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Federal Communications Commission DA 17-583
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Conroy Dawson
Paterson, New Jersey
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)
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File No. EB-FIELDNER-16-00022155
NAL/Acct. No.: 201732380001
FRN: 0026151753
FORFEITURE ORDER
Adopted:  June 19, 2017 Released: June 19, 2017
By the Regional Director, Region One, Enforcement Bureau:
I. INTRODUCTION
1. We impose a penalty of $25,000 against Conroy Dawson for operating an FM broadcast 
station on 97.5 MHz in Paterson, New Jersey, without a license or other authorization issued by the 
Commission, in violation of Section 301 of the Communications Act of 1934, as amended (Act).
1
  The 
Enforcement Bureau (Bureau) previously proposed a $25,000 penalty against Mr. Dawson for his 
apparent operation of this unlicensed station.
2
  After reviewing Mr. Dawson’s response to the NAL, we 
find no reason to cancel, withdraw, or reduce the proposed penalty, and we therefore assess the $25,000 
forfeiture the Bureau previously proposed.
3
II. BACKGROUND
2. In May 2016, agents from the New York Field Office (New York Office) investigated an 
unauthorized FM broadcast station operating on 97.5 MHz in Paterson, New Jersey and identifying itself 
over the air as “WBLR – Big Link Radio 97.5 FM.”
4
  Using direction-finding techniques, agents traced 
the source of the transmissions to a residential apartment occupied by Conroy Dawson and a relative of 
Mr. Dawson (First Site).  The New York Office then issued a Notice of Unlicensed Operation to Mr. 
Dawson to notify him that the operation of the station located in his residence was illegal and to warn him 
that continued operation of the station could result in enforcement actions.
5
Following receipt of the 
NOUO, Mr. Dawson contacted the New York Office by telephone, claimed to have sought a license from 
the Commission to operate the station, and agreed to remove the transmission equipment.
6
   
                                                     
1
47 U.S.C. § 301.
2
Conroy Dawson, Paterson, New Jersey, Notice of Apparent Liability for Forfeiture, 32 FCC Rcd 107 (EB 2017) 
(NAL).
3
Conroy Dawson, Response to Notice of Apparent Liability for Forfeiture (Feb. 10, 2017) (on file in EB-
FIELDNER-16-00022155) (NAL Response).    
4
NAL, 32 FCC Rcd at 108, para. 3.  The NAL includes a more complete discussion of the facts and history of this 
case and is incorporated herein by reference.
5
See Conroy Dawson, Notice of Unlicensed Operation (New York Office, EB, May 23, 2016) (on file in EB-
FIELDNER-16-00022155) (NOUO).
6
See NAL, 32 FCC Rcd at 108-09, para. 4.
Federal Communications Commission DA 17-583
2
3. Two months later, the Commission received another complaint that a pirate station was 
once again operating on 97.5 MHz in Paterson, New Jersey.  Upon investigating that complaint, agents 
from the New York Office determined that the station was operating from a new location (Second Site).
7
  
The agents recorded the station’s audio stream, during which the station publicized a call-in number that 
agents linked to Mr. Dawson, identified itself as “Big Link Radio,” and provided the station’s operating 
frequency: “97.5.” The agents posted a warning on the door of the Second Site.
8
  The following month, in 
August 2016, agents again investigated a pirate station operating on 97.5 MHz and determined that it had 
moved to yet another location (Third Site).
9
  Once again, the station continued to identify itself on the air 
as “Big Link Radio.”
10
  
4. On January 12, 2017, the Enforcement Bureau (Bureau) issued the NAL proposing a 
$25,000 forfeiture against Mr. Dawson for his apparent willful and repeated violation of Section 301 of
the Act by operating an FM broadcast station without the requisite license or other authorization issued by 
the Commission.  On February 10, 2017, Mr. Dawson filed a response to the NAL.  In the NAL Response, 
Mr. Dawson argues that the NAL should be cancelled or reduced. Specifically, Mr. Dawson asserts that, 
although he operates an internet-based streaming radio station, his operation does not have a broadcast 
component and, as a result, he is the victim of pirate broadcasts rather than the perpetrator.
11
  
