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Federal Communications Commission DA 17-16
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Conroy Dawson,
Paterson, New Jersey
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File No. EB-FIELDNER-16-00022155
1
NAL/Acct. No.: 201732380001
FRN: 0026151753
NOTCE OF APPARENT LIABILITY FOR FORFEITURE
Adopted:  January 11, 2017 Released: January 12, 2017
By the Regional Director, Region One, Enforcement Bureau:
I. INTRODUCTION
1. We propose a penalty of $25,000 against Conroy Dawson for operating an unlicensed 
radio station on 97.5 MHz in Paterson, New Jersey.  The Commission previously warned Mr. Dawson 
that operation of this unlicensed station was illegal and that continued operation could result in further 
enforcement action.  Mr. Dawson’s deliberate disregard of the Commission’s warning warrants a 
significant penalty.  Commission action in this area is essential because unlicensed radio station create a 
danger of interference to licensed communications and undermine the Commission’s authority over FM 
broadcast radio operations.  
II. BACKGROUND
2. On October 17, 2015 the Commission received a complaint from the licensee of an FM 
translator station located in Jersey City, New Jersey, alleging that an unauthorized station was causing co-
channel interference on 97.5 MHz.  On November 17, 2015, two agents from the Commission’s New 
York Field Office (New York Office) used direction finding techniques to trace the source of the 
interfering signal on 97.5 MHz to a residential building located in Paterson, New Jersey (First Site).  The 
agents observed an FM broadcast antenna mounted on the roof of the First Site and recorded a portion of 
the station’s audio stream in which the announcer identified the station as “Big Link Radio” and 
announced a telephone number that listeners could use to reach the station’s studio (Call-In Number).  
The agents took field strength measurements of the station’s signal and determined that the transmissions 
on 97.5 MHz exceeded the limits for operation under Part 15 of the Commission’s rules (Rules), and 
therefore required a license.
2
  The agents consulted the Commission’s records and confirmed that the 
                                                     
1
The investigation began under File Nos. EB-FIELDNER-15-00020409 and EB-FIELDNER-16-00021696 and was 
subsequently assigned File No. EB-FIELDNER-16-00022155. Any future correspondence with the Commission 
concerning this matter should reflect the new case number.
2
Section 15.239 of the Rules provides that non-licensed broadcasting in the 88-108 MHz band is permitted only if 
the field strength of the transmission does not exceed 250 micro volts per meter (“?V/m”) at three meters. 47 CFR 
§ 15.239. Measurements showed that the field strength of the station's signal exceeded the permissible level for a 
non-licensed Part 15 transmitter.
Federal Communications Commission DA 17-16
2
Commission had not authorized an FM broadcast station to operate on 97.5 MHz at or near the First Site.  
The agents consulted the online property tax records of Paterson, New Jersey and, after identifying 
Mantari Investments LLC (Mantari) as the owner of the First Site, issued to Mantari a Notice of 
Unlicensed Operation (NOUO), dated December 2, 2015.  The NOUO informed Mantari that an 
unlicensed radio station was operating at 97.5 MHz at the First Site and warned it that continued 
unlicensed operations could result in additional enforcement action.
3
  On January 20, 2016, agents from 
the New York Office confirmed that the pirate broadcast station was no longer operating on 97.5 MHz 
from the First Site. 
3. On May 9, 2016, the Commission received a new complaint that an unlicensed station, 
identifying itself as WBLR, was again operating on 97.5 MHz in Paterson, New Jersey.
4
  The next day, an 
agent used direction finding techniques to trace the source of the signal on 97.5 MHz to the First Site.  
The agent recorded a portion of the station’s audio in which the announcer identified the station as 
“WBLR – Big Link Radio 97.5 FM.”  The agent took field strength measurements of the station’s signal 
and determined that the transmissions on 97.5 MHz exceeded the limits for operation under Part 15 of the 
Rules and therefore required a license.
5
  The agent consulted the Commission’s records and confirmed 
that the Commission had not authorized an FM broadcast station to operate on 97.5 MHz at or near the 
First Site.  On May 17, 2016, the agent returned to the First Site and spoke with building maintenance 
personnel, who accompanied the agent to the building’s roof, where the agent observed an FM broadcast 
antenna with coaxial cable that ran to an apartment within the First Site (Apartment).  The building 
maintenance personnel confirmed that a radio station operated from the Apartment.  Upon interviewing 
another tenant at the First Site, the agent confirmed that Mr. Dawson and one of Mr. Dawson’s relatives 
occupied the Apartment and operated a radio station from that location.  On May 23, 2016, the New York 
Office sent Mr. Dawson a NOUO (Dawson NOUO) informing him that an unlicensed radio station was 
operating at 97.5 MHz at the First Site and warning him that continued unlicensed operations could result 
in additional enforcement action.
6
  That same day, the New York Office also sent Mantari a second 
NOUO.
7
4. On May 31, 2016, a representative of Mantari contacted the New York Office, confirmed 
that Mr. Dawson was operating a station from the First Site, and stated that Mantari had requested that 
Mr. Dawson remove the FM broadcast antenna from the First Site.  The Mantari representative also stated 
that Mr. Dawson claimed to have a Commission license to operate the station, but he was unable to 
produce a copy of the license upon Mantari’s request.  On June 1, 2016, Mr. Dawson contacted the New 
York Office and spoke with an agent, who advised Mr. Dawson that (a) he needed a license to operate an 
FM broadcast station on 97.5 MHz in Paterson, New Jersey and (b) continued unlicensed operations 
could result in additional enforcement actions.  During the conversation with the agent, Mr. Dawson 
stated that he had applied for a Commission license to operate the station, but he did not provide the agent 
with more information about the purported application.
8
  Mr. Dawson then told the agent that he would 
remove the transmission equipment from the Apartment.  On June 6, 2016, a representative from Mantari 
                                                     
