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Federal Communications Commission DA 17-40
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Straight Path Communications Inc., Ultimate
Parent Company of Straight Path Spectrum, LLC
Straight Path Spectrum, LLC
)
)
)
)
)
)
)
File No.: EB-SED-16-00022575
Acct. No.: 201732100003
FRN: 0022779334
ORDER
Adopted: January 11, 2017 Released: January 12, 2017
By the Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission
(Commission) has entered into a Consent Decree with Straight Path Communications, Inc., parent
company of Straight Path Spectrum, LLC (collectively, Straight Path), to resolve the Bureau’s
investigation into allegations that Straight Path violated the Commission’s buildout and discontinuance
rules in connection with Straight Path’s licenses in the 28 GHz and 39 GHz spectrum bands. The
Commission recently identified both of these bands as appropriate for the deployment of the next
generational evolution of wireless technologies (also referred to as “5G”).1 The Commission’s rules set
out construction and discontinuance requirements to promote productive use of spectrum, to encourage
provision of service to customers in a timely manner and to promote the provision of innovative services.2
A failure to comply with the construction and discontinuance rules undermines these important goals and
is contrary to sound spectrum management principles.
2. As the holder of radio licenses in the 39 GHz spectrum bands, Straight Path made
“substantial service” filings with the Commission in which it represented that it had met its buildout
requirements for the provision of wireless communications services in the 39 GHz bands. Straight Path
admits that an internal investigation determined that the equipment deployed in connection with the
buildout of its 39 GHz spectrum band licenses was put in place only for a short period of time and that a
significant amount of the installed equipment was no longer present at the original locations at the time of
the investigation. In short, the investigation found that Straight Path had not actually deployed equipment
with any permanency.
3. To settle this matter, Straight Path will pay to the United States Treasury (Treasury) a
$100,000,000 civil penalty, surrender to the Commission 196 of its licenses in the 39 GHz spectrum band,
sell the remainder of its license portfolio, and remit twenty percent (20%) of the proceeds of that sale to
the Treasury as an additional civil penalty. The first $15,000,000 of the $100,000,000 civil penalty will
be paid upfront on an installment basis, but the remaining $85,000,000 of the penalty is suspended,
pending Straight Path’s transfer or assignment of its license portfolio within the next 12 months. If
Straight Path does not transfer control of or assign its license portfolio to one or more qualified entities
within that time, the remaining $85,000,000 shall become due immediately or Straight Path shall
surrender to the Commission all of the licenses in its license portfolio. Finally, Straight Path agrees to
1 See Use of Spectrum Bands Above 24 GHz for Mobile Radio Services, Report and Order and Further Notice of
Proposed Rulemaking, 31 FCC Rcd 8014(2016) (Spectrum Frontiers Order).
2 Id., 31 FCC Rcd at 8085-93, paras. 191-228.
Federal Communications Commission DA 17-40
2
submit to the Commission for cancellation by January 18, 2017, ninety-three (93) of its 39 GHz economic
area licenses and all 103 of its 39 GHz rectangular service area licenses.
4. 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 regarding Straight Path’s compliance with Sections 1.17, 1.946, 1.955, 101.17,
101.63, 101.65, 101.305, and 101.1011 of the Commission’s rules.3 By adopting the Consent Decree, we
ensure that these licenses are put into beneficial use as quickly as possible, promoting the rapid and
widespread deployment of innovative wireless technologies to the public’s benefit.
5. In the absence of material new evidence relating to this matter or a subsequent violation
of the Consent Decree, we do not set for hearing the question of Straight Path’s basic qualifications to
hold or obtain any Commission license or authorization.4
6. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Communications Act
of 1934, as amended,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.
7. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED in
accordance with the terms of the attached Consent Decree.
8. 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 Straight Path Communications, Inc.,
c/o Davidi Jonas, 5300 Hickory Park Dr., Glen Allen, VA 23059; Russell H. Fox, Mintz Levin Cohn
Ferris Glovsky and Popeo PC, 701 Pennsylvania Avenue, NW, Suite 900, Washington, DC 20004; and to
Frank Lamancusa, Morgan, Lewis & Bockius LLP, 2020 K Street, NW, Washington, DC 20006-1806.
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief
Enforcement Bureau
3 47 CFR §§ 1.17, 1.946, 1.955, 101.17, 101.63, 101.65, 101.305, and 101.1011.
4 See 47 CFR § 1.93(b).
5 47 U.S.C. § 154(i).
6 47 CFR §§ 0.111, 0.311.
Federal Communications Commission DA 17-40
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Straight Path Communications Inc., Ultimate
Parent Company of Straight Path Spectrum, LLC
Straight Path Spectrum, LLC
)
)
)
)
)
)
)
File No.: EB-SED-16-00022575
Acct. No.: 201732100003
FRN: 0022779334
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission, Straight Path
Spectrum, LLC, and Straight Path Communications Inc., ultimate parent company of Straight Path
Spectrum, LLC, by their authorized representatives, hereby enter into this Consent Decree for the purpose
of terminating the Enforcement Bureau’s investigation into alleged violations of Sections 1.17, 1.946,
1.955, 101.17, 101.63, 101.65, 101.305, and 101.10111 of the Commission’s rules (Rules) in connection
with Straight Path Spectrum, LLC’s licenses to operate on the 28 GHz (27.5 – 28.35 GHz) and 39 GHz
(38.6 – 40 GHz) bands of the Fixed Microwave Services.
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.2
(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent
Decree without change, addition, deletion, or modification.
(c) “Bureau” means the Enforcement Bureau of the Federal Communications
Commission.
(d) “Commission” and “FCC” mean the Federal Communications Commission and all
of its bureaus and offices.
(e) “Communications Laws” means collectively, the Act, the Rules, and the published
and promulgated orders and decisions of the Commission to which Straight Path is
subject by virtue of its business activities, including but not limited to the Licensing
Rules.
(f) “Effective Date” means the date by which both the Bureau and Straight Path have
signed the Consent Decree.
