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                                                      Federal Communications Commission                    DA 16-1196
Before the
Federal Communications Commission
Washington, D.C.  20554
In the Matter of
Simple Network, Inc.
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File No. EB-IHD-13-00011486
1
NAL/Acct. No. 201532080014
FRN No. 0007921224
FORFEITURE ORDER 
Adopted:  October 26, 2016    Released:  October 26, 2016
By the Deputy Chief, Enforcement Bureau:
I. INTRODUCTION
1. We impose a penalty of $100,000 against Simple Network, Inc. (Simple Network or 
Company) for providing interstate telecommunications services without previously registering with the 
Commission as required by Section 64.1195 of the Commission’s rules (Rules).  In the Simple Network 
NAL, we found that Simple Network’s failure to register allowed the Company to avoid making required 
payments to important federal programs, which gave it an unfair economic advantage over competing 
companies that complied with the Rules. In its response to the NAL, Simple Network argues that the 
Enforcement Bureau (Bureau) did not adequately justify and explain the nature of the violation or the 
proposed penalty against the Company.  For the reasons set forth below, we disagree.  After reviewing 
Simple Network’s response to the NAL, we find no reason to cancel, withdraw, or reduce the proposed 
penalty, and we therefore assess the $100,000 forfeiture the Bureau previously proposed.
II. BACKGROUND
2. The underlying facts and circumstances for this Forfeiture Order are set forth in the 
Simple Network NAL, and need not be reiterated here at length.
2
  Simple Network is a New Jersey 
corporation that provides prepaid calling card services.  The Company claims to have “been in the 
international . . . calling card and telecom services business for 15 years.”
3
Notably, the Commission 
recently fined the Company $5 million “for deceptively marketing its prepaid telephone calling cards.”
4
                                                     
1
The investigation began under File No. EB-12-IH-0179 and was subsequently assigned a new case number, File 
No. EB-IHD-13-00011486.  Any future correspondence with the Commission regarding this matter should reflect the 
new case number.
2
See Simple Network, Inc., Notice of Apparent Liability for Forfeiture and Order, 30 FCC Rcd 4525 (EB 2015).
(Simple Network NAL or NAL).
3
See Mother India Online, About Us, https://www.motherindiacard.com/aboutus.asp (last visited June 27, 2016).
4
Simple Network, Inc., Forfeiture Order, 30 FCC Rcd 11765 (2015).
                           Federal Communications Commission                              DA 16-1196
2
3. On May 4, 2015, we released the Simple Network NAL, which proposed a forfeiture of 
$100,000 against Simple Network for its apparent violation of Section 64.1195 of the Rules by failing to 
register with the Commission.
5
Carriers’ compliance with the Commission’s registration requirement is 
critical to the administration of the Universal Service Fund (USF), Telecommunications Relay Service 
(TRS) Fund and other programs, and to fulfilling a number of Congress’s objectives under the Act.
6
  
Registration allows the Commission and the various program administrators to ascertain which 
companies are fulfilling their regulatory obligations.
7
  These obligations include filing regular 
Telecommunications Reporting Worksheets (Worksheets or Forms 499) and contributing to federal 
programs that support, among other things, increasing access to telecommunications for people with 
disabilities and certain other populations.
8
  Entities that fail to register with the Commission and 
contribute to federal regulatory programs enjoy an unfair economic advantage over competitors who, as a 
result of following the Rules, must pay more than their fair share of the costs of these programs.
9
4.   On June 3, 2015, Simple Network’s counsel submitted a response to the NAL, along 
with a Declaration by Herman R. Patel, President and CEO of Simple Network, and the Company’s 
Federal income tax returns for 2014, 2013, and 2012.
10
  In its NAL Response, Simple Network makes a 
number of arguments as to why the NAL should be canceled or reduced, including that the Company 
provides “international services and thus it is not required to pay into the Universal Service Fund,”
11
and 
that the Company is unable to pay the forfeiture.
12
  Further, Simple Network requested that the proposed 
forfeiture be dismissed in its entirety, or, in the alternative, that the Company pay a total of $10,000 over 
                                                     
