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Federal Communications Commission FCC 17-171
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Sinclair Broadcast Group, Inc.
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File No.: EB-IHD-16-00021748
NAL/Acct. No.: 201732080006
FRN No.: 0004331096
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: December 13, 2017 Released: December 21, 2017
By the Commission: Chairman Pai and Commissioners O’Rielly and Carr issuing separate statements;
Commissioners Clyburn and Rosenworcel dissenting and issuing separate statements.
I. INTRODUCTION
1. We propose a penalty of $13,376,200 against Sinclair Broadcast Group, Inc. (identified
herein, including its wholly owned subsidiaries on Attachment A and Sinclair Television Group, Inc., as
Sinclair) for apparently engaging in repeated violations of the Communications Act of 1934, as amended
(Act), and Federal Communications Commission (FCC or Commission) rules (Rules) regarding paid-for
broadcast programming.1 Our rules require a broadcaster airing a paid program to include an
announcement stating that the program has been paid to air and identifying the program sponsor
(collectively, sponsorship identification announcements or disclosures). After receiving an anonymous
complaint (Complaint), the Commission’s Enforcement Bureau (Bureau) gathered evidence that revealed
that Sinclair apparently was paid to broadcast sponsored programming, including programming in the
form of news segments that aired during the local news. Sinclair apparently broadcast such programming
at 64 of its stations—collectively more than 1,400 times—without airing the required sponsorship
identification announcements. The Bureau’s investigation also showed Sinclair apparently provided the
paid programming to 13 non-Sinclair stations more than 280 times without advising those licensees that
the programming was sponsored or who sponsored it. Then, the non-Sinclair stations apparently
broadcast such programming without informing viewers that the programming was paid for by a third
party or clearly identifying the third party. These apparent actions violate the Act and the Rules.
2. Our action today advances the Commission’s longstanding goals of protecting consumers
by ensuring they know who is attempting to persuade them and protecting broadcasters and sponsors from
unfair competitors that fail to abide by our disclosure rules. When a broadcast licensee fails to disclose
the sponsor of paid programming, it may mislead the public into believing the paid broadcast material is a
station’s independently generated news or editorial content. In addition, enforcement of the sponsorship
identification requirements protects competition by preventing sponsors from gaining an unfair advantage
by paying stations to present commercial material as news or editorial content, while their competitors’
paid programming is properly disclosed as sponsored material.
II. BACKGROUND
3. On April 11, 2016, the Commission received a Complaint alleging Sinclair had aired
“compensated stories as news content” about Huntsman Cancer Institute (HCI) on behalf of the Huntsman
Cancer Foundation (Huntsman Foundation or HCF) but failed to disclose that HCF paid for those stories
1 Attachment A also identifies the Sinclair and non-Sinclair stations that broadcast the programming discussed
herein.
Federal Communications Commission FCC 17-171
2
to air.2 On July 26, 2016, the Bureau issued a letter of inquiry (LOI) to Sinclair, seeking more
information about the HCI programming.3 The LOI included a copy of the Complaint.4 On September
30, 2016, Sinclair responded to the LOI by providing a narrative statement and responsive documents
(LOI Response).5 The Bureau thereafter issued additional inquiries to Sinclair, to which Sinclair
responded.6
4. As described below, although Sinclair disputes the inferences we draw from the facts,
there are few, if any, actual disputes about the key facts associated with the apparent violations.7 Sinclair
and the Huntsman Foundation entered into an agreement (Huntsman Agreement) to promote HCF and

2 Letter from anonymous complainant to Jeffrey J. Gee, Chief, Investigations and Hearings Division, FCC
Enforcement Bureau (Mar. 31, 2016) (on file in EB-IHD-16-00021748).
3 Letter from Matthew L. Conaty, Deputy Chief, Investigations and Hearings Division, FCC Enforcement Bureau, to
Barry M. Faber, Esq., Executive Vice President and General Counsel, Sinclair Broadcast Group, Inc. (July 26, 2016)
(on file in EB-IHD-16-00021748).