(g) “Investigation” means the investigation commenced by the Bureau in EB-SED-16-
00022575 regarding whether Straight Path violated the Licensing Rules.
(h) “License Portfolio” means the radio licenses listed in Appendix A.
1 See 47 CFR §§ 1.17, 1.946, 1.955, 101.17, 101.63, 101.65, 101.305, 101.1011. But see Use of Spectrum Bands
Above 24 GHz for Mobile Radio Services, Report and Order and Further Notice of Proposed Rulemaking, 31 FCC
Rcd 8014, 8208, 8217 (2016) (Spectrum Frontiers Order) (new construction requirements now appear in 47 CFR
§ 30.105).
2 47 U.S.C. § 151 et seq.
Federal Communications Commission DA 17-40
2
(i) “Licensing Rules” means Sections 1.17, 1.946, 1.955, 101.17, 101.63, 101.65,
101.305, and 101.1011 of the Rules3 and other provisions of the Act, the Rules, and
Commission orders related to the conditions to apply for, renew, and hold licenses.
(j) “LOI” means the Letter of Inquiry issued by the Bureau to Straight Path on
September 20, 2016, in connection with Straight Path Spectrum, LLC’s licenses to
operate on the 28 GHz (27.5 – 28.35 GHz) and 39 GHz (38.6 – 40 GHz) bands.
(k) “Other Licenses” means the radio licenses listed in Appendix C.
(l) “Parties” means Straight Path and the Bureau, each of which is a “Party.”
(m) “Proceeds” means the aggregate amount Straight Path receives directly or indirectly
from one or more transactions (whether by merger, sale of shares, sale of assets or
otherwise) transferring control or assigning the License Portfolio or any portion
thereof from Straight Path, in one or more arm’s-length transactions, to unrelated
third-parties, regardless of the value that may be attributed individually to the
licenses in the License Portfolio as part of the transaction or transactions, but
excluding the value attributable to assets of Straight Path other than the License
Portfolio that are be included in the transaction (“Non-License Portfolio Assets”), if
any, pursuant to which the transfer of control or assignment of the License Portfolio
is implemented, provided that, notwithstanding the actual value of such Non-
License Portfolio Assets, the value attributed to the Non-License Portfolio Assets
for the purpose of this provision shall be $50,000,000 (the “Excluded Amount”). If
the Non-License Portfolio Assets are included as part of a sale of the License
Portfolio, the Excluded Amount shall be applied in its entirety if the License
Portfolio is transferred or assigned in one transaction; if more than one transaction is
required to transfer or assign of the entire License Portfolio, the Excluded Amount
shall be applied to the final transaction that completes the transfer or assignment of
the License Portfolio.
(n) “Rules” means the Commission’s regulations found in Title 47 of the Code of
Federal Regulations.
(o) “Straight Path” means Straight Path Communications Inc. and Straight Path
Spectrum, LLC, and their respective affiliates, subsidiaries, predecessors-in-interest,
and successors-in-interest.
(p) “Transactional Documents” means the complete set of documents created to support
a transaction or transactions that will effectuate the transfer of control or assignment
of the License Portfolio between Straight Path and one or more unrelated third-
parties.
II. BACKGROUND
3. The Commission has established construction and discontinuance requirements,
including the Licensing Rules, among other things, “to promote the productive use of spectrum, to
encourage licensees to provide service to customers in a timely manner, and to promote the provision of
innovative services.”4 Sections 101.175 and 101.1011 of the Rules state that all Local Multipoint
Distribution Service (LMDS) and 39 GHz band licensees must demonstrate “substantial service” by a
3 See 47 CFR §§ 1.17, 1.946, 1.955, 101.17, 101.63, 101.65, 101.305, 101.1011.
4 Spectrum Frontiers Order, 31 FCC Rcd at 8085, para. 191.
5 See supra, note 1, regarding 47 CFR §101.17.
Federal Communications Commission DA 17-40
3
showing to the Commission.6 Sections 1.946, 101.63 and other rules state that failure by any licensee to
meet this condition will result in termination of the license and the licensee will be ineligible to regain it.7
Sections 1.955, 101.65, and 101.305 of the Rules provide for automatic license termination for
discontinuance of service, such as where a licensee voluntarily removes facilities so as to render the
station not operational for a period of 30 days or more or discontinues operations for 12 continuous
months or more.8 Finally, Section 1.17 of the Rules requires that, no person subject to this rule shall “(1)
In any written or oral statement of fact, intentionally provide material factual information that is incorrect
or intentionally omit material information that is necessary to prevent any material factual statement that
is made from being incorrect or misleading”; and “(2) In any written statement of fact, provide material
factual information that is incorrect or omit material information that is necessary to prevent any material
factual statement that is made from being incorrect or misleading without a reasonable basis for believing
that any such material factual statement is correct and not misleading.”9
4. Straight Path Communications Inc. is a publicly-traded communications asset company
and the ultimate parent of Straight Path Spectrum, LLC, which holds radio licenses in bands identified for
the next generation wireless broadband deployment (5G). Straight Path Spectrum, LLC also holds several
licenses in other bands and services. Straight Path Spectrum, LLC’s radio licenses were assigned or
transferred to Straight Path Spectrum, LLC from IDT Spectrum LLC, IDT Capital, LLC, or Spectrum
Holdings Technologies, LLC in 2013 and 2014. In November 2015, an anonymous report alleged that the
“vast majority of Straight Path[’s] 39 GHz spectrum licenses’ [substantial service showings] were
obtained under fraudulent misrepresentation, because the systems were never built on the sites as
specified in the filings.”10 The report alleged that the substantial service filings identified systems as
“constructed” that were never actually built.11 Straight Path subsequently engaged the law firm of
Morgan, Lewis & Bockius LLP to conduct an independent investigation of the allegations in the
anonymous report (Morgan Lewis investigation). In response to the preliminary investigation of Morgan
Lewis following the investigation of a limited number of sites, Straight Path released a statement that “a
significant amount of the equipment that had been installed in connection with the substantial service
showings [was] no longer present at the original locations.”12 As part of the Morgan Lewis investigation,
Straight Path reported that “[i]nterviews and contemporaneous documents consistently confirm that
equipment was deployed at the original locations in connection with the substantial service applications,
but the investigators concluded, based on the weight of the evidence, that the equipment was likely put in
place for a short period of time at each location.”13 The Morgan Lewis investigation also determined that
“the investigators did not find any evidence that the equipment used in connection with the substantial
service applications is still present at the originally specified locations.”14 On September 20, 2016, the
6 Amendment of the Commission’s Rules Regarding the 37.0 - 38.6 GHz and 38.6 - 40 GHz Bands, Report and Order
and Second Notice of Proposed Rulemaking, 12 FCC Rcd 18600, 18623 para. 42 (1997) (performance requirements
intended to “ensure that service is indeed being provided to the public”)
7 47 CFR §§ 101.17, 101.63, 101.1011; see also 47 CFR §§ 1.946(c), 1.955(a)(2).