5
See Simple Network NAL, 30 FCC Rcd 4525; 47 CFR § 64.1195.
6
See RB Communications, Inc., d/b/a Starfone, Notice of Apparent Liability for Forfeiture and Order, 27 FCC Rcd 
4393, 4398, para. 16 (2012) (Starfone), forfeiture issued, Forfeiture Order, 29 FCC Rcd 5668 (2014).
7
See id.
8
See id.; see also 47 U.S.C. §§ 225, 251, 254.
9
Sixty days prior to the start of each quarter, USAC must provide the Commission with a projection of the high 
cost, low income, schools and libraries, and rural health care funding requirements for the following quarter. USAC, 
FCC Filings, http://www.usac.org/about/tools/fcc/filings/default.aspx (last visited June 27, 2016).  Based on 
USAC’s projection of the needs of the USF, and revenue projections from the registered carriers subject to universal 
service requirements, the Commission establishes a specific percentage of interstate and international end-user 
revenues that each subject telecommunications provider must contribute toward the USF. This percentage is called 
the contribution factor. The contribution factor, and, consequently, the amount owed to the USF by each affected 
telecommunications company, changes each quarter, depending on the needs of the USF and carrier-provided 
revenue projections. See FCC Managing Director, Contribution Factor & Quarterly Filings—Universal Service 
Fund (USF) Management Support, https://www.fcc.gov/encyclopedia/contribution-factor-quarterly-filings-
universal-service-fund-usf-management-support (last visited June 27, 2016). Thus, in cases where a carrier, such as 
Simple Network, fails to file required Worksheets reporting its revenue projections in a timely fashion, its revenues 
are excluded from the contribution base from which universal service assessments are derived, and the economic 
burden of contributing falls disproportionately on carriers that have satisfied their reporting obligations.
10
See Letter from Neil S. Ende, Technology Law Group, LLC, Counsel to Simple Network, Inc., to Marlene H. 
Dortch, Secretary, FCC (June 3, 2015) (on file in EB-IHD-13-00011486) (Simple Network NAL Response).
11
Simple Network NAL Response at 6.
12
See id. at 7; E-mail from Neil S. Ende, Technology Law Group, LLC, Counsel to Simple Network, Inc., to Pam 
Slipakoff, Attorney Advisor, FCC Enforcement Bureau (Sept. 30, 2016, 15:29 EDT) (on file in EB-IHD-13-
00011486) (Simple Network September 30, 2016 E-mail).
                           Federal Communications Commission                              DA 16-1196
3
twelve months, register and begin to file the Worksheets “as deemed necessary under its present business 
operations.”
13
  We find all of these responses unacceptable.  
III. DISCUSSION
5. The Bureau proposed a forfeiture in this case in accordance with Section 503(b) of the 
Communications Act of 1934, as amended (Act),
14
Section 1.80 of the Rules,
15
and the Commission’s 
Forfeiture Policy Statement.
16
  When we assess forfeitures, Section 503(b)(2)(E) requires that we take 
into account the “nature, circumstances, extent, and gravity of the violation and, with respect to the 
violator, the degree of culpability, any history of prior offenses, ability to pay, and such other matters as 
justice may require.”
17
  As discussed below, we have fully considered Simple Network’s legal and factual 
arguments in response to the NAL, and we find none of them persuasive.  We therefore affirm the 
$100,000 forfeiture proposed in the NAL.
A. Simple Network Failed to Comply with the Commission’s Rules
6. We find by a preponderance of the evidence that Simple Network willfully and 
repeatedly engaged in the violation described in the NAL.  More specifically, we find that Simple 
Network willfully and repeatedly violated Section 64.1195 of the Rules by failing to register with the 
Commission prior to providing interstate telecommunications service.
7. All providers of interstate telecommunications services, including prepaid calling card 
service providers and providers of international telecommunications, such as Simple Network, are 
required to contribute to the USF, TRS Fund, and numbering support mechanisms, and pay regulatory 
fees.
18
  To do so, all contributors must register with the Commission by filing an Annual 
Telecommunications Reporting Worksheet (Form 499-A) in accordance with Section 64.1195 of the 
Rules.
19
8. The Form 499-A Instructions state, “[w]ith very limited exceptions, all intrastate, 
interstate, and international providers of telecommunications in the United States must file this 
Worksheet.”
20
In 2002, Simple Network applied for and received a “Grant of Authority” from the 
Commission to “operate as a facilities based carrier in accordance with the provisions of Section 
63.18(e)(1) of the rules, and also to provide service in accordance with the provisions of Section 
                                                     
