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Federal Communications Commission DA 16-1032
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
AT&T Inc., Parent Company of New Cingular 
Wireless PCS, LLC and AT&T Mobility Puerto 
Rico, Inc.
)
)
)
)
)
)
File No.:  EB-SED-13-00008891
Acct. No.: 201532100002
FRN:  0005193701
ORDER
Adopted: September 22, 2016 Released:  September 23, 2016
By the Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission 
(Commission) has entered into a Consent Decree to resolve its investigation into whether AT&T
1
operated numerous common carrier fixed point-to-point microwave stations for several years at variance 
from the stations’ Commission authorizations.  The regulations involved ensure that consumers can use 
their wireless devices without interference from unauthorized radio operations. To settle this matter, 
AT&T admits that it operated numerous fixed microwave stations at variance from their authorizations 
for periods ranging from approximately three and a half years to over four years.  AT&T agrees that it
will implement a robust compliance plan to ensure there is no reoccurrence of these violations for future 
acquired microwave licenses and will pay a $450,000 civil penalty.  
2. As part of the compliance plan, AT&T will conduct timely reviews of fixed microwave 
stations acquired in future transactions to ensure that the stations are operating in accordance with their 
licensed parameters, file periodic progress reports on its compliance efforts, and correct any 
noncompliance discovered during the review process within 60 days of its discovery.  
3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the
referenced investigation resolving the Notice of Apparent Liability for Forfeiture (NAL) regarding 
AT&T’s operation of numerous wireless stations without authorization and failure to provide required 
license modification notices to the Commission, in violation of Section 301 of the Communications Act, 
as amended (Act),
2
and Sections 1.903(a), 1.947(a) and 1.947(b) of the Commission’s rules.
3
  
4. In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of AT&T’s basic qualifications to hold or obtain any Commission license or authorization.
4
                                                     
1
For purposes of this Order, we use the term “AT&T” as that term is defined in the Consent Decree.  Consent 
Decree at para. 2(c) (“‘AT&T’ means, for purposes of settlement only, AT&T Inc., AT&T Mobility LLC, and the
subsidiaries, predecessors-in-interest, and successors-in-interest of AT&T Mobility LLC.  AT&T Mobility LLC is a 
100 percent-owned, indirect subsidiary of AT&T Inc., as are AT&T Mobility of Puerto Rico LLC and New Cingular 
Wireless PCS LLC.”).
2
47 U.S.C. § 301.
3
47 C.F.R. §§ 1.903(a), 1.947(a)-(b). 
4
See 47 C.F.R. § 1.93(b).
Federal Communications Commission DA 16-1032
2
5. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) and 503(b) of the Act,
5
and
the authority delegated by Sections 0.111 and 0.311 of the Commission’s rules,
6
the attached Consent 
Decree IS ADOPTED and its terms incorporated by reference.
6. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED and 
the NAL IS RESOLVED in accordance with the terms of the attached Consent Decree.
7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Michael P. Goggin, General 
Attorney, and Jeanine A. Poltronieri, Assistant Vice President – Federal Regulatory, AT&T Services, 
Inc., 1120 20
th
Street, N.W., Suite 1000, Washington, D.C. 20036.  
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief
Enforcement Bureau
                                                     
5
47 U.S.C. §§ 154(i) 503(b).
6
47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 16-1032
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
AT&T Inc., Parent Company of 
New Cingular Wireless PCS, LLC and
AT&T Mobility Puerto Rico, Inc.
)
)
)
)
)
File No.:  EB-SED-13-00008891
Acct. No.:  201532100002
FRN:  0005193701
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and AT&T Inc. 
(AT&T), by their authorized representatives, hereby enter into this Consent Decree for the purpose of
terminating the Enforcement Bureau's investigation into whether AT&T violated Section 301 of the
Communications Act of 1934, as amended,
1
and Sections 1.903(a), 1.947(a), and 1.947(b) of the 
Commission's rules
2
in connection with its operation of certain microwave stations it acquired through 
asset purchase transactions. 
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.
3
(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) "AT&T" means, for purposes of settlement only, AT&T Inc., AT&T Mobility LLC, 
and the subsidiaries, predecessors-in-interest, and successors-in-interest of AT&T 
Mobility LLC.  AT&T Mobility LLC is a 100 percent-owned, indirect subsidiary of 
AT&T Inc., as are AT&T Mobility of Puerto Rico LLC and New Cingular Wireless 
PCS LLC. 
(d) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(e) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.
(f) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which AT&T is subject 
by virtue of its business activities, including but not limited to the Licensing Rules.
(g) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 11.
(h) “Covered Employees” means all employees and agents of AT&T and its affiliates 
who perform, supervise, oversee, or manage the operation, integration and/or 
discontinuance of acquired microwave authorizations, including with respect to 
                                                     