8 47 CFR §§ 1.955(a)(3), 101.65, 101.305.
9 47 CFR § 1.17(a).
10 Sinclair Upton Research, Straight Path Communications Inc. (STRP): How to Commit Fraud Against the FCC
And Get Away With It (Until Now) at 1 (Nov. 2015).
11 Id. at 3.
12 Straight Path Communications, Inc., United States Securities and Exchange Commission Form 8-K, Current
Report, Filed 12/01/15 for the Period Ending 11/25/15 at 2, (Dec. 1, 2015), available at
http://spathinc.com/investors.
13 Straight Path Communications, Inc., United States Securities and Exchange Commission Form 8-K, Current
Report, Filed 7/22/16 for the period ending 7/21/16 at 2 (July 22, 2016), available at http://spathinc.com/investors.
14 Straight Path Communications, Inc., 2016 Annual Report at 11 (2016), available at
http://spathinc.com/spci/downloads/reports/SPCI%202016%20Annual%20Report.pdf.
Federal Communications Commission DA 17-40
4
Enforcement Bureau issued an LOI to Straight Path to investigate the allegations made in the anonymous
report, Straight Path’s statements, and whether Straight Path violated the Licensing Rules. Straight Path
filed responses to the LOI on October 11, 2016 (October 11 LOI Response), October 20, 2016, and
November 7, 2016. In its October 11 LOI Response, Straight Path argued that the prior substantial
service filings made for the 39 GHz licenses held by Straight Path Spectrum, LLC had satisfied the
substantial service rules, that the Commission had accepted the filings, and that the 39 GHz licenses are
not subject to the discontinuance rules.
5. To settle this investigation, Straight Path has agreed (i) to pay a one hundred million
dollar ($100,000,000) Civil Penalty, with payment of fifteen million dollars ($15,000,000) due in
installments pursuant to the provisions of paragraph 14 and payment of the remaining eighty-five million
dollars ($85,000,000) based on the provisions of paragraphs 13 and 15; (ii) to submit to the Commission
applications for the cancellation of the licenses listed in Appendix B, (iii) to submit applications for the
transfer of control or assignment of the License Portfolio in an arm’s-length transaction(s) to one or more
entities; and (iv) to pay the United States Treasury twenty-percent (20%) of the Proceeds from the
transfer(s) of control or assignment(s) of the License Portfolio. In the event that Straight Path enters into
a transaction(s) for the transfer of control or assignment of the License Portfolio within twelve (12)
months of the Effective Date, eighty-five million dollars ($85,000,000) of the Civil Penalty shall not be
due. In the event that Straight Path does not enter into a transaction(s) for the transfer of control or
assignment of the License Portfolio within twelve (12) months of the Effective Date, Straight Path has the
option to submit to the Commission applications to cancel the License Portfolio in lieu of payment of the
eight-five million dollars ($85,000,000). Finally, Straight Path has agreed to assign, transfer, or
voluntarily submit applications for the cancellation of its Other Licenses.
III. TERMS OF AGREEMENT
6. Adopting Order. The provisions of this Consent Decree shall be incorporated by the
Bureau in an Adopting Order.
7. Jurisdiction. Straight Path 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.
8. 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.
9. 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, Straight Path agrees
to the terms, conditions, and procedures contained herein. The Bureau further agrees that, in the absence
of new material evidence or a violation by Straight Path of this Consent Decree, the Bureau 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 Straight Path concerning the matters that were the subject of the Investigation. The
Bureau also agrees that, in the absence of new material evidence or a violation by Straight Path of this
Consent Decree, the Bureau 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 Straight Path’s basic qualifications to be a Commission
licensee or hold Commission licenses or authorizations.15
10. Admission. Straight Path admits for the purpose of this Consent Decree and for
Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 9 herein,
the facts described in paragraph 4 herein.
15 See 47 CFR 1.93(b).
Federal Communications Commission DA 17-40
5
11. 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 Act16 against Straight Path 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 Straight Path with the
Communications Laws.
12. Relinquishment of Licenses. In consideration of the termination of the Investigation,
and in express reliance on the provisions of paragraph 9 herein, Straight Path will submit to the
Commission applications for the cancellation of the licenses listed by call sign in Appendix B on or
before January 18, 2017.
13. Civil Penalty. Straight Path will pay a Civil Penalty to the United States Treasury in the
amount of one hundred million dollars ($100,000,000). Of this amount, Straight Path shall pay the
amount of fifteen million dollars ($15,000,000) (Initial Civil Penalty) pursuant to the provisions of
paragraph 14. The remaining eighty-five million dollars ($85,000,000) (Non-Transfer Penalty) shall
become due if Straight Path fails to meet certain obligations as provided in paragraph 15. In the event
that Straight Path meets the obligations as provided in paragraph 15, the Non-Transfer Penalty shall not
be due.