4 Id. at 1, Attachment.
5 Letter from Miles S. Mason, Esq., Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman
LLP, to Marlene H. Dortch, Secretary, FCC, et al. (Sept. 30, 2016) (on file in EB-IHD-16-00021748) (LOI
Response). Sinclair acknowledged receipt of the Complaint and discussed it in its LOI Response. Id. at 2 n.2.
6 E-mail from Matthew L. Conaty, Deputy Chief, Investigations and Hearings Division, FCC Enforcement Bureau,
to Miles S. Mason, Esq., Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP (Oct. 25,
2016, 17:04 EST) (on file in EB-IHD-16-00021748) (Supplemental LOI); Letter from Miles S. Mason, Esq.,
Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary,
FCC, et al. (Nov. 4, 2016) (on file in EB-IHD-16-00021748); E-mail from Miles S. Mason, Esq., Counsel to Sinclair
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Matthew L. Conaty, Deputy Chief, Investigations
and Hearings Division, FCC Enforcement Bureau, et al. (Nov. 15, 2016, 16:27 EST) (on file in EB-IHD-16-
00021748) (collectively, Supplemental LOI Response); Letter from Miles S. Mason, Esq., Counsel to Sinclair
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, FCC, et al. (Apr. 4,
2017) (on file in EB-IHD-16-00021748) (Second Supplemental Response); Letter from Miles S. Mason, Esq.,
Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary,
FCC, et al. (May 12, 2017) (on file in EB-IHD-16-00021748) (Third Supplemental Response).
7 Sinclair requested, pursuant to 47 CFR § 0.459, that the Commission afford confidential treatment of its entire LOI
Response. See LOI Response at 19. The Bureau thereafter provided Sinclair the opportunity to supplement and
amend its request to conform to the requirements of Section 0.459. Letter from Matthew L. Conaty, Deputy Chief,
Investigations and Hearings Division, FCC Enforcement Bureau, to Miles S. Mason, Esq., Counsel to Sinclair
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP (Apr. 28, 2017) (on file in EB-IHD-16-00021748); E-
mail from Matthew L. Conaty, Deputy Chief, Investigations and Hearings Division, FCC Enforcement Bureau, to
Miles S. Mason, Esq., Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP (May 15,
2017, 16:13 EDT) (on file in EB-IHD-16-00021748). Sinclair subsequently amended and narrowed the scope of its
request, following discussions with Commission staff. Letter from Miles S. Mason, Esq., Counsel to Sinclair
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, FCC, et al. (May
17, 2017) (on file in EB-IHD-16-00021748) (rescinding request to keep confidential Exhibit D to the Supplemental
LOI Request and pages 5-40 of the Second Supplemental Response); Letter from Miles S. Mason, Esq., Counsel to
Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, FCC, et al.
(May 12, 2017) (on file in EB-IHD-16-00021748) (withdrawing request for confidentiality with respect to LOI
Response Exhibits 1, 2, 3, 4, 5, 8, 11, 12, 15, 18 & 19); Letter from Miles S. Mason, Esq., Counsel to Sinclair
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, FCC, et al. (May 3,
2017) (on file in EB-IHD-16-00021748). This NAL does not disclose material identified as confidential under
Sinclair’s amended request; we defer ruling on the amended request unless and until necessary. See 47 CFR §
0.459(d)(3) (the Commission may defer acting on requests for confidential treatment of materials submitted to the
Commission until a request for inspection has been made pursuant to § 0.460 or § 0.461; such materials will be
accorded confidential treatment until the Commission acts on the confidentiality request and all subsequent appeal
and stay proceedings have been exhausted).