3
Mantari Investments LLC, Notice of Unlicensed Operation (New York Office, EB, Dec. 2, 2015).  On December 8, 
2015, the New York Office received confirmation that the NOUO had been delivered to Mantari, but the New York 
Office did not receive a written response from Mantari.
4
We note that the Commission has assigned the WBLR call sign to an AM broadcast station licensed to Augusta 
Radio Fellowship Institute, Inc. in Batesburg, South Carolina.
5
See 47 CFR § 15.239. 
6
Conroy Dawson, Notice of Unlicensed Operation (New York Office, EB, May 23, 2016).  The New York Office 
confirmed with the U.S. Postal Service that the Dawson NOUO was delivered on May 26, 2016. 
7
Mantari Investments LLC, Notice of Unlicensed Operation (New York Office, EB, May 23, 2016).
8
Following the conversation with Mr. Dawson, the agent reviewed the Commission’s licensing databases and could 
not find evidence of Mr. Dawson having applied for a broadcast license. 
Federal Communications Commission DA 17-16
3
contacted the New York Office and confirmed the removal of the FM broadcast antenna from the First 
Site. 
5. On July 6, 2016, the New York Office received a complaint alleging that an unlicensed 
station was operating on 97.5 MHz in Paterson, New Jersey.  On August 2, 2016, an agent from the New 
York Office used direction finding techniques to trace the source of the interfering signal on 97.5 MHz to 
a different residential building in Paterson, New Jersey (Second Site). The agent observed an FM 
broadcast antenna mounted on the roof of the Second Site and recorded a portion of the station’s audio
stream, during which the announcer identified the station as “WBLR – Big Link Radio” and publicized 
the Call-In Number as a way to contact the station’s studio.  The agent took field strength measurements 
of the station’s signal and determined that the transmissions on 97.5 MHz exceeded the limits for 
operation under Part 15 of the Rules, and therefore required a license.
9
  The agent consulted the 
Commission’s records and confirmed that the Commission had not authorized an FM broadcast station to 
operate on 97.5 MHz at or near the Second Site.  The agent then posted a Notice of Unlicensed Radio 
Operation on the front door of the Second Site.
10
  
6. On August 9, 2016, the agent from the New York Office returned to the Second Site to 
determine whether the unlicensed station was still broadcasting.  At the Second Site, the agent observed 
that the unlicensed station remained on the air and that an FM broadcast antenna was still present on the 
building’s roof.  However, after further observation, the agent concluded that the unlicensed station was 
no longer operating from the Second Site.  The agent then used direction finding techniques to trace the 
source of the unlicensed signal on 97.5 MHz to a possible location in Paterson, New Jersey.  However, 
before the agent was able to establish the station’s precise location, the station was taken off the air.  
While the station was on the air, however, the agent recorded a portion of the station’s audio stream, in 
which the announcer identified the station as “WBLR – Big Link Radio.”  
7. On August 17, 2016, the agent returned to the Second Site and observed that the FM 
broadcast antenna remained on the building’s roof but that the unlicensed station was operating from a 
different location.  Using direction finding techniques, the agent traced the source of the transmissions to 
a single family dwelling in Paterson, New Jersey (Third Site).  The agent observed the presence of an FM 
broadcast antenna in a tree at the Third Site and recorded a portion of the station’s audio, in which the 
announcer identified the station as “WBLR – Big Link Radio.”  The agent took field strength 
measurements of the station’s signal and determined that the transmissions on 97.5 MHz exceeded the 
limits for operation under Part 15 of the Rules, and therefore required a license.
11
  The agent consulted the 
Commission’s records and confirmed that the Commission had not authorized an FM broadcast station to 
operate on 97.5 MHz at or near the Third Site.  
III. DISCUSSION
8. We find that Mr. Dawson apparently willfully and repeatedly violated Section 301 of the 
Communications Act of 1934, as amended (Act).  Section 301 of the Act states that no person shall use or 
operate any apparatus for the transmission of energy or communications or signals by radio within the 
United States without a license granted by the Commission.
12
  As noted above, after Mr. Dawson 
removed the unlicensed FM broadcast station’s equipment from the First Site, agents from the New York 
Office determined that Mr. Dawson has repeatedly operated his unlicensed FM broadcast station on 
97.5 MHz from three additional locations in Paterson, New Jersey.
13
  Despite receiving a written warning 
                                                     