14. Installment Payments. The Initial Civil Penalty payment shall be made in four (4)
installments (each, an Installment Payment). The first Installment Payment in the amount of four million
dollars ($4,000,000) shall be paid within thirty (30) calendar days of the Effective Date. The second
Installment Payment in the amount of four million dollars ($4,000,000) shall be paid within three (3)
months of the Effective Date. The third Installment Payment in the amount of three million five hundred
thousand dollars ($3,500,000) shall be paid within six (6) months of the Effective Date. The fourth and
final Installment Payment in the amount of three million five hundred thousand dollars ($3,500,000) shall
be paid within nine (9) months of the Effective Date. If the closing of the last transaction required by
paragraph 16 occurs prior to the due date of any Installment Payment, any remaining Installment
Payments will become due on the date of such closing, in addition to any amounts due to the Commission
specified in paragraph 16. Straight Path acknowledges and agrees that upon execution of this Consent
Decree, the Initial Civil Penalty and each Installment Payment shall become a “Claim” or “Debt” as
defined in Section 3701(b)(1) of the Debt Collection Improvement Act of 1996 (DCIA).17 Upon an Event
of Default (as defined below), all procedures for collection as permitted by law may, at the Commission’s
discretion, be initiated.
15. Non-Transfer Penalty. In the event that Straight Path fails to submit to the
Commission, in a form acceptable for filing, within twelve (12) months of the Effective Date, one or more
applications for the transfer of control or assignment of the entirety of the License Portfolio in arm’s-
length transaction(s) to one or more entities qualified to hold licenses under the Communications Act as
specified in paragraph 16, Straight Path, shall on the next business day following that deadline, either (i)
pay to the United States Treasury the Non-Transfer Penalty or (ii) submit to the Commission applications
for the cancellation of the License Portfolio not already transferred or assigned or subject to a pending
transfer of control or assignment application. The payment of the Non-Transfer Penalty will be in
addition to the Initial Civil Penalty identified in paragraph 13. Straight Path acknowledges and agrees
that in the event that it fails to satisfy the provisions of this paragraph, the Commission may, at its own
discretion, take administrative action to declare the licenses in the License Portfolio cancelled. Straight
Path further waives any and all rights to object or to seek review of such administrative action (other than
to attempt to demonstrate that it did comply with the provisions of this paragraph). In the event that
Straight Path submits to the Commission, in a form acceptable for filing, within twelve (12) months of the
16 47 U.S.C. § 208.
17 Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996) (DCIA).
Federal Communications Commission DA 17-40
6
Effective Date, one or more applications for the transfer of control or assignment of the entirety of the
License Portfolio in arm’s-length transaction(s) to one or more entities qualified to hold licenses under the
Communications Act as specified in paragraph 16, the Non-Transfer Penalty shall not be due.
16. Transfer or Assignment of the License Portfolio. In consideration of the termination
of the Investigation, and in express reliance on the provisions of paragraph 9 herein, Straight Path agrees
to submit applications for the transfer of control or assignment of the entirety of the License Portfolio for
an arm’s-length transaction(s) to one or more entities qualified to hold licenses under the
Communications Act.18 Straight Path further agrees to pay the United States Treasury an Additional Civil
Penalty equal to twenty percent (20%) of the Proceeds from the transfer(s) or assignment(s) of the
License Portfolio (Additional Civil Penalty); such payment(s) to be in the form specified in paragraph 18
below. For purposes of submitting payment to the United States Treasury, the amounts due from any
transaction(s) for the transfer of control or assignment of the License Portfolio will be due upon closing
the transaction, or each transaction individually if there are multiple transactions. For purposes of
determining the amount(s) of the Additional Civil Penalty, Straight Path agrees to provide to the
Commission personnel identified in Appendix D, electronic copies of the applications submitted to the
Commission and the Transactional Documents prior to or contemporaneous with the filing of the
application(s) for the transfer of control or the assignment of the License Portfolio. In providing the
Transactional Documents to the Commission, Straight Path will also provide any documents associated
with any additional transfer of control, assignment, or similar transaction relating to all or part of the
License Portfolio. Straight Path agrees and acknowledges that the Commission may condition regulatory
approval (including of the consummation) of any transaction involving the License Portfolio to the
payment of the amounts due to the United States Treasury. The payment of the Additional Civil Penalty
under this paragraph remains due upon the closing of any transaction(s) for the transfer or assignment of
the License Portfolio, even in the event that payment of the Non-Transfer Penalty under paragraph 15 is
triggered.
17. Enforcement of Part 101 Discontinuance of Service Rules. The Bureau agrees not to
pursue an investigation of Straight Path for a violation of the discontinuance of service provisions
contained in Sections 101.65 or 101.305 of the Rules regarding the License Portfolio for the period of
time between the Effective Date and earliest of: (i) the closing date of the last transaction(s) to transfer or
assigns the License Portfolio as specified in paragraph 16; (ii) the occurrence of an Event of Default as
specified in paragraph 19; (iii) or twelve (12) months from the Effective Date, unless applications are
pending with the Commission to transfer or assign the entirety of the License Portfolio as specified in
paragraph 16.
18. Payments. Straight Path shall send electronic notification of each payment required by
paragraphs 13, 14, 15, and 16 to Ricardo Durham at Ricardo.Durham@fcc.gov, Maureen McCarthy at
Maureen.McCarthy@fcc.gov, and Samantha Peoples at Sam.Peoples@fcc.gov on the date said payment
is made. The payments must be made by wire transfer and must include the Account Number and FRN
referenced above. A completed FCC Form 159 (Remittance Advice) must be submitted.19 When
completing the FCC Form 159, enter the Account Number in block number 23A (call sign/other ID) and
18 A transaction with a Straight Path predecessor-in-interest will not be considered an arm’s-length transaction for
purposes of paragraph 16. Nor will a transaction with an entity be considered an arm’s-length transaction if any of
the entities’ attributable owners has at any time been an attributable owner of Straight Path as defined in this
Consent Decree. For purposes of this Consent Decree, attributable owners include any officer, director, present or
former holder of any equity or voting interest of greater than 5%, any spouse or immediate family member of any of
the foregoing, or any “affiliate” within the meaning of 47 CFR § 1.2110(c)(5). Straight Path further agrees that
neither Straight Path nor any of its attributable owners shall enter into any new spectrum lease or other agreement
after the Effective Date with any party with respect to any of the licenses in the License Portfolio, until such time as
Straight Path’s obligations under paragraphs 12, 13, 14, 15, and 16 are satisfied.
