifts
   . . . ."); Ashley Harrell, The Radio Pirate Goes Legit, S.F. Weekly, May
   26, 2010, available at
   http://www.sfweekly.com/2010-05-26/news/the-radio-pirate-goes-legit/ (last
   visited Nov. 8, 2010) (discussing Mr. Roberts's history as a pirate radio
   broadcaster) (Harrell Article); http://www.piratecatradio. com/about/php
   (last visited July 28, 2008) ("Pirate Cat is an unlicensed low powered
   community radio station, broadcasting on 87.9 megahertz.").

   ^ Forfeiture Order,  26 FCC Rcd at 14487, para. 9. Mr. Roberts also stated
   on the PCR website "that Title 47 Section 73.3542 of the U.S. Code of
   federal regulations currently allows Pirate Cat Radio 87.9fm to legally
   broadcast with out [sic] a formal licence [sic] from the FCC." Id. We note
   that the authority to operate pursuant to Section 73.3542 of the Rules
   must be granted by the Commission and the applicant bears the burden of
   showing the required "extraordinary circumstances" to support such a
   grant. See  A-O Broad. Corp., Memorandum Opinion and Order, 23 FCC Rcd
   603, 614, para. 20 (2008). No evidence exists showing that Mr. Roberts or
   PCR has ever received such a grant of authority from the Commission.
   Additionally, the frequency used by Mr. Roberts and PCR at 87.9 MHz is not
   allocated to the FM broadcast band. See 47 C.F.R. S 73.201.

   ^ Forfeiture Order,  26 FCC Rcd at 14487, para. 9 (quoting Harrell
   Article). We note that the Commission created the low power FM (LPFM)
   broadcast service to encourage nonprofit educational groups to actively
   participate in local broadcasting and to foster a diverse range of
   community voices. See 47 C.F.R. S 73.801 et seq. See also
   http://www.fcc.gov/encyclopedia/low-power-fm-broadcast-radio-stations-lpfm
   (last visited Feb. 3, 2014).

   ^ Id. at 14487-88, para. 10. See Kevin Montgomery, Pirate Cat Radio Fined
   $10k and Ceases FM Broadcast, Mission Mission, Nov. 2, 2009, available at
   http://www.missionmission.org/2009/11/02/
   pirate-cat-radio-fined-10k-and-ceases-fm-broadcast/ (last visited Aug. 16,
   2010). The press release also stated that "PCR can continue as an internet
   only station and the cafe/studio on 21^stst [sic] will continue to
   operate, . . . but it cannot safely broadcast over the terrestrial FM band
   without possibly jeopardizing its volunteers and supporters." Id. The
   press release concluded by stating that Mr. Roberts and others working at
   the station "made a collective decision that Pirate Cat Radio must come
   off the public airwaves, until some method is found to change the law or
   get it authorized under existing law." Id.

   ^ Forfeiture Order,  26 FCC Rcd at 14488, para. 10. This fact undercuts
   Mr. Roberts's earlier assertion that the transmissions detected by the San
   Francisco Office agents were caused by third parties outside his control
   involved in airing internet-streamed program service from PCR. See id. at
   14486, para. 7.

   ^ Petition at 2-12. Mr. Roberts contends that the NAL did not comply with
   the Commission's rules because it did not give him "an opportunity within
   30 days to address the charges in a personal interview at the field office
   as required by Section 1.80(d) of the Rules, 47 C.F.R. S 1.80(d)." Id. at
   1 n.1. Mr. Roberts misunderstands the application of the interview
   provisions of Section 1.80(d). An opportunity for an interview is not
   required when the individual "is engaged in (and the violation relates to)
   activities for which a license, permit, certificate, or other
   authorization is required . . . ." 47 C.F.R. S 1.80(d)(3). As described
   above, Mr. Roberts was required to have an authorization for his PCR
   broadcast on frequency 87.9 MHz and therefore was not entitled to a
   personal interview at the field office before the imposition of a
   forfeiture.

   ^ See 47 C.F.R. S 1.106(c); EZ Sacramento, Inc., Memorandum Opinion and
   Order, 15 FCC Rcd 18257 (Enf. Bur. 2000) (citing WWIZ, Inc.,  37 FCC 685,
   686 (1964), aff'd sub. nom. Lorain Journal Co. v. FCC,  351 F.2d 824 (D.C.
   Cir. 1965), cert. denied,  383 U.S. 967 (1966)).

   ^ EZ Sacramento, Inc.,  15 FCC Rcd at 18257, para. 2.

   ^ Mr. Roberts argues that certain sworn statements made in his NAL
   Response must be accepted as true, including his statements that he had no
   ownership, access, and control over any facility at 841 Corbett Avenue,
   that he did not install or operate a transmitter at 841 Corbett Avenue,
   that he did not create a studio-transmitter link from the Pirate Cat Cafe
   and Studio to another location, and that "no extra-legal transmitter had
   ever been energized at the location of Pirate Cat Radio" because the
   Region failed to rebut them.  Petition at 1-2.  We disagree. The Region
   took into account these statements when it specifically determined that
   Mr. Roberts "mistakenly argues that a violation of section 301 of the Act
   requires that the violator be actually operating a transmitter at the
   location of the studio and nothing less."  Forfeiture Order, 26 FCC Rcd at
   14486, para. 8.

   ^ Petition at 3-6.

   ^ 167 F.2d 451 (5th Cir. 1948).