Federal Communications Commission FCC 17-171
3
HCI through programming broadcast on Sinclair stations and on stations to which Sinclair provided
programming under various agreements (we refer collectively to these non-Sinclair stations as Agreement
Stations).8 The Huntsman Agreement provided for a multi-market campaign including: (a) 60-90 second
sponsored stories about HCI made to look like independently generated news stories (on-air stories)9 and
(b) 30-minute paid programs about HCI (long-form programs).10 KUTV, Sinclair’s station in Salt Lake
City, Utah, produced the on-air stories and long-form programs and transmitted them to other stations for
broadcast.11 According to Sinclair, “[d]espite repeated written and oral direction from Sinclair’s
executive and legal staff to include proper sponsorship identification,” certain broadcasts containing paid
programming aired without the required sponsorship identification announcements.12 Sinclair attributes
this to alleged miscommunications and “misunderstanding[s]” concerning the process for inserting
sponsorship identifications, as well as “automation of the process” which “resulted in subsequent
omissions of the [sponsorship] identification at some stations.”13
5. More specifically, Sinclair identified 1,644 instances in which it, and the Agreement
Stations to which Sinclair provided the programming without the necessary disclosures, apparently failed
to air the requisite announcements.14 Notwithstanding Sinclair’s admissions and the record evidence,
however, and as discussed further herein, Sinclair argues that it was not legally required to make the
sponsorship identification disclosures required under the Huntsman Agreement.15 In addition, the record
indicates that in 79 instances, Sinclair stations and the Agreement Stations aired long-form programs with
sponsorship announcements that failed to clearly identify HCF as the sponsor. Overall, our review of the
record indicates that the majority of the broadcasts of the paid on-air stories were aired without the
required sponsorship identification announcements.16

8 LOI Response at 3-4, 7-9 & n.7, Answer Nos. 8 & 9, Exh. 9; Supplemental LOI Response at 5, Answer No. 4(b);
Third Supplemental Response, Exhs. 3 & 5. Sinclair Television Group, Inc., a Sinclair subsidiary, is the party to the
Huntsman Agreement. LOI Response at 9, Exh. 9.
9 “The on-air stories [we]re separately produced . . . for distribution to the stations for inclusion in their morning
and/or evening news programs,” LOI Response at 4, thus making them difficult to distinguish from the actual news.
10 LOI Response at 7 & n.7, Answer No. 9, Exh. 9. The Huntsman Agreement also contemplated the production and
dissemination of “commercials,” which are not at issue in this matter. See 47 CFR § 73.1212(f) (“In the case of
broadcast matter advertising commercial products or services, an announcement stating the sponsor’s corporate or
trade name, or the name of the sponsor’s product, when it is clear that the mention of the name of the product
constitutes a sponsorship identification, shall be deemed sufficient for the purpose of this section and only one such
announcement need be made at any time during the course of the broadcast.”).
11 LOI Response at 4.
12 Id.; Second Supplemental Response at 5-40 (listing stations, types of programs, dates, and times on which
programming aired without a sponsorship identification announcement).
13 LOI Response at 4. Sinclair stations received various inquiries about the HCI programming, apparently from the
public, but none of these inquiries seems to have resulted in discovery of the issue. Id. at 6-7, Answer No. 7.
14 Second Supplemental Response at 5-40. Specifically, as set forth herein, a total of 1,366 paid programs aired on
Sinclair stations and a total of 278 paid programs aired on Agreement Stations, representing 1,644 instances in
which such paid programming aired without a sponsorship announcement. See infra para. 6.