19 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 17-40
7
enter the letters “FORF” in block number 24A (payment type code). Below are additional instructions
that should be followed:
? 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.
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.
19. Events of Default. Straight Path agrees that an Event of Default shall occur upon: (i) the
failure to pay the Initial Civil Penalty or any Installment Payments to the United States Treasury on or
before the dates specified in paragraphs 13 and 14; (ii) the failure of Straight Path to submit applications
for the cancellation of the licenses in Appendix B as specified in paragraph 12; or (iii) the failure to pay
the Additional Civil Penalty upon closing of the transaction(s) transferring or assigning the License
Portfolio as specified in paragraph 16; or (iv) the failure to satisfy the Non-Transfer Penalty (if
applicable) as specified in paragraph 15. An Event of Default constitutes a violation of the Consent
Decree.
20. Other Licenses. Straight Path will submit to the Commission applications for the
transfer, assignment, or cancellation of the Other Licenses as of twelve (12) months of the Effective Date
in the event that the Other Licenses are not part of any transaction(s) to transfer or assign the License
Portfolio as specified in paragraph 16 and have not otherwise been transferred within twelve (12) months
of the Effective Date.
21. Interest, Charges for Collection, and Acceleration of Maturity Date. After an Event
of Default has occurred under this Consent Decree, in addition to any other remedies under this Consent
Decree, the then unpaid amount of the civil penalties for the specific Event of Default (specified in
paragraphs 13, 15 and 16 (monetary penalty only)) shall accrue interest, computed using the U.S. Prime
Rate in effect on the date of the Event of Default plus 4.75 percent, from the date of the Event of Default
until payment in full. Upon an Event of Default, the then unpaid amount of any of the penalties, together
with interest, any penalties permitted and/or required by the law, including but not limited to 31 U.S.C. §
3717 and administrative charges, plus the costs of collection, litigation, and attorneys’ fees, shall become
immediately due and payable, without notice, presentment, demand, protest, or notice of protest of any
kind, all of which are waived by Straight Path.
22. Cooperation with Rebanding. In the event that the Commission announces a filing
window for the transition to the new channel plan in the 39 GHz band, Straight Path agrees to promptly
cooperate with the Commission and other 39 GHz band licensees to select frequencies and file
applications to convert the 39 GHz band Economic Area licenses it holds at that time to the new channel
plan outlined in Section 30.4(b)(2) of the Rules.20
23. Status Reports. Straight Path shall file status reports with the Commission upon
meeting certain milestones required by this Consent Decree and in connection with the transfer or
assignment of the License Portfolio as specified in paragraph 16. All status reports shall be accompanied
by a certification from an officer of Straight Path that complies with Section 1.16 of the Rules and be
subscribed to as true under penalty of perjury in substantially the form set forth therein.21 All status
reports shall be submitted electronically to Chief, Spectrum Enforcement Division, Enforcement
Bureau, Federal Communications Commission, 445 12th Street, SW, Rm. 4C-224, Washington, DC
20554, with a copy submitted electronically to Ricardo Durham at Ricardo.Durham@fcc.gov and
20 47 CFR § 30.4(b)(2).
21 47 CFR § 1.16.
Federal Communications Commission DA 17-40
8
Maureen McCarthy at Maureen.McCarthy@fcc.gov. Specifically Straight Path shall notify the
Commission when:
(a) Straight Path submits to the Commission applications to cancel the licenses
identified in Appendix B as specified in paragraph 12.
(b) Straight Path engages an investment bank in connection with the transfer of control
or assignment of the License Portfolio.
(c) Straight Path’s Board of Directors votes to transfer control of the company or assign
its assets as soon as such information is made public.
(d) Straight Path files good faith applications with the Commission for regulatory
approval for the transfer of control or assignment of the License Portfolio.
(e) Straight Path executes closing documents for arm’s-length transaction(s) with third-
parties to whom Straight Path transfers control of or assigns the License Portfolio.
(f) Straight Path will satisfy the provisions of paragraph 15 by either the payment of the
Non-Transfer Penalty or the filing of applications for the cancelation of the License
Portfolio, by at least two weeks prior to the last day of the twelfth month from
Effective Date.
24. Waivers. As of the Effective Date, Straight Path 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. Straight Path 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 Straight Path nor the Commission shall contest the
validity of the Consent Decree or the Adopting Order, and Straight Path shall waive any statutory right to
a trial de novo. Straight Path hereby agrees to waive any claims it may otherwise have under the Equal
Access to Justice Act22 relating to the matters addressed in this Consent Decree.
25. Governing Law and Venue. Without regard to principles of conflicts of laws, the
validity, interpretation, performance and enforcement of this Consent Decree shall be governed by and
construed in accordance with the federal law of the United States of America. Any legal action or
proceeding relating to this Consent Decree shall only be brought in the United States District Court for
the District of Columbia, and, by execution and delivery of this Consent Decree Straight Path hereby
accepts for itself and in respect of its property generally and unconditionally, the jurisdiction of the
aforesaid court. Straight Path hereby irrevocably waives any objection, including, without limitation, any
objection to the laying of venue or based on the grounds of forum non conveniens, which Straight Path
may now or hereafter have to the bringing of any such action or proceeding in the District of Columbia.
Notwithstanding the foregoing, the Commission shall have the right to bring any action or proceeding
against Straight Path in the Courts of any other jurisdiction which the Commission deems necessary or
appropriate in order to enforce the Commission’s rights against Straight Path.
26. 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.
27. 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.
22 See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530.
Federal Communications Commission DA 17-40
9
28. 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 Straight Path does not expressly
consent) that provision will be superseded by such Rule or Order.