   ^ Petition at 6; Forfeiture Order, 26 FCC Rcd at 14486, para. 8 (quoting
   Campbell, 167 F.2d at 453). Mr. Roberts objects to the Region's assertion
   that, in order to determine whether an individual is involved in the
   general conduct or management of the station, the Commission can consider
   whether such individual exercises "any means of actual working control
   over the operation of the [station] in whatever manner exercised." See
   Petition at 8-9. While Mr. Roberts may disagree with this longstanding
   Commission precedent, he provides no evidence that he did not exercise
   working control over the operation of PCR without a license.

   ^ Petition at 6-7. Mr. Roberts also cites to United States v. Molyneaux,
   55 F.2d 912 (2d Cir 1932), a case decided under the Federal Radio Act,
   which predates the existence of the Federal Communications Commission.
   That case is inapposite to the instant case because Molyneaux concerned an
   individual handling and manipulating radio apparatus, not an individual
   promoting a radio station and controlling its management and operation.
   Although mechanical manipulation of radio apparatus is not required under
   the standard established in Campbell, we note that the record in this
   proceeding demonstrates (and Mr. Roberts did not dispute) that Mr. Roberts
   was observed operating the board, mixers, and other equipment at the
   Pirate Cat Cafe and Studio and that agents from the San Francisco Office
   recognized and identified Mr. Roberts as the voice on the unlicensed
   transmissions. See supra paras. 3-4.

   ^ Campbell, 167 F.2d at 453.

   ^ Id.

   ^ Id. Mr. Roberts argues that previous enforcement actions against
   unlicensed operators involved individuals with access to the coaxial cable
   linking the operator's residence to the transmitter or the actual room
   containing the transmitter. See Petition at 7 n. 5 (citing Durrant Clark,
   Notice of Apparent Liability for Forfeiture, 26 FCC Rcd 6982 (Enf. Bur.
   2011); Christopher M. Myers, Memorandum Opinion and Order 26 FCC Rcd 10302
   (Enf. Bur. 2011); Nounoune Lubin, Forfeiture Order, 26 FCC Rcd 7758 (Enf.
   Bur. 2011); Audre Alleyne and Jessie White, Forfeiture Order, 26 FCC Rcd
   10372 (Enf. Bur. 2011) (Alleyne and White)). As indicated above, it is Mr.
   Roberts's management of PCR, not access to PCR's radio equipment, which
   violated Section 301. However, we note that in certain enforcement actions
   cited to by Mr. Roberts the evidence supporting a finding of unlicensed
   operation included unsworn statements by individuals acknowledging that
   they owned and operated the station as well as the ability of the
   individuals to turn off the unlicensed station. See Alleyne and White, 26
   FCC Rcd at 10376, para. 9; Eleuterio Lebron, Notice of Apparent Liability
   for Forfeiture, 26 FCC Rcd 13070, 13070, para. 2 (Enf. Bur. 2011). Mr.
   Roberts demonstrated similar control over PCR when he announced and
   effected the cessation of PCR's transmissions following issuance of the
   NAL.

   ^ Petition at 9-11.

   ^ Id. at 9.

   ^ Indeed, Mr. Roberts previously stated publicly his belief that the
   enforcement action taken against him was not based on the content of PCR's
   broadcasts. See Titania Kumeh, Music Monday: Pirate Cat Radio vs. the FCC,
   Mother Jones Magazine, Jan. 18, 2010, available at
   www.motherjones.com-riff-2009-12-fight-radio-right (last visited April 16,
   2013) (reporting that Mr. Roberts stated that "the reason the FCC is
   possibly giving us a fine and telling us to get off the air, I think, is
   not because of content or because of interfering with other stations. The
   FCC just licensed outside of the filing period for TV channel 6 in
   Fremont, which utilizes 87.9 FM for its audio carrier, so I wouldn't be
   surprised if somebody with a big pocketbook said, `Hey! We want this
   license and we're going to pay you money to give us a license outside of
   your filing period.'") (Kumeh Article).

   ^ See AT&T, Inc., Forfeiture Order, 27 FCC Rcd 10803 (Enf. Bur. 2012)
   (finding the preponderance of the evidence, including the cessation of
   interference when subject exercised control of device by turning it off,
   supports finding a Section 301 violation, even when the subject denies
   that it was the source of the interference).

   ^ Despite Mr. Roberts's carefully parsed arguments about the definition of
   "operate" under Section 301, we note that he continued to publicize his
   operation of PCR for months after the issuance of the NAL. See, e.g.,
   Kumeh Article. In that article, Mr. Roberts was asked, "Why fight for the
   right to be on the radio when it's practically obsolete?" Mr. Roberts
   responded, "[a] lot of people don't have the money to spend to be a part
   of the digital world. They don't own a computer. They don't have an
   Internet connection; if they do have an Internet connection and computer,
   they can listen to Pirate Cat Radio online, but they still have to deal
   with buffering and not having the right software to listen to the stream.
   Whereas when a radio station broadcasts through analog air, you can go and
   pick up a radio at Radio Shack literally for $5 and turn it on, tune to
   87.9 FM, and you'll get Pirate Cat Radio." Kumeh Article.

   ^ 47 U.S.C. S 405.

   ^ 47 C.F.R. S 1.106.

   ^ 47 U.S.C. SS 301, 503(b); 47 C.F.R. SS 0.111, 0.311, 1.80(f)(4).

   ^ 47 C.F.R. S 1.80.

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

   ^ 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.

   (Continued from previous page)

   (continued....)

   Federal Communications Commission DA 14-167

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   Federal Communications Commission DA 14-167