13
Simple Network NAL Response at 1–2, 7; see also Simple Network September 30, 2016 E-mail.
14
47 U.S.C. § 503(b).
15
47 CFR § 1.80.
16
The Commission’s Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the 
Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087 (1997) (Forfeiture Policy Statement), recons. denied, 
Memorandum Opinion and Order, 15 FCC Rcd 303 (1999).
17
47 U.S.C. § 503(b)(2)(E).
18
See 47 CFR §§ 1.1154, 52.17, 54.706(a)(19), 64.604(c)(5)(iii)(A) (explaining which entities are required to 
contribute to federal support mechanisms and pay regulatory fees); see also 47 U.S.C. §§ 159, 225, 251, 254 
(providing congressional mandates for federal support mechanisms and the collection of regulatory fees).
19
  See 47 CFR §§ 64.1195; 52.17(a); 54.711(a); 64.604(c)(5)(iii)(B); 2016 Telecommunications Reporting 
Worksheet Instructions, FCC Form 499-A at 4 (Jan. 2016) available at
https://apps.fcc.gov/edocs_public/attachmatch/DA-16-138A2.pdf (2016 FCC Form 499-A Instructions); see also
United States v. Unipoint, Civil No. 14-12020-LTS, 2016 WL 424955 at *3 (D. Mass. Feb. 3, 2016) 
(“Telecommunications carriers providing international telecommunications service must register with the FCC, 
which requires submitting an FCC Form 499-A.”).
20
2016 FCC Form 499-A Instructions at 4 (internal citations omitted).
                           Federal Communications Commission                              DA 16-1196
4
63.18(e)(2) of the rules.”
21
  Because the Company has a “Grant of Authority” to provide “international 
services,” it follows that the Company has violated Section 64.1195 of the Commission’s Rules by failing 
to register with the Commission through the filing of a Form 499-A.
22
   
9. Simple Network claims that the NAL failed to allege that the Company provides interstate 
telecommunications services, or provide the dates of the violation.  These arguments are inapposite.  As 
discussed above, because Simple Network is a prepaid calling card service provider authorized to provide 
international service, it must register with the Commission prior to providing service, and contribute to 
various funds on the basis of its revenues.  Accordingly, the NAL clearly described Simple Network’s 
failure to file a Form 499-A in violation of Section 64.1195 of the Rules, as well as the violation’s
duration, which began on the date the Company began providing service without registration in or around
1997, and continues until the Company files its initial Form 499-A.
23
10. Simple Network’s failure to register was also both willful and repeated, despite the 
Company’s arguments to the contrary.  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.
24
“Repeated” means that the act was committed or omitted more than once, or lasts more than one day.
25
The legislative history to Section 312 of the Act clarifies that the definitions of willful and repeated apply
to both Sections 312 and 503(b) of the Act,
26
and the Commission has so interpreted the terms in the 
Section 503(b) context.
27
  Based on the Rules, Simple Network’s failure to register was both willful and 
repeated.  As discussed in the NAL, the Company did not file a Form 499-A despite the requirement to do 
so.
28
  Accordingly, Simple Network’s failure to act has lasted for several years while the Company
provided telecommunications service over the same period without registering with the Commission.
29
   
11. Therefore, contrary to Simple Network’s arguments, we conclude that the NAL fully and 
properly explained the Company’s willful and repeated violation of Section 64.1195 of the Rules. 
B. The Forfeiture Amount Discussed in the NAL is Appropriate.
12. Section 503(b)(2)(B) of the Act authorizes the Commission to assess a forfeiture against 
Simple Network of up to $189,361 for each violation or each day of a continuing violation, up to a 
                                                     