29. Successors and Assigns. Straight Path agrees that the provisions of this Consent Decree
shall be binding upon and inure to the benefit of Straight Path and its successors, assigns, and transferees.
30. Final Settlement. The Parties agree and acknowledge that this Consent Decree shall
constitute a final settlement between the Parties with respect to the Investigation.
31. Modifications. This Consent Decree cannot be modified without the advance written
consent of both Parties.
32. 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.
33. Authorized Representative. Each Party represents and warrants to the other that it has
full power and authority to enter into this Consent Decree and to effectuate its terms and conditions. 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.
34. 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
________________________________
Date
________________________________
Davidi Jonas
President and CEO
Straight Path Communications Inc.
________________________________
Date
________________________________
Davidi Jonas
Straight Path Spectrum, LLC
________________________________
Date
Federal Communications Commission DA 17-40
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APPENDIX A
License Portfolio
WPOH623 WPOH624 WPOH625 WPOH626 WPOH627 WPOH628 WPOH629
WPOH630 WPOH631 WPOH632 WPOH633 WPOH634 WPOH635 WPOH636
WPOH692 WPOH693 WPOH695 WPOH696 WPOH697 WPOH698 WPOH701
WPOH702 WPOH706 WPOH708 WPOH711 WPOH728 WPOH729 WPOH730
WPOH731 WPOH732 WPOH733 WPOH734 WPOH736 WPOH737 WPOH738
WPOH739 WPOH740 WPOH741 WPOH744 WPOH745 WPOH748 WPOH749
WPOH750 WPOH751 WPOH752 WPOH756 WPOH757 WPOH758 WPOH762
WPOH763 WPOH765 WPOH768 WPOH769 WPOH770 WPOH774 WPOH777
WPOH778 WPOH781 WPOH782 WPOH783 WPOH784 WPOH785 WPOH786
WPOH787 WPOH789 WPOH790 WPOH797 WPOH799 WPOH800 WPOH801
WPOH802 WPOH803 WPOH804 WPOH805 WPOH806 WPOH812 WPOH813
WPOH814 WPOH815 WPOH816 WPOH818 WPOH820 WPOH822 WPOH823
WPOH825 WPOH839 WPOH843 WPOH847 WPOH848 WPOH851 WPOH853
WPOH854 WPOH855 WPOH857 WPOH858 WPOH860 WPOH862 WPOH863
WPOH864 WPOH865 WPOH866 WPOH869 WPOH871 WPOH872 WPOH873
WPOH875 WPOH877 WPOH878 WPOH880 WPOH883 WPOH884 WPOH885
WPOH887 WPOH889 WPOH896 WPOH898 WPOH901 WPOH902 WPOH903
WPOH904 WPOH905 WPOH908 WPOH909 WPOH911 WPOH912 WPOH913
WPOH914 WPOH915 WPOH916 WPOH917 WPOH918 WPOH921 WPOI485
WPQT972 WPQT973 WPQT974 WPQT975 WPQT976 WPQT978 WPQT979
WPQT980 WPQT981 WPQT982 WPQT983 WPQT984 WPQT985 WPQT986
WPQT989 WPQT990 WPQT991 WPQT993 WPQT999 WPQU200 WPQU201
WPQU203 WPQU204 WPQU208 WPQU210 WPQU211 WPQU212 WPQU213
WPQU215 WPQU216 WPQU218 WPQU221 WPQU222 WPQU223 WPQU225
WPQU226 WPQU227 WPQU230 WPQU231 WPQU232 WPQU233 WPQU235
WPQU236 WPQU238 WPQU239 WPQU240 WPQU241 WPQU242 WPQU243
WPQU244 WPQU245 WPQU246 WPQU247 WPQU250 WPQU251 WPQU252
WPQU253 WPQU254 WPQU257 WPQU261 WPQU265 WPQU266 WPQU267
WPQU268 WPQU273 WPQU274 WPQU277 WPQU280 WPQU284 WPQU285
WPQU286 WPQU287 WPQU288 WPQU290 WPQU293 WPQU294 WPQU295
WPQU297 WPQU298 WPQU299 WPQU301 WPQU302 WPQU303 WPQU304
WPQU305 WPQU306 WPQU307 WPQU308 WPQU309 WPQU310 WPQU311
WPQU312 WPQU313 WPQU315 WPQU318 WPQU319 WPQU320 WPQU321
WPQU322 WPQU323 WPQU324 WPQU325 WPQU327 WPQU328 WPQU329
WPQU331 WPQU333 WPQU335 WPQU336 WPQU337 WPQU340 WPQU341
WPQU349 WPQU350 WPQU351 WPQU352 WPQU353 WPQU359 WPQU360
WPQU362 WPQU363 WPQU364 WPQU365 WPQU366 WPQU367 WPQU368
WPQU369 WPQU370 WPQU371 WPQU373 WPQU374 WPQU375 WPQU376
WPQU377 WPQU378 WPQU380 WPQU381 WPQU383 WPQU384 WPQU387
WPQU389 WPQU390 WPQU391 WPQU392 WPQU393 WPQU396 WPQU397
WPQU398 WPQU399 WPQU403 WPQU404 WPQU405 WPQU406 WPQU408
WPQU416 WPQU418 WPQU420 WPQU421 WPQU422 WPQU423 WPQU424