1
47 U.S.C. § 301.
2
47 CFR §§ 1.903(a),1.947(a)-(b).
3
47 U.S.C. § 151 et seq.
Federal Communications Commission DA 16-1032
2
AT&T’s responsibilities under the Communications Laws, and in particular, the 
Licensing Rules.
(i) “Covered Transactions” means any asset purchase transaction entered into after the 
Effective Date whereby AT&T or an AT&T affiliate acquires one or more Part 101 
microwave station authorizations.  A Covered Transaction shall be considered 
completed as of the closing date indicated by the parties in the FCC Form 603 
Notice of Consummation filed with the FCC after the transaction has closed.
(j) “Effective Date” means the date by which both the Bureau and AT&T have signed 
the Consent Decree.
(k) "Investigation" means the investigation commenced by the Bureau in File No. 
EB-11-SE-107 and later transitioned to File No. EB-SED-13-00008891 regarding 
whether AT&T violated the Licensing Rules, which culminated in the issuance of 
the NAL.
(l) "Licensing Rules" means Section 301 of the Communications Act of 1934, as
amended, and Sections 1.903(a), l.947(a), and 1.947(b) of the Commission's rules 
and other provisions of the Act, the Rules, and Commission orders that prohibit the 
use or operation of a wireless radio station in a manner inconsistent with its licensed
parameters.
(m) “NAL” means the Notice of Apparent Liability for Forfeiture issued to AT&T on 
January 29, 2015, proposing a six hundred forty thousand dollar ($640,000) 
forfeiture for apparent violations of the Licensing Rules.
(n) “Operating Procedures” means the standard internal operating procedures and 
compliance policies established by AT&T or its parent company to implement the 
Compliance Plan.
(o) “Parties” means AT&T and the Bureau, each of which is a “Party.”
(p) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
II. BACKGROUND
3. Section 301 of the Act and Section 1.903(a) of the Commission's rules prohibit the use or 
operation of any apparatus for the transmission of energy or communications or signals by radio except
under, and in accordance with, a Commission-granted authorization.
4
Section 1.947(a) of the
Commission's rules states that all “major modifications” to wireless radio service stations require prior
Commission approval.
5  Section 1.929(d) of the Commission's rules sets forth the types of modifications
that are considered major, such as any substantial change in ownership or control, changes that require 
frequency coordination, and the addition of a frequency for which a licensee is not currently authorized.
6
Failure to receive prior Commission approval for major modifications to station operations constitutes
unauthorized operations under the Act and the Commission's rules.
7
  For all other modifications, known 
as “minor modifications,” Section 1.947(b) of the Commission’s rules requires licensees to notify the 
Commission by filing corrective information within thirty days of implementing such modifications.
8
  
While licensees may make minor modifications to their wireless operations without prior approval, 
                                                     
4
47 U.S.C. § 301; 47 CFR § 1.903(a).
5
47 CFR § 1.947(a).   
6
47 CFR § 1.929(d).
7
47 U.S.C. § 301; 47 CFR § l .903(a).
8
47 CFR § 1.947(b).
Federal Communications Commission DA 16-1032
3
Commission notification ensures the accuracy of the Commission’s Universal Licensing System and 
supports the efficient administration of the radio spectrum.
9
4. On January 29, 2015, the Commission issued the NAL against AT&T for violating 
Section 301 of the Act,
10
and Sections 1.903(a), 1.947(a), and 1.947(b) of the Commission’s rules
11
for 
unauthorized operation of 26 microwave stations and for failing to provide required license modification 
notices to the Commission for eight additional microwave stations.
12
  That decision capped nearly three 
years of investigation and disclosures from AT&T that ultimately revealed the violations at issue here.  
As of the release date of the NAL, AT&T had yet to file seven modification applications that were 
reportedly needed to bring the respective stations into compliance.
13
  Since the release of the NAL, AT&T 
has filed all the necessary modification applications and received approvals. AT&T filed its response to 
the NAL on March 2, 2015.  Subsequently, AT&T and the Bureau engaged in settlement negotiations.  
The Bureau and AT&T agree to the following terms and conditions of settlement and hereby enter into 
this Consent Decree as provided herein.
III. TERMS OF AGREEMENT
5. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.
6. Jurisdiction.  AT&T agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
7. 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 Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.
8. 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, AT&T agrees to the 
terms, conditions, and procedures contained herein.  The Bureau further 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 new proceeding, formal or 
informal, or take any action on its own motion against AT&T 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 to set for hearing the 
question of AT&T’s basic qualifications to be a Commission licensee or hold Commission licenses or 
authorizations.
14
                                                     