21
International Authorizations Granted, Public Notice, Report No. TEL, 00609, DA No. 02-3416, File Number 
ITC-214-20021113-00549 at 2, 17 FCC Rcd 24831 (2002).
22
47 CFR § 64.1195.
23
See Simple Network NAL, 30 FCC Rcd at 4527, para. 6; see also Simple Network, About Us (2012), 
https://www.motherindiacard.com/aboutus.asp.
24
47 U.S.C. § 312(f)(1). Contrary to Simple Network’s argument, the Commission is not required to demonstrate 
scienter to prove that an act was willful under the Communications Act.
25
See 47 U.S.C. § 312(f)(2); Callais Cablevision, Inc., Notice of Apparent Liability for Monetary Forfeiture, 16 
FCC Rcd 1359, 1362, para. 9 (2001), forfeiture issued, 17 FCC Rcd 22626 (2002); Application for Review of 
Southern California Broadcasting Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388, para. 5 (1991) 
(Southern California Broadcasting Co.).
26
H.R. Rep. No. 97-765, 97
th
Cong. 2d Sess. 51 (1982).  Simple Network’s argument that Section 312(f) applies 
only to the violations in Section 312 of the Act is misplaced.  The legislative history explicitly states that the 
provision “defines the terms ‘willful’ and ‘repeated’ for purposes of Section 312, and for any other relevant section 
of the Act (e.g., Section 503).” Id. (emphasis added).
27
See, e.g., Southern California Broadcasting Co., 6 FCC Rcd at 4388, para. 5 (1991).
28
Simple Network NAL, 30 FCC Rcd at 4527, para. 6.
29
See id.
                           Federal Communications Commission                              DA 16-1196
5
statutory maximum of $1,893,610 for a single act or failure to act.
30
  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.”
31
13. In the Simple Network NAL, the Bureau imposed a base forfeiture of $100,000 for the 
failure to register under Section 64.1195 of the Commission’s rules.
32
This amount is reasonable in light 
of the Commission’s precedent in failure to register cases, and the facts uncovered in this investigation.
33
We note that this is a very limited action in light of the duration of the Company’s continuing violation 
and the Company’s ability to pay.
34
  In its response to the Simple Network NAL, the Company’s counsel 
states that Simple Network’s financial situation “fully supports the elimination of the One Hundred 
Thousand Dollar ($100,000) forfeiture in its entirety or a reduction of the forfeiture to no more than Ten 
Thousand Dollars on the condition that Simple Network is given at least One (1) year to make 
payment.”
35
  We do not accept this proposal.
                                                     
30
See 47 U.S.C. § 503(b)(2)(B); 47 CFR § 1.80(b)(9). These amounts reflect inflation adjustments to the forfeitures 
specified in Section 503(b)(2)(B) ($100,000 per violation or per day of a continuing violation and $1,000,000 per 
any single act or failure to act). The Federal Civil Penalties Inflation Adjustment Act of 1990, Pub. L. No. 101-410, 
104 Stat. 890, as amended by the Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, Sec. 31001, 110 
Stat. 1321 (DCIA), requires the Commission to adjust its forfeiture penalties periodically for inflation. See 28 
U.S.C. § 2461 note (4). The Commission most recently adjusted its penalties to account for inflation on June 9, 
2016. See Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment of Civil Monetary Penalties to 
Reflect Inflation, Order, DA 16-644, 2016 WL 3218781 (EB 2016); see also Inflation Adjustment of Monetary 
Penalties, 81 Fed. Reg. 42,554 (Jun. 30, 2016) (setting August 1, 2016 as the effective date for the increases).
However, because the DCIA specifies that any inflationary adjustment “shall apply only to violations which occur 
after the date the increase takes effect,” in the NAL we applied the forfeiture penalties in effect at the time the 
apparent violation took place. 28 U.S.C. § 2461 note (6). Here, because the apparent violation at issue occurred 
before August 1, 2016, the applicable maximum penalties are based on the Commission’s previous inflation 
adjustment that became effective on September 13, 2013. See Inflation Adjustment of Maximum Forfeiture 
Penalties, 78 Fed. Reg. 49,370-01 (Aug. 14, 2013).
31
47 U.S.C. § 503(b)(2)(E); 47 CFR § 1.80(b)(8).
32
See Simple Network NAL, 30 FCC Rcd at 4528, para. 8.
33
E.g., Starfone, 27 FCC Rcd at 4401, para. 24; Telecom House, Inc., Notice of Apparent Liability for Forfeiture 
and Order, 20 FCC Rcd 15131, 15142, para. 29 (2005), consent decree adopted, Order, 21 FCC Rcd 10883 (2006); 
Teletronics, Inc., Notice of Apparent Liability for Forfeiture and Order, 20 FCC Rcd 13291, 13302, para. 30 (2005), 
consent decree adopted, Order, 22 FCC Rcd 8681 (2007).
34
Simple Network wrongly claims that the Bureau’s reliance on Starfone and other relevant precedent renders the 
$100,000 forfeiture “arbitrary and capricious.” See Simple Network NAL Response at 5–6, n.5. We note that we 
have regularly stated that $100,000 is the base forfeiture established by the Commission for violating Section 
64.1195 of the Rules, based on the seriousness of the violation itself and the importance of registration. See supra
note 33.  Further, while Starfone and other cases may have involved violations in addition to failure to register, the 
forfeiture for violating Section 64.1195 was assessed separately from other violations in those cases. See, e.g., 
Starfone, 27 FCC Rcd at 4400–02, paras. 20–27. Further, the facts in this matter demonstrate, if anything, a more 
egregious violation of Section 64.1195 than was present in Starfone, because Simple Network failed to respond 
appropriately to the Bureau’s Letter of Inquiry and continues to be in noncompliance, whereas Starfone began to 
comply with the Rules during the pendency of the Bureau’s investigation. See Simple Network NAL, 30 FCC Rcd at 
4526, para. 4; Starfone, 27 FCC Rcd at 4396, paras. 9–11. We also note that the Bureau exercised its discretion 
when it declined to assess liability or forfeitures against Simple Network for failures to file regular Worksheets and 
was unable to determine whether the Company was required to contribute to the USF and other funds because the 
Company has never filed revenue information with the Commission.
35
Simple Network NAL Response at 6–7.
                           Federal Communications Commission                              DA 16-1196
6
14. The Company argues that it is not in “an economic position” to pay the $100,000 
forfeiture, and further contends that “the forfeiture is plainly punitive in nature.”
36
  However, the only 
documentation submitted in support of Simple Network’s claim of financial hardship were the U.S. 
income tax returns the Company provided with its NAL Response,
37
which do not support a downward 
adjustment or cancellation for inability to pay. In analyzing financial hardship claims, the Commission’s 
long established standard is to consider a company’s gross revenues.
38
The Commission has found that, 
“[i]n general, gross revenues are the best indicator of [a company’s] ability to pay a forfeiture.”
39
  In 
addition, while the Commission has noted that “in some cases other financial indicators, such as net 
losses, may also be relevant,” if “gross revenues are sufficiently great . . . the mere fact that a business is 
operating at a loss does not mean that it cannot afford to pay a forfeiture.”
40
  