III. DISCUSSION
5. The Bureau proposed a forfeiture in this case in accordance with Section 503(b) of the 
Act,
12
Section 1.80 of the Commission’s rules (Rules),
13
and the Commission’s Forfeiture Policy 
Statement.
14
  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.”
15
  
As discussed below, we have fully considered Mr. Dawson’s response to the NAL, but we do not find his 
arguments persuasive.  We therefore affirm the $25,000 forfeiture proposed in the NAL. 
A. Mr. Dawson has Violated Section 301 of the Communications Act  
6. 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.
16
  The record in this proceeding demonstrates that Mr. Dawson operated such 
an apparatus without a license granted by the Commission.
7. As set forth in greater detail in the NAL, in May 2016, agents from the New York Office 
used a series of technical measurements and witness interviews to identify Mr. Dawson as the operator of 
the pirate station operating on 97.5 MHz in Paterson, New Jersey, and branding itself as “Big Link 
                                                     
7
NAL, 32 FCC Rcd at 109, para. 5.
8
Id.
9
Id., para. 7.
10
Id.
11
NAL Response at 1, 4. 
12
47 U.S.C. § 503(b).
13
47 CFR § 1.80.
14
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).
15
47 U.S.C. § 503(b)(2)(E).
16
47 U.S.C. § 301.
Federal Communications Commission DA 17-583
3
Radio.”
17
  Agents recorded the station’s over-the-air broadcasts on 97.5 MHz and observed that the 
station was identified as “WBLR – Big Link Radio, 97.5 MHz.”
18
  Upon determining that the station was 
broadcasting from the First Site, agents traced the coaxial cable from the transmission antenna to a 
specific apartment within the building and then interviewed witnesses, who stated that Mr. Dawson 
operated a radio station from the apartment in question, which Mr. Dawson occupied with a relative.
19
  
Agents also received confirmation from the building owner that Mr. Dawson was operating a radio station 
at the First Site.
20
  
8. When operations at the First Site ceased and then moved to the Second Site and, later, the 
Third Site, agents confirmed that they were observing the same pirate station using three pieces of 
evidence: (a) the continued use of 97.5 MHz as the station’s operating frequency,
21
(b) the continued use 
of the “WBLR - Big Link Radio” branding during station identification breaks,
22
and (c) the continued 
use of the same studio call-in telephone number that the agents observed being broadcast at the First 
Site.
23
  Therefore, we find that Mr. Dawson was continuing to operate the station in violation of Section 
301 at the Second and Third Sites as well. 
B. Mr. Dawson Does Not Provide a Sufficient Basis for Canceling the Forfeiture 
Amount
9. Mr. Dawson, however, maintains that the forfeiture amount proposed in the NAL is not 
warranted.  First, he claims that he was not the operator of the station transmitting on 97.5 MHz in 
Paterson, New Jersey, and states in the NAL Response that he “only did the Internet” and did not “place 
any antenna on any site.”
24
  Mr. Dawson further asserts that he has “no connection, location or agreement 
with anyone to rebroadcast our Internet feed,”
25
and that he has tried to convince unnamed third-parties 
who allegedly broadcast Big Link Radio to refrain from doing so.
26
  
10. We are not persuaded by Mr. Dawson’s argument that he is not the operator of the illegal 
FM broadcast station on 97.5 MHz in Paterson, New Jersey.  First, Mr. Dawson admits to being the 
operator of an internet-based streaming radio station that operates under the branding of “Big Link Radio” 
or “WBLR.”
27
  Second, Mr. Dawson does not contest our finding in the NAL that the station 
identifications recorded by agents included a reference to the station’s operating frequency of 97.5 MHz.
28
  