9
Id.  See Biennial Regulatory Review – Amendment of Parts 0, 1, 13, 22, 24, 26, 27, 80, 87, 90, 95, 97, and 101 of 
the Commission’s Rules to Facilitate the Development and Use of the Universal Licensing System in the Wireless 
Telecommunications Services, Report and Order, 13 FCC Rcd 21027, 21060–61, paras. 72–73 (1998).
10
47 U.S.C. § 301.
11
47 CFR §§ 1.903(a), 1.947(a), 1.947(b).
12
AT&T Inc., Parent Company of New Cingular Wireless PCS, LLC and AT&T Mobility Puerto Rico, Inc., Notice 
of Apparent Liability for Forfeiture, 30 FCC Rcd 856, 863, para. 16 (2015) (NAL).  The NAL includes a more 
complete discussion of the facts and history of this case and the NAL, as well as AT&T’s response, is incorporated 
herein by reference.
13
Modifications were needed for stations WMN554, WPNL652, WPOP550, WPOS887, WQLR316, WPUS598, 
and WQJM490.  See Letter from Jacquelyne Flemming, Assistant Vice President – External Affairs/Regulatory, 
AT&T Services, Inc., to John Poutasse, Division Chief, Spectrum Enforcement Division, FCC Enforcement Bureau 
(Aug. 5, 2014) (on file in EB-SED-13-00008891) at Attachment 1.
14
See 47 CFR § 1.93(b).
Federal Communications Commission DA 16-1032
4
9. Admission of Liability.  AT&T admits, for the purpose of this Consent Decree and 
for Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 8
h erein, that its actions that were the subject of the NAL violated the Licensing Rules.
10. Compliance Officer.  Within thirty (30) calendar days after the Effective Date,
AT&T shall designate a senior corporate manager with the requisite corporate and organizational 
authority to serve as a 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 AT&T 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 or her duties under this Consent Decree, the 
Compliance Officer shall have specific knowledge of the Licensing Rules prior to assuming his/her duties.
The Compliance Officer may use the resources of legal counsel, consultants and/or other AT&T 
managers to aid the Compliance Officer in the discharge of his/her duties under this Consent
Decree.
11. Compliance Plan.  For purposes of settling the matters set forth herein, AT&T agrees
to the following steps to ensure compliance with the Licensing Rules for microwave stations acquired 
in Covered Transactions.  AT&T shall, within sixty (60) calendar days after the Effective Date, 
develop and implement a Compliance Plan designed to ensure future compliance with the 
Communications Laws and with the terms and conditions of this Consent Decree with respect to 
Covered Transactions.
15
  Specifically, within sixty (60) calendar days after the Effective Date,
AT&T shall establish Operating Procedures that all Covered Employees must follow to ensure 
AT&T's compliance with the Licensing Rules with respect to microwave stations acquired in 
Covered Transactions.  AT&T’s Operating Procedures shall include internal procedures and policies
specifically designed to ensure that it operates microwave stations acquired in Covered Transactions 
in accordance with their authorizations.  The Operating Procedures shall require, at a minimum, that:
(a) Analysis and Corrective Filings.  AT&T will analyze all microwave stations 
acquired in a Covered Transaction to determine whether the station is being 
operated consistently with its authorization.  Within 90 days of completing a 
Covered Transaction, AT&T shall review all compliance documentation 
obtained from the seller with respect to each acquired microwave authorization 
to determine whether any information (such as an as-built survey) is needed to 
complete this analysis (the Gap Analysis).  Subsequent to the Gap Analysis, 
AT&T shall acquire any necessary surveys or other documentation necessary to 
determine, with respect to each acquired microwave station, whether it is 
operating in accordance with its authorization.  In the event that it determines 
that a station is not operating in accordance with its authorization, AT&T shall 
submit a corrective filing to the Commission to amend the authorization as 
needed.  Absent circumstances beyond AT&T’s control, such as the need for 
cooperation from an uncooperative tower owner, any corrective filing shall be 
made within 60 days of the time the need for such a filing is determined as a 
result of AT&T’s analysis, except that if AT&T determines, during the 60 day 
period, an additional basis for a corrective filing, the corrective filing for the 
license shall be made within 60 days of such subsequent determination.
(b) 180-Day Compliance Report.  Within 180 days of completing a Covered 
Transaction, AT&T shall submit a Compliance Report to the Bureau in which, 
for each acquired microwave station, it indicates: (i) whether it has completed 
                                                     