15 LOI Response at 11-12, Answer No. 11; Supplemental LOI Response at 4, Answer No. 3(a).
16 Third Supplemental Response, Exh. 5; Second Supplemental Response at 5-40.
Federal Communications Commission FCC 17-171
4
6. The following table summarizes the evidence regarding the programming broadcast by
the Sinclair stations:
Program Sinclair Stations
On-air stories and long-form programs broadcast without any identification 1,36617
Long-form programs that identified the programming as paid but failed to
clearly identify the sponsors 71
Total 1,437

7. The following table summarizes the evidence regarding Sinclair’s failure to provide
disclosures to the Agreement Stations and the related non-compliant broadcasts:
Program Agreement Stations
On-air stories and long-form programs provided to Agreement Stations
without any identification 27818
Long-form programs provided to Agreement Stations that identified the
programming as paid but failed to clearly identify the sponsors 8
Total 286

III. DISCUSSION
8. We find that Sinclair apparently willfully and repeatedly violated Section 317(a)(1) of the
Act and Section 73.1212(a) of the Rules by broadcasting on 64 of its stations (a) 1,366 on-air stories and
long-form programs about HCI without an announcement disclosing that the programming was
sponsored, and (b) 71 long-form programs with deficient announcements—i.e., announcements that
identified the programming as paid but failed to clearly identify the sponsor of the paid program. Also,
we find that Sinclair apparently violated the reporting obligations in Section 507 of the Act by failing to
notify Agreement Stations in 286 instances that the Huntsman Foundation paid Sinclair to air the HCI
programming, which resulted in programs being aired without fully compliant disclosures.19 We propose
a forfeiture of $13,376,200 against Sinclair based on its apparent violations of the Act and the Rules.
A. Sinclair Apparently Violated Section 317 of the Act and Section 73.1212 of the Rules
9. When programming is sponsored, Section 317 of the Act and Section 73.1212(a) of the
Rules require the broadcaster to announce to viewers at the time the program is aired that the broadcaster
has been paid to air the programming and the identification of the sponsor.20 As discussed in detail
below, Sinclair apparently violated these provisions.

17 This includes 1,357 on-air stories and nine long-form programs. See supra note 14.
18 Pursuant to the Huntsman Agreement, Sinclair apparently provided programming to 13 Agreement Stations over
the course of 28 weeks. In calculating the potential violations, we counted instances in which Sinclair provided the
programming and the programming was aired without a sponsorship identification announcement. Second
Supplemental Response at 5-40 (listing stations, dates, and times on which programming aired without a
sponsorship announcement). We only counted one violation per on-air story or long-form program, even if the
Agreement Station aired it multiple times, because Sinclair’s apparent violations of Section 507 occurred at the
points that it failed to disclose to the Agreement Stations that the content it supplied was sponsored.
19 The Bureau and Sinclair initially agreed to toll the applicable statutes of limitations for all such potential
violations by 180 days. See Tolling Agreement at 1-2, paras. 1-2 (Sept. 8, 2016) (on file in EB-IHD-16-00021748).
On June 7, 2017, the Bureau and Sinclair agreed to extend tolling an additional 180 days. See Second Tolling
Agreement at 1-2, paras. 1-2 (June 7, 2017) (on file in EB-IHD-16-00021748). Under these agreements, the
applicable statutes of limitations for the apparent violations, as to Sinclair, would have expired between January 8,
2018, and July 15, 2022.
20 Section 317(a)(1) of the Act provides in part:
(continued….)

Federal Communications Commission FCC 17-171
8
This type of graphic also accompanied long-form programs disclosing that “the program supplier” had
paid for the broadcast.42 These announcements, however, do not sufficiently identify the program
sponsor.43 “A sponsorship identification announcement must state in language understandable to a
majority of the audience that the station received consideration for the matter broadcast, and from whom
that consideration was received.”44 Likewise, the fact that the words “Huntsman Cancer Institute”
appeared in the program does not clearly state that the Huntsman Cancer Institute paid for the program.45
Viewers could not be expected to identify the sponsor without additional information, because the
program supplier may not necessarily be the entity featured in the programming. The subject matter of
the broadcasts was insufficient to disclose the program sponsor. Just because the program was about
HCI, it does not necessarily follow that HCI paid for it. Indeed, Sinclair claims it previously aired similar
content for free as part of its own news programming.46 The Rules require not only a statement that
material is paid for but also a specific disclosure of the identity of the individual or entity who paid for the
broadcast of such material.