9
47 CFR § 15.239.
10
Owner, Notice of Unlicensed Radio Operation (New York Office, EB, Aug. 2, 2016). 
11
47 CFR § 15.239
12
47 U.S.C. § 301. 
13
See paras. 5-7, supra.
Federal Communications Commission DA 17-16
4
from the New York Office and a subsequent verbal warning from an agent of the New York Office in 
connection with his operations from the First Site, Mr. Dawson has chosen to continue to operate his 
illegal station on 97.5 MHz and has established a pattern of relocating his unlicensed FM broadcast 
station shortly after the New York Office issues a NOUO to the applicable building owner.  This course 
of conduct demonstrates Mr. Dawson’s continued awareness that his operation of an unlicensed FM 
station on 97.5 MHz in Paterson, New Jersey violates Section 301 of the Act. 
9. Section 503(b) of the Act authorizes the Commission to impose a forfeiture against any 
entity that “willfully or repeatedly fail[s] to comply with any of the provisions of [the Act] or of any rule, 
regulation, or order issued by the Commission.”
14
  Here, Section 503(b)(2)(D) of the Act authorizes us to 
assess a forfeiture against Mr. Dawson up to $18,936  for each day of a continuing violation, up to a 
statutory maximum of $142,021 for a single act or failure to act.
15
  In exercising our forfeiture authority, 
we must consider 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.”
16
  In addition, the Commission has established forfeiture guidelines; they establish 
base penalties for certain violations and identify criteria that we consider when determining the 
appropriate penalty in any given case.
17
  Under these guidelines, we may adjust a forfeiture upward for 
violations that are egregious, intentional, or repeated, or that cause substantial harm or generate 
substantial economic gain for the violator.
18
  Section 1.80(b) of the Rules sets a base forfeiture of $10,000 
for operation without an instrument of authorization for each violation or each day of a continuing 
violation.
19
  
10. Through its investigation, the Enforcement Bureau has determined that Mr. Dawson 
operated an unlicensed FM station on 97.5 MHz (a) on May 10, 2016, from the First Site, and (b) between 
August 2 and August 17, 2016, from the Second Site and the Third Site, all in apparent violation of 
Section 301 of the Act. In light of these findings, we propose an aggregate base forfeiture of $20,000 for 
these apparent violations of Section 301 of the Act.  We have discretion, however, to depart from these 
guidelines, taking into account the particular facts of each individual case.
20
  Given the totality of the 
                                                     