WPQU427 WPQU428 WPQU429 WPQU433 WPQU434 WPQU435 WPQU436
WPQU437 WPQU438 WPQU439 WPQU440 WPQU441 WPQU444 WPQU445
WPQU446 WPQU447 WPQU450 WPQU451 WPQU452 WPQU453 WPQU455
WPQU457 WPQU458 WPQU459 WPQU460 WPQU466 WPQU469 WPQU470
WPQU471 WPQU473 WPQU478 WPQU480 WPQU481 WPQU482 WPQU484
WPQU485 WPQU486 WPQU491 WPQU492 WPQU493 WPQU494 WPQU495
WPQU496 WPQU499 WPQU500 WPQU503 WPQU504 WPQU505 WPQU506
Federal Communications Commission DA 17-40
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WPQU507 WPQU508 WPQU509 WPQU510 WPQU511 WPQU512 WPQU513
WPQU514 WPQU516 WPQU517 WPQU518 WPQU519 WPQU520 WPQU521
WPQU523 WPQU524 WPQU525 WPQU526 WPQU527 WPQU532 WPQU533
WPQU538 WPQU540 WPQU546 WPQU548 WPQU550 WPQU551 WPQU552
WPQU553 WPQU554 WPQU555 WPQU556 WPQU557 WPQU558 WPQU559
WPQU560 WPQU561 WPQU563 WPQU565 WPQU566 WPQU568 WPQU570
WPQU571 WPQU572 WPQU573 WPQU574 WPQU575 WPQU579 WPQU580
WPQU581 WPQU582 WPQU584 WPQU585 WPQU589 WPQU591 WPQU592
WPQU593 WPQU594 WPQU595 WPQU597 WPQU603 WPQU604 WPQU605
WPQU606 WPQU607 WPQU610 WPQU611 WPQU614 WPQU616 WPQU618
WPQU619 WPQU620 WPQU621 WPQU622 WPQU623 WPQU624 WPQU625
WPQU627 WPQU628 WPQU630 WPQU631 WPQU632 WPQU633 WPQU634
WPQU636 WPQU638 WPQU640 WPQU641 WPQU642 WPQU643 WPQU644
WPQU647 WPQU659 WPQU660 WPQU662 WPQU663 WPQU667 WPQU669
WPQU671 WPQU672 WPQU673 WPQU674 WPQU676 WPQU677 WPQU678
WPQU679 WPQU680 WPQU683 WPQU684 WPQU685 WPQU686 WPQU689
WPQU691 WPQU692 WPQU695 WPQU696 WPQU697 WPQU699 WPQU700
WPQU701 WPQU702 WPQU703 WPQU704 WPQU705 WPQU707 WPQU708
WPQU709 WPQU710 WPQU711 WPQU713 WPQU714 WPQU715 WPQU717
WPQU718 WPQU719 WPQU720 WPQU721 WPQU723 WPQU727 WPQU729
WPQU731 WPQU732 WPQU735 WPQU737 WPQU738 WPQU739 WPQU741
WPQU744 WPQU745 WPQU746 WPQU747 WPQU749 WPQU750 WPQU751
WPQU752 WPQU753 WPQU754 WPQU755 WPQU757 WPQU758 WPQU759
WPQU760 WPQU761 WPQU763 WPQU767 WPQU768 WPQU769 WPQU771
WPQU772 WPQU773 WPQU774 WPQU775 WPQU776 WPQU777 WPQU778
WPQU786 WPQU787 WPQU793 WPQU794 WPQU795 WPQU798 WPQU801
WPQU802 WPQU803 WPQU804 WPQU810 WPQU811 WPQU812 WPQU814
WPQU815 WPQU816 WPQU818 WPQU819 WPQU820 WPQU822 WPQU823
WPQU824 WPQU825 WPQU829 WPQU831 WPQU835 WPQU836 WPQU838
WPQU844 WPQU845 WPQU846 WPQU847 WPQU848 WPQU849 WPQU850
WPQU851 WPQU855 WPQU856 WPQU857 WPQU860 WPQU861 WPQU865
WPQU868 WPQU870 WPQU871 WPQU872 WPQU874 WPQU875 WPQU878
WPQU879 WPQU881 WPQU883 WPQU885 WPQU887 WPQU893 WPQU894
WPQU895 WPQU896 WPQU898 WPQU900 WPQU902 WPQU903 WPQU904
WPQU906 WPQU908 WPQU909 WPQU910 WPQU912 WPQU914 WPQU917
WPQU920 WPQU922 WPQU923 WPQU925 WPQU927 WPQU929 WPQU931
WPQU932 WPQU933 WPQU934 WPQU940 WPQU941 WPQU943 WPQU944
WPQU945 WPQU946 WPQU947 WPQU948 WPQU949 WPQU953 WPQU954
WPQU956 WPQU957 WPQU958 WPQU959 WPQU964 WPQU965 WPQU966
WPQU967 WPQU969 WPQU970 WPQU971 WPQU974 WPQU975 WPQU977
WPQU978 WPQU979 WPQU980 WPQU982 WPQU984 WPQU985 WPQU987
WPQU989 WPQU991 WPQU992 WPQU994 WPQU995 WPQU999 WPQV200
WPQV201 WPQV203 WPQV205 WPQV207 WPQV208 WPQV209 WPQV210
WPQV211 WPQV212 WPQV214 WPQV216 WPQV217 WPQV219 WPQV222
WPQV223 WPQV227 WPQV229 WPQV231 WPQV232 WPQV233 WPQV241
WPQV242 WPQV244 WPQV246 WPQV247 WPQV248 WPQV250 WPQV251
WPQV252 WPQV254 WPQV256 WPQV257 WPQV259 WPQV262 WPQV265
WPQV267 WPQV269 WPQV270 WPQV271 WPQV273 WPQV274 WPQV276
WPQV277 WPQV279 WPQV282 WPQV283 WPQV284 WPQV286 WPQV287
WPQV288 WPQV289 WPQV290 WPQV292 WPQV293 WPQV295 WPQV296
WPQV297 WPQV298 WPQV312 WPQV313 WPQV314 WPQV315 WPQV316
WPQV317 WPQV319 WPQV320 WPQV321 WPQV322 WPQV323 WPQV324
WPQV325 WPQV326 WPQV327 WPQV328 WPQV329 WPQV330 WPQV331
Federal Communications Commission DA 17-40
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WPQV332 WPQV333 WPQV334 WPQV336 WPQV337 WPQV338 WPQV339