17. The long-form program sponsorship identification announcements therefore do not
comply with the two-part requirement of Section 73.1212 of the Rules, which mandates that the station
announce both that the program material was paid for and the name of the individual or entity who paid
for the program.47 The Rules require the licensee to disclose the sponsor’s identity so that viewers are not
burdened with deducing it.48 Based on the deficient announcements in the recordings and transcripts
Sinclair submitted, and in the absence of the Company’s ability to demonstrate that compliant
announcements aired for any long-form program broadcasts,49 we find that all 71 long-form programs

42 LOI Response at 16, Answer No. 16, Exh. 15, Recording No. 36, WLOS; Supplemental LOI Response at 3,
Answer No. 1(g), Supplemental Exh. A.
43 See Sonshine Family Television, Inc.; Sinclair Broadcast Group, Inc., Notice of Apparent Liability for Forfeiture,
22 FCC Rcd 18686, 18693, paras. 14-15 & n.35 (2007) (Sonshine NAL), aff’d with reduced forfeiture, Forfeiture
Order, 24 FCC Rcd 14830, 14833-34, paras. 11-12 (2009) (forfeiture reduced and paid) (Sonshine Forfeiture Order)
(rejecting licensee’s assertion that the overall presentation of sponsored programming, which included identification
of the program title participants and production company, sufficed); WTOP License Limited Partnership, Notice of
Apparent Liability for Forfeiture, 10 FCC Rcd 11002, 11002 (MMB 1995) (WTOP NAL) (tag line stating “the
following is a commercial announcement” preceding a paid announcement did not suffice because the tag line failed
to identify by whom or on whose behalf the announcement consideration was supplied), aff’d with reduced
forfeiture, Memorandum Opinion and Order, 11 FCC Rcd 11840 (MMB 1996); Liability of WDAX, Incorporated,
Memorandum Opinion and Order, 6 FCC Rcd 1987, 1987, paras. 2 & 4 (MMB 1991) (assessing forfeiture where the
licensee identified a sponsored message as a “paid announcement” but failed to provide the name of the sponsor
who paid for the message).
44 Sonshine NAL, 22 FCC Rcd at 18693, para. 14 (footnote omitted).
45 See Radio License Holding XI, LLC, Forfeiture Order, 29 FCC Rcd 1623, 1623-24, 1625, paras. 3, 5 (2014)
(forfeiture paid) (Radio License Holding XI) (deeming mere mention of sponsor’s name in the course of paid
informational program material insufficient to satisfy sponsorship identification requirements).
46 LOI Response at 12, Answer No. 11.
47 47 CFR § 73.1212(a)(1)-(a)(2).
48 Cf. WPIX, Inc. (WPIX), New York, New York; Forum Communications, Inc., New York, New York, Initial Decision
of Administrative Law Judge James F. Tierney, 68 FCC 2d 218, 327, para. 488 (1974) (“The announcement
expected should fully and fairly disclose the true identity of the consideration source.”).
49 See Infinity Broadcasting Corporation of Los Angeles, Memorandum Opinion and Order, 17 FCC Rcd 9892,
9896, para. 18 (2002) (“[A] licensee may not avoid liability by claiming that he doesn’t know what did or did not go
out over his station.”) (internal quotation marks omitted); ProActive Communications, Inc., Notice of Apparent
Liability for Forfeiture, 23 FCC Rcd 9079, 9082-83, para. 7 (EB 2008) (forfeiture paid) (ProActive) (“[T]he
Commission has previously ruled that a licensee may not avoid liability for a rule violation by claiming ignorance as
to what was broadcast over its station.”).