14
47 U.S.C. § 503(b).
15
See 47 U.S.C. § 503(b)(2)(D); 47 CFR §§ 1.80(b)(7), (9).  These amounts reflect inflation adjustments to the 
forfeitures specified in Section 503(b)(2)(D) ($10,000 per violation or per day of a continuing violation and $75,000 
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), as further amended by the Federal Reports Elimination Act of 1998, Pub. L. No. 105-362, 
Sec. 1301, 112 Stat. 3280, and as further amended by the Federal Civil Penalties Inflation Adjustment Act 
Improvements Act of 2015, Sec. 701, Pub. L. No. 114-74, 129 Stat. 599 (codified as amended 28 U.S.C. § 2461 
note) (the 2015 Inflation Adjustment Act), requires the Commission to adjust its penalties for inflation and publish 
interim final rules with the initial penalty adjustment amounts by July 1, 2016 and new penalty levels must take 
effect no later than August 1, 2016.  See 28 U.S.C. § 2461 note.  The Commission published those interim final rules 
on June 30, 2016.  See Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment of Civil Monetary 
Penalties to Reflect Inflation, Order, 31 FCC Rcd 6793 (EB 2016); see also Adjustment of Civil Monetary Penalties 
to Reflect Inflation, 81 Fed. Reg. 42554 (June 30, 2016) (setting August 1, 2016, as the effective date for the 
increases).  The adjustments to the civil monetary penalties adopted by the Bureau pursuant to 2015 Inflation 
Adjustment Act will apply only to such penalties assessed after the effective date of the amendments to Section 
1.80(b).  See 28 U.S.C. § 2461 note (6).   
16
47 U.S.C. § 503(b)(2)(E).
17
47 CFR § 1.80(b)(8), Note to paragraph (b)(8).
18
Id.
19
47 CFR § 1.80(b).
20
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, 17098–99, para. 22 (1997) (noting that “[a]lthough we 
(continued….)
Federal Communications Commission DA 17-16
5
circumstances, and consistent with the Forfeiture Policy Statement, we conclude that a significant upward 
adjustment is warranted.  While still operating at the First Site, Mr. Dawson was instructed to cease 
operating his unlicensed FM broadcast station.  Yet, instead of complying with the Commission’s 
instructions, Mr. Dawson continued to operate his illegal station from a series of different locations.  We 
therefore propose an upward adjustment of $5,000 based on the repeated nature of Mr. Dawson’s 
apparent violations of Section 301 of the Act.  After applying the Forfeiture Policy Statement, Section 
1.80 of the Rules, and the statutory factors, we therefore propose a total monetary forfeiture of $25,000 
for which Mr. Dawson is apparently liable.  
IV. CONCLUSION
11. We have determined that Mr. Dawson apparently willfully and repeatedly violated 
Section 301 of the Act.  As such, Mr. Dawson is apparently liable for a forfeiture of $25,000.
V. ORDERING CLAUSES 
12. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act
21
and 
Sections 1.80 of the Rules,
22
Conroy Dawson is hereby NOTIFIED of this APPARENT LIABILITY 
FOR A FORFEITURE in the amount of Twenty-Five Thousand Dollars ($25,000) for willful and 
repeated violations of Section 301 of the Act.
23
  
13. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Rules,
24
within thirty 
(30) calendar days of the release date of this Notice of Apparent Liability for Forfeiture, Conroy Dawson
SHALL PAY the full amount of the proposed forfeiture or SHALL FILE a written statement seeking 
reduction or cancellation of the proposed forfeiture consistent with paragraph 16 below.
14. 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.  Public Safety 
Technologies, Inc. shall send electronic notification of payment to NER-Response@fcc.gov and 
Matthew.Gibson@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.
25
  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 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.
(Continued from previous page)                                                            
have adopted the base forfeiture amounts as guidelines to provide a measure of predictability to the forfeiture 
process, we retain our discretion to depart from the guidelines and issue forfeitures on a case-by-case basis, under 
our general forfeiture authority contained in Section 503 of the Act”) (Forfeiture Policy Statement), recons. denied, 
Memorandum Opinion and Order, 15 FCC Rcd 303 (1999).
21
47 U.S.C. § 503(b).
22
47 CFR § 1.80.
23
47 U.S.C. § 301.
24
47 CFR § 1.80.
25
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
Federal Communications Commission DA 17-16
6
? 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.
15. 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.
26
  Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by phone, 1-877-480-3201, or by e-mail, 
ARINQUIRIES@fcc.gov.
16. The written statement seeking reduction or cancellation of the proposed forfeiture, if any, 
must include a detailed factual statement supported by appropriate documentation and affidavits pursuant 
to Sections 1.16 and 1.80(f)(3) of the Rules.
27
  The written statement must be mailed to Region One 
Regional Office, Federal Communications Commission, 9200 Farm House Lane, Columbia MD 21046, 
and must include the NAL/Account Number referenced in the caption.  The statement must also be e-
mailed to NER-Response@fcc.gov and Matthew.Gibson@fcc.gov. 
17. The Commission will not consider reducing or canceling a forfeiture in response to a 
claim of inability to pay unless the petitioner submits:  (1) federal tax returns for the most recent three-
year period; (2) financial statements prepared according to generally accepted accounting practices; or 
(3) some other reliable and objective documentation that accurately reflects the petitioner’s current 
financial status.  Any claim of inability to pay must specifically identify the basis for the claim by 
reference to the financial documentation.
18. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by first class mail and certified mail, return receipt requested, Conroy Dawson at 
his address of record.
FEDERAL COMMUNICATIONS COMMISSION
David Dombrowski,
Regional Director, Region One
Enforcement Bureau
                                                     
26
See 47 CFR § 1.1914.
27
47 CFR §§ 1.16, 1.80(f)(3).