15
AT&T represents that it has comprehensive organizational structures, plans, and procedures in place that are
intended to ensure compliance with the Communications Laws. This Consent Decree does not require new
organizational structures, plans, or procedures except as necessary to implement paragraphs 10-12 of this
Consent Decree, nor does it require application of the Compliance Plan to Covered Employees with no 
responsibilities for compliance with the Licensing Rules.
Federal Communications Commission DA 16-1032
5
its analysis of the station to determine if it is operating in accordance with its 
authorization; (ii) if so, whether the station requires a corrective filing and the 
date this was determined; (iii) for each such station, the nature of the corrective 
filing required (such as a major or minor modification or a cancellation notice), 
as well as the reason for the corrective filing (such as that a new survey 
indicates that the elevation differs from the elevation indicated in the 
Commission’s records, or that the station is no longer in use); (iv) the total 
number of such authorizations identified as of the date of the report that require 
a corrective filing; and (v) the number of authorizations for which corrective 
filings have been submitted as of the date of the report.  
(c) 1-year Compliance Report.  Within one year of completing a Covered 
Transaction, AT&T shall submit a Compliance Report to the Bureau in which 
for each acquired microwave station, it indicates: (i) whether it has completed 
its analysis of the station to determine if it is operating in accordance with its 
authorization; (ii) if so, whether the station requires a corrective filing and the 
date this was determined; (iii) for each such station, the nature of the corrective 
filing required (such as a major or minor modification or a cancellation notice), 
as well as the reason for the corrective filing (such as that a new survey 
indicates that the elevation differs from the elevation indicated in the 
Commission’s records, or that the station is no longer in use); (iv) the total 
number of such authorizations identified as of the date of the report that require 
a corrective filing; and (v) the number of authorizations for which corrective 
filings have been submitted as of the date of the report.  Within one year of 
completing a Covered Transaction involving the acquisition of 150 microwave 
station authorizations or fewer, AT&T shall submit, as part of its 1-year 
Compliance Report, a certification that it has identified all microwave stations 
acquired in the Covered Transaction that require a corrective filing and has 
submitted all such corrective filings. 
(d) 2-year Compliance Report.  Within two years of completing a Covered
Transaction involving the acquisition of more than 150 microwave station 
authorizations, AT&T shall submit a Compliance Report to the Bureau in which 
for each acquired microwave station, it indicates: (i) whether it has completed 
its analysis of the station to determine if it is operating in accordance with its 
authorization; (ii) if so, whether the station requires a corrective filing and the 
date this was determined; (iii) for each such station, the nature of the corrective 
filing required (such as a major or minor modification or a cancellation notice), 
as well as the reason for the corrective filing (such as that a new survey 
indicates that the elevation differs from the elevation indicated in the 
Commission’s records, or that the station is no longer in use); (iv) the total 
number of such authorizations identified as of the date of the report that require 
a corrective filing; and (v) the number of authorizations for which corrective 
filings have been submitted as of the date of the report.  AT&T shall submit, as 
part of its 2-year Compliance Report, a certification that it has identified all 
microwave stations acquired in the Covered Transaction that require a 
corrective filing and has submitted all such corrective filings. 
12. Compliance Reports.  In addition to the information required by paragraph 11, the 
final Compliance Report submitted in connection with a Covered Transaction (for Covered 
Transactions involving 150 microwave station authorizations or fewer, the final Compliance Report 
will be the 1-Year Compliance Report; for Covered Transactions involving more than 150 
microwave station authorizations, the final Compliance Report will be the 2-Year Compliance 
Report unless the 1-year Compliance Report includes all acquired authorizations) shall include a 
Federal Communications Commission DA 16-1032
6
certification by the Compliance Officer, as an agent of and on behalf of AT&T, stating that the 
Compliance Officer has personal knowledge that AT&T: (i) has established and implemented the 
Compliance Plan; (ii) has performed the Gap Analysis in connection with the Covered Transaction, 