Federal Communications Commission FCC 17-171
11
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, substantial economic gain, and such other matters
as justice may require.61 We have discretion to upwardly or downwardly adjust from the base forfeiture,
taking into account the particular facts of each individual case.62
24. Section 1.80(b) of the Rules sets a base forfeiture of $4,000 for violations of the
Commission’s sponsorship identification rules for each violation or each day of a continuing violation.63
We apply the $4,000 base forfeiture to each of Sinclair’s apparent violations of the sponsorship
identification requirements, including the apparent violations of Section 317 of the Act and Section
73.1212 of the Rules (1,437 instances of apparently airing programs without the requisite disclosures),
and the apparent violations of the reporting obligations of Section 507 of the Act (286 instances of
apparently failing to provide the requisite disclosures to Agreement Stations, which then apparently failed
to air the required disclosures).64 Thus, the aggregate base forfeiture amount for the violations at issue
here is $6,892,000. 65
(Continued from previous page)
Office of Mgmt. & Budget, Exec. Office of the President, Memorandum for the Heads of Executive Departments
and Agencies re Implementation of the 2017 annual adjustment pursuant to the Federal Civil Penalties Inflation
Adjustment Act Improvements Act of 2015, M-17-11, Dec. 16, 2016, at 1. The Bureau released the order making
the 2017 annual adjustment on December 30, 2016. See Amendment of Section 1.80(b) of the Commission’s Rules,
Adjustment of Civil Monetary Penalties to Reflect Inflation, Order, DA 16-1453 (EB 2016), 2016 WL 7492481; see
also Annual Adjustment of Civil Monetary Penalties to Reflect Inflation, 82 Fed. Reg. 8170 (Jan. 24, 2017) (setting
January 24, 2017, as the effective date for the increases). The 2015 Inflation Adjustment Act provides that the new
penalty levels shall apply to penalties assessed after the effective date of the increase, “including [penalties] whose
associated violation predated such increase.” See 28 U.S.C. § 2461 note, citing the Federal Civil Penalties Inflation
Adjustment Act, as amended, § 6.
61 47 U.S.C. § 503(b)(2)(E); 47 CFR § 1.80(b)(8), Note § II (articulating criteria for upward adjustments (egregious
misconduct, ability to pay/relative disincentive, intentional violation, substantial harm, prior violations of any FCC
requirements, substantial economic gain, and repeated or continuous violation) and downward adjustments (minor
violation, good faith or voluntary disclosure, history of overall compliance, and inability to pay)).
62 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) (1997 Forfeiture Policy
Statement) (noting that “[a]lthough we 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”), recons. denied,
Memorandum Opinion and Order, 15 FCC Rcd 303 (1999).
63 47 CFR § 1.80(b).
64 Section 1.80 lists a base forfeiture of $4,000 per violation for “sponsorship identification requirements.” The
Commission has previously assessed forfeitures consistent with this listing in instances involving violations of
sponsorship identification requirements under Section 317 of the Act and Section 73.1212 of the Commission’s
rules. See Radio License Holding XI, LLC, 29 FCC Rcd at 1628, 1630-31, paras. 1, 12, 17 (2014). To the extent
necessary for purposes of this proceeding, we find this to be persuasive precedent for purposes of support for these
requirements as well as for violations of Section 507 of the Act given the similarities in conduct proscribed and
public interest involved. The requirements at issue relate to adequate sponsorship identification so that the public
may know who seeks to persuade it.
65 In Radio License Holding XI, we observed that “[i]n more recent cases . . . [we have] imposed significantly higher
forfeiture amounts and ha[ve] calculated the forfeiture by multiplying the base forfeiture by the number of violations
. . . . We are following here the approach we used in Sonshine, and we intend that the Commission and the Bureau
will generally take this approach to calculating forfeiture amounts for sponsorship identification violations in the
future.” Radio License Holding XI, LLC, 29 FCC Rcd at 1628, para. 12. Although the Commission has deviated
from a per-instance standard occasionally in other areas, see, e.g., STi Telecom, Inc., Forfeiture Order, 30 FCC Rcd
11742, 11756, para. 30 (2015), in this case, no excessive penalties will result if we follow the guidance in Radio
License Holding XI, LLC; thus, we see no reason to deviate from that approach here.