15. Based on the tax returns submitted by the Company for the three year period of 2012
through 2014, we find that Simple Network has not demonstrated an inability to pay a $100,000 
forfeiture.
41
  The proposed forfeiture expressed as a percentage of Simple Network’s gross revenues is 
significantly less than the threshold used to determine an inability to pay reduction, and the other 
information the Company submitted fails to show that paying that percentage of its gross revenues would 
undermine its financial position.
42
Thus, the Company’s gross revenues clearly demonstrate an ability to 
pay the $100,000 forfeiture. The Bureau has previously observed that if a company “could escape 
meaningful sanctions for violations of the Rules by seeking an inability to pay reduction that is 
unsupported by its gross revenues, it would be in a position to undermine the remedial purposes of 
Section 503 of the Act.”
43
  In setting forfeiture amounts, the Commission is “guided by Congress’s stated 
                                                     
36
Id.
37
See supra para. 4; Simple Network NAL Response, Attachments 4–6 (Simple Network 2012–2014 Tax Returns).
38
See PTT Phone Cards, Inc., Forfeiture Order, 30 FCC Rcd 14701, 14706, para. 16 (2015) (PTT Phone Cards).
39
See PTT Phone Cards, 30 FCC Rcd at 14706, para. 16. See also Unipoint Techs., Inc. d/b/a Comfi.com d/b/a 
Masterbell.com d/b/a Pushline.com a/k/a Communications Fidelity, Forfeiture Order, 29 FCC Rcd 1633, 1643, para. 
29 (2014) (Unipoint) (citing PJB Commc’ns of Virg., Inc., Memorandum Opinion and Order, 7 FCC Rcd 2088, 
2089, para. 8 (1992) (PJB Communications)); see also Emigrant Storage LLC, Forfeiture Order, 29 FCC Rcd 3529, 
3532, para. 7 (2014).
40
See Unipoint, 29 FCC Rcd at 1643, para. 29 (citing PJB Communications, 7 FCC Rcd at 2089, para 8); see also 
Sunstar Travel & Tours, Inc., Forfeiture Order, 25 FCC Rcd 13804, 13808, para. 14 (2010).  
41
See Simple Network 2012–2014 Tax Returns; Unipoint, 29 FCC Rcd at 1643, para. 30. In its response to the 
NAL, Simple Network asserted that a judgment entered against the Company affected its ability to pay the forfeiture 
penalty. See Simple Network NAL Response at 7.  When Bureau Staff requested a copy of the judgment, the 
Company informed Bureau Staff for the first time that the judgment had been resolved. See Simple Network 
September 30, 2016 E-mail.  Bureau Staff also requested a copy of the Company’s 2015 tax return, which may have 
allowed us to consider the effect of the judgment on the Company’s economic position, and thus its ability to pay the 
forfeiture.  See E-mail from Pam Slipakoff, Attorney Advisor, FCC Enforcement Bureau, to Neil S. Ende,
Technology Law Group, LLC, Counsel to Simple Network, Inc. (Oct. 4, 2016, 09:22 EDT) (on file in EB-IHD-13-
00011486). Simple Network’s counsel declined, and strictly offered to provide the 2015 tax return in the context of 
settlement discussions. See E-mail from Neil S. Ende, Technology Law Group, LLC, Counsel to Simple Network, 
Inc., to Pam Slipakoff, Attorney Advisor, FCC Enforcement Bureau (Oct. 4, 2016, 10:28 EDT) (on file in EB-IHD-
13-00011486).  Thus, Simple Network failed to provide documentation sufficient to support its assertion that it was 
unable to pay the forfeiture penalty.
42
See Side By Side, Inc., Forfeiture Order, 23 FCC Rcd 7393, 7395–96, para. 8 & n.25 (EB-SED 2008), aff’d, 27 
FCC Rcd 11132, 11136–37, para. 9 (EB 2012) (Side By Side); see also Unipoint, 29 FCC Rcd at 1643, para. 30.
43