(iii) has identified all necessary corrective filings, and; (iv) 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 of this Consent Decree.
(a) The Compliance Officer's certification shall be accompanied by a statement
explaining the basis for such certification and shall 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.
16
(b) If the Compliance Officer cannot provide the requisite certification, the
Compliance Officer, as an agent of and on behalf of AT&T, 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 AT&T has taken 
or will take to remedy such noncompliance, including the schedule on which 
proposed remedial actions will be taken; and (iii) the steps that AT&T has 
taken or will take to prevent the recurrence of any such noncompliance, 
including the schedule on which such preventive action will be taken.
(c) All Compliance Reports, including any associated Compliance Officer 
certifications or noncompliance reports required by Paragraphs 12(a)-(b), 
above,  shall be submitted to the Chief, Spectrum Enforcement Division, 
Enforcement Bureau, Federal Communications Commission, 445 12th Street, 
SW, Rm. 4C-224, Washington, DC 20554, with copies submitted
electronically to Paul Noone at Paul.Noone@fcc.gov and Pamera Hairston at 
Pamera.Hairston@fcc.gov.
13. Termination Date. Unless stated otherwise, the requirements set forth in paragraphs 10 
through 12 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.  For the 
avoidance of doubt, this Consent Decree shall not apply to transactions completed more than 36 months 
after the Effective Date, but the reporting obligations in Paragraphs 10 through 12 of this Consent Decree 
shall continue to apply after the Termination Date with respect to any Covered Transaction completed 
less than 36 months after the Effective Date.
14. Section 208 Complaints; Subsequent Investigations. Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
Section 208 of the Act
17
against AT&T or its affiliates for alleged violations of the Act, or for any other 
type of alleged misconduct, regardless of when such misconduct took place.  The Commission's 
adjudication of any such complaint 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 AT&T with the Communications
Laws.
15. Civil Penalty.  AT&T will pay a civil penalty to the United States Treasury in the 
amount of four-hundred and fifty thousand dollars ($450,000.00) within thirty (30) calendar days of the 
Effective Date.  AT&T shall send electronic notification of payment to Paul Noone at 
Paul.Noone@fcc.gov, Pamera Hairston at Pamera.Hairston@fcc.gov, and Samantha Peoples at 
Sam.Peoples@fcc.gov on the date said payment is made.  The payment must be made by check or similar 
instrument, wire transfer, or credit card, and must include the Account Number and FRN referenced in the 
caption of the Adopting Order.  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 
                                                     
16
47 CFR § 1.16.
17
  47 U.S.C. § 208.
Federal Communications Commission DA 16-1032
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 that should be followed based on the form of 
payment selected:
? 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.
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.
16. Waivers.  As of the Effective Date, AT&T 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.  AT&T 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 Consent 
Decree or the Adopting Order, neither AT&T nor the Commission shall contest the validity of the 
Consent Decree or the Adopting Order, and AT&T shall waive any statutory right to a trial de novo.  
AT&T hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice Act
1
relating to the matters addressed in this Consent Decree.
17. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
18. 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.
19. 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 AT&T does not expressly 
consent) that provision will be superseded by such Rule or Order.
20. Successors and Assigns.  AT&T agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees and any AT&T affiliate that acquires Commission 
microwave licenses.
                                                     
1
See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530.
Federal Communications Commission DA 16-1032
2
21. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation. 
22. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
23. 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.
24. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions.
25. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Travis LeBlanc
Chief
Enforcement Bureau
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John Monday
Vice President 
AT&T Inc.
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