Federal Communications Commission FCC 17-171
12
25. In this case, given the totality of the circumstances, and consistent with the 1997
Forfeiture Policy Statement, we conclude that a significant upward adjustment is warranted. This
adjustment is justified by multiple statutory factors, beginning with the nature, circumstances, extent, and
gravity of the violations.66 As a result of Sinclair’s conduct detailed above, in more than 1,700 instances
during a seven-month period, HCI on-air stories and long-form programs apparently were broadcast
without the required sponsorship identification announcements on 77 stations, including 64 Sinclair
stations and 13 non-Sinclair Agreement Stations, and potentially reached a large national audience of
viewers.67 The violations at issue were not isolated either geographically or temporally.68 Most of the
apparent violations involved paid programming that aired without any sponsorship identification
announcements and could have misled the audience into believing the content was independently
generated news originated without regard to third-party influence. Although some of the apparent
violations provided incomplete disclosures—that the programming was paid but not by whom—such
violations accounted for only a small number of all violations. That said, we do not upwardly adjust to
the same extent for such violations as we do for violations where there was no disclosure.
26. In addition, Sinclair has a prior history of violating other FCC rules governing
commercial messages.69 Over the past decade, Sinclair has repeatedly violated the commercial limits
component of the Children’s Television Rules, 47 CFR § 73.670.70
27. That an upward adjustment is warranted also is confirmed by other factors. The
Huntsman Agreement generated significant revenue, requiring payments of $275,000 per month to
Sinclair in consideration for these broadcasts, for an expected total compensation package of $ .71
Moreover, Sinclair, a sophisticated broadcaster with national reach, reported 2016 revenues in excess of
$2.7 billion.72 As we have previously noted and “as Congress has stated, for a forfeiture to be an effective

66 47 U.S.C. § 503(b)(2)(E).
67 See Viacom, Inc., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 2548, 2566, para. 38 (2014) aff’d sub
nom. Viacom Inc. ESPN Inc., Forfeiture Order, 30 FCC Rcd 797, 805, para. 21 (2015) (forfeitures paid) (Viacom)
(assessing forfeitures of $1,120,000 against Viacom and ESPN, based, in pertinent part, upon companies’ networks’
substantial audience reach); Behringer USA, Inc., Forfeiture Order, 22 FCC Rcd 10451, 10457-58, para. 16 (2007)
(forfeiture paid) (nature and extent of violations justify an upward adjustment); see also Capstar TX Limited
Partnership, Notice of Apparent Liability for Forfeiture, 23 FCC Rcd 10464, 10467-68, paras. 8-9 (EB 2008)
(forfeiture paid) (applying upward adjustment of the base forfeiture from $4,000 to $12,000); Multicultural Radio
Broadcasting Licensee, LLC, Notice of Apparent Liability for Forfeiture, 22 FCC Rcd 21555, 21561-62, para. 15
(EB 2007) (forfeiture paid) (applying an upward adjustment from the base forfeiture of $4,000 to $12,000 based in
part on an egregious violation); Citicasters Licenses, L.P., Notice of Apparent Liability for Forfeiture, 22 FCC Rcd
1633, 1635-36, paras. 9-10 (EB 2007) (forfeiture paid) (applying upward adjustment of the base forfeiture from
$4,000 to $10,000).
68 We have not upwardly adjusted based on the number of incidents to avoid any double counting against Sinclair.
69 See Forfeiture Policy Statement, 12 FCC Rcd at 17116 (including “[p]rior violations of any FCC requirements” as
an upward adjustment factor).
70 Channel 33, Inc., Letter and Admonishment, 29 FCC Rcd 12609 (MB 2014); WLOS Licensee, LLC, Notice of
Apparent Liability for Forfeiture, 25 FCC Rcd 4598 (MB 2010) (forfeiture paid); San Antonio (KRRT-TV) Licensee