See, e.g., Side By Side, 23 FCC Rcd at 7395–96, para. 8 (citing Frank Neely, Memorandum Opinion and Order, 22 
FCC Rcd 1434, 1436, para. 8 (EB 2007)); see also Unipoint, 29 FCC Rcd at 1643, para. 31.
                           Federal Communications Commission                              DA 16-1196
7
goal of imposing forfeitures that are ‘sufficiently high to deter violations and constitute a meaningful 
sanction.’”
44
  Based on our review of Simple Network’s financial condition, we conclude that the 
Company has failed to prove it is unable to pay a forfeiture penalty of $100,000.
16. Therefore, having examined the financial records provided by the Company, consistent 
with precedent and after applying the Forfeiture Policy Statement, Section 1.80 of the Rules, and the 
statutory factors, we impose a total forfeiture of $100,000 against Simple Network.  We find no reason to 
cancel or reduce the forfeiture we proposed in the Simple Network NAL.
IV. CONCLUSION
17. Based on the record before us and in light of the applicable statutory factors, we conclude 
that Simple Network willfully and repeatedly violated Section 64.1195 of the Rules by providing 
interstate telecommunications services without registering with the Commission.  We decline to cancel or 
reduce the $100,000 forfeiture proposed in the NAL.
V. ORDERING CLAUSES
18. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act,
45
and Section 
1.80 of the Rules,
46
Simple Network, Inc. IS LIABLE FOR A MONETARY FORFEITURE in the 
amount of $100,000 for willfully and repeatedly violating Section 64.1195 of the Rules.
19. Payment of the forfeiture shall be made in the manner provided for in Section 1.80 of the 
Rules within thirty (30) calendar days after the release of this Forfeiture 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.
20. 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.  Simple Network, 
Inc. shall send electronic notification of payment to Pam Slipakoff at Pam.Slipakoff@fcc.gov and to 
Valerie Hill at Valerie.Hill@fcc.gov on the date said payment is made.  Regardless of the form of 
payment, a completed FCC Form 159 (Remittance Advice) must be submitted.   When completing the 
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 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 completed Form 159) must be mailed 
to the 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.
                                                     
44
See Radio X Broad. Corp., Memorandum Opinion and Order, 21 FCC Rcd 12209, 12217, para. 19 (2006) 
(quoting S. Rep. No. 580, 95th Cong. 1st Sess. 3 (1978), reprinted in 1978 U.S.C.C.A.N. 109, 111).  
45
47 U.S.C. § 503(b).
46
47 CFR § 1.80.
                           Federal Communications Commission                              DA 16-1196
8
? Payment by credit card must be made by providing the required credit card information on FCC 
From 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.
21. 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, SW, Room 1 A625, Washington, DC 20554.   Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by telephone, 1-877-480-3201, or by e-mail, 
ARINQUIRIES@fcc.gov.
22. IT IS FURTHER ORDERED that copies of this Forfeiture Order shall be sent by first 
class mail and certified mail, return receipt requested, to Herman R. Patel, Simple Network, Inc., 25 
South Main Street, Suite #6, Edison, NJ 08837, and to Neil S. Ende, Esq., Counsel for Simple Network, 
Inc., 5335 Wisconsin Avenue, NW, Suite 440, Washington, DC 20015.
FEDERAL COMMUNICATIONS COMMISSION
William Davenport
Deputy Chief
Enforcement Bureau