Third, and finally, the station’s website includes a programming advertisement that references the fact 
that it is broadcast on 97.5 MHz.
29
  If Mr. Dawson were truly unaware that Big Link Radio was being 
broadcast on 97.5 MHz, we would not have found references to an operating frequency in Big Link 
Radio’s periodic station identifications or in promotional materials on its own website.
                                                     
17
NAL, 32 FCC Rcd at 108, para. 3.
18
Id.
19
Id.
20
Id.
21
NAL, 32 FCC Rcd at 109, paras. 5, 7.
22
Id.
23
Id., 32 FCC Rcd at 109, para. 5.
24
NAL Response at 1.
25
Id. at 2. 
26
Id.
27
NAL, 32 FCC Rcd at 107-09, paras. 2-3, 5-7.
28
NAL, 32 FCC Rcd at 108, para 3.
29
SeeWBLR Radio, Gallery, http://www.wblrradio.net/gallery, (last visited May 4, 2017). 
Federal Communications Commission DA 17-583
4
11. In the NAL Response, Mr. Dawson faults the New York Office for failing to reach out to 
him directly before issuing the NAL.
30
  Such an assertion is at odds with the facts of this case and further 
undermines Mr. Dawson’s credibility.  As noted in the NAL, on June 1, 2016, an agent from the New 
York Office spoke with Mr. Dawson by phone, issued a verbal warning, and explained the consequences 
of continuing to operate an illegal FM broadcast station.
31
  During this conversation, Mr. Dawson claimed 
to have previously applied for a license from the Commission (for which no record exists) and indicated 
to the agents that he was going to remove the radio equipment from his apartment.
32
12. Accordingly, we find that Mr. Dawson operated an unauthorized radio station.  Weighing 
the relevant statutory factors and our own forfeiture guidelines, we conclude, based on the evidence 
before us, that the proposed forfeiture of $25,000 properly reflects the seriousness, duration, and scope of 
Mr. Dawson’s violations and that no reduction of the proposed forfeiture is warranted. 
IV. CONCLUSION
13. Based on the record before us and in light of the applicable statutory factors, we conclude 
that Mr. Dawson willfully and repeatedly violated Section 301 of the Act by operating a pirate FM 
broadcast station on 97.5 MHz in Paterson, New Jersey.  We decline to cancel or reduce the $25,000 
forfeiture proposed in the NAL.
V. ORDERING CLAUSES
14. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act,
33
and Section 
1.80 of the Rules,
34
Conroy Dawson IS LIABLE FOR A MONETARY FORFEITURE in the amount 
of Twenty-Five Thousand Dollars ($25,000) for willfully and repeatedly violating Section 301 of the 
Act.
35
15. 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.
36
  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.
37
16. 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.  Mr. Dawson shall 
send electronic notification of payment to Matthew L. Gibson at 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.
38
  When completing 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: 
                                                     
30
See NAL Response at 3-4.
31
NAL, 32 FCC Rcd at 108-09, para. 4.
32
Id.
33
47 U.S.C. § 503(b).
34
47 CFR § 1.80.
35
47 U.S.C. § 301.
36
Id.
37
47 U.S.C. § 504(a).
38
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 17-583
5
? 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. Luis, MO 63101.
? Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and Account Number 27000001.  To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
at (314) 418-4232 on the same business day the wire transfer is initiated.
? Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.  
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank –
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.
17. 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 12
th
Street, 
S.W., Room 1-A625, Washington, DC 20554.
39
  Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by telephone, 1-877-480-3201, or by e-mail, 
ARINQUIRES@fcc.gov. 
18. IT IS FURTHER ORDERED that a copy of this Forfeiture Order shall be sent by first 
class mail and certified mail, return receipt requested to Conroy Dawson at his address of record.
FEDERAL COMMUNICATIONS COMMISSION
David Dombrowski
Regional Director
Region One
Enforcement Bureau
                                                     
39
See 47 CFR § 1.1914.