WPQV340 WPQV341 WPQV342 WPQV343 WPQV344 WPQV345 WPQV346
WPQV347 WPQV348 WPQV349 WPQV350 WPQV351 WPQV352 WPQV353
WPQV354 WPQV355 WPQV356 WPQV357 WPQV358 WPQV359 WPQV360
WPQV361 WPQV362 WPQV363 WPQV364 WPQV365 WPQV366 WPQV367
WPQV368 WPQV369 WPQV370 WPQV371 WPQV372 WPQV373 WPQV374
WPQV375 WPQV376 WPQV377 WPQV378 WPQV379 WPQV380 WPQV381
WPQV382 WPQV383 WPQV384 WPQV385 WPQV386 WPQV387 WPQV388
WPQV389 WPQV390 WPQV391 WPQV392 WPQV393 WPQV394 WPQV395
WPQV396 WPQV397 WPQV398 WPQV399 WPQV400 WPQV401 WPQV402
WPQV403 WPQV404 WPQV405 WPQV406 WPQV407 WPQV408 WPQV409
WPQV410 WPQV412 WPQV413 WPQV414 WPQV416 WPQV417 WPQV418
WPQV419 WPQV420 WPQV421 WPQV422 WPQV423 WPQV424 WPQV425
WPQV426 WPQV427 WPQV428 WPQV430 WPQV431 WPQV433 WPQV435
WPQV436 WPQV437 WPQV438 WPQV439 WPQV440 WPQV441 WPQV442
WPQV443 WPQV444 WPQV445 WPQV447 WPQV448 WPQV449 WPQV450
WPQV451 WPQV452 WPQV453 WPQV454 WPQV455 WPQV456 WPQV457
WPQV458 WPQV460 WPQV461 WPQV464 WPQV465 WPQV467 WPQV470
WPQV471 WPQV473 WPQV479 WPQV480 WPQV481 WPQV484 WPQV485
WPQV487 WPQV500 WPQV501 WPQV502 WPQV503 WPQV504 WPQV505
WPQV506 WPQV507 WPQV508 WPQV509 WPQV510 WPQV511 WPQV512
WPQV513 WPQV514 WPQV516 WPQV517 WPQV518 WPQV519 WPQV521
Federal Communications Commission DA 17-40
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APPENDIX B
Licenses to be Initially Cancelled
WMN321 WMN327 WMN331 WMN337 WMN339 WMT817 WMW862
WNPG365 WNPG374 WPNA368 WPNA369 WPNA372 WPNA388 WPNA436
WPNA520 WPNA663 WPNA672 WPNA673 WPNA676 WPNC464 WPNC471
WPND496 WPND497 WPND514 WPND515 WPND516 WPND517 WPND518
WPND614 WPND619 WPND620 WPND621 WPND622 WPND623 WPND624
WPND761 WPND762 WPND764 WPND768 WPND769 WPND825 WPND830
WPND837 WPNE214 WPNE226 WPNE229 WPNE234 WPNE363 WPNE398
WPNE399 WPNE400 WPNE401 WPNE686 WPNE687 WPNE688 WPNE735
WPNE742 WPNE756 WPNE759 WPNE961 WPNE963 WPNE964 WPNE989
WPNE993 WPNE994 WPNF243 WPNF258 WPNG286 WPNG289 WPNG291
WPNG293 WPNG309 WPNG360 WPNG361 WPNG362 WPNG363 WPNG364
WPNG368 WPNG369 WPNG375 WPNG377 WPNG378 WPNG379 WPNG382
WPNG384 WPNG390 WPNG400 WPNG951 WPNH422 WPNH554 WPNH842
WPNI214 WPNI216 WPNI252 WPNI271 WPNI835 WPNI838 WPNL601
WPNL602 WPNL613 WPNL623 WPNN812 WPOP581 WPQU316 WPQU432
WPQU544 WPQU608 WPQU629 WPQU639 WPQU675 WPQU687 WPQU690
WPQU694 WPQU730 WPQU743 WPQU762 WPQU764 WPQU781 WPQU784
WPQU790 WPQU800 WPQU808 WPQU813 WPQU817 WPQU826 WPQU827
WPQU830 WPQU833 WPQU837 WPQU842 WPQU843 WPQU854 WPQU859
WPQU877 WPQU884 WPQU886 WPQU888 WPQU891 WPQU892 WPQU897
WPQU899 WPQU901 WPQU913 WPQU915 WPQU916 WPQU921 WPQU924
WPQU937 WPQU939 WPQU942 WPQU960 WPQU968 WPQU976 WPQU983
WPQV202 WPQV213 WPQV224 WPQV225 WPQV226 WPQV234 WPQV239
WPQV243 WPQV261 WPQV263 WPQV268 WPQV280 WPQV281 WPQV294
WPQV301 WPQV302 WPQV318 WPQV335 WPQV411 WPQV415 WPQV429
WPQV432 WPQV434 WPQV446 WPQV459 WPQV462 WPQV463 WPQV466
WPQV468 WPQV469 WPQV472 WPQV474 WPQV475 WPQV476 WPQV477
WPQV478 WPQV482 WPQV483 WPQV486 WPQV488 WPQV515 WPQV520
Federal Communications Commission DA 17-40
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APPENDIX C
Other Licenses
WPOT926
WPOT927
WPOU743
WPQL595
WPQL602
WQKJ217
WQKJ219
WQKJ220
WQKK420
WQJF531
Federal Communications Commission DA 17-40
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APPENDIX D
Wireless Telecommunications Bureau:
Enforcement Bureau:
Suzanne Tetreault
Suzanne.Tetreault@fcc.gov
Aspasia Paroutsas
Aspasia.Paroutsas@fcc.gov
Blaise Scinto
Blaise.Scinto@fcc.gov
Ricardo Durham
Ricardo.Durham@fcc.gov
Linda Ray
Linda.Ray@fcc.gov
Maureen McCarthy
Maureen.McCarthy@fcc.gov
Elizabeth Fishel
Elizabeth.Fishel@fcc.gov
Ruth Taylor
Ruth.Taylor@fcc.gov
John Schauble
John.Schauble@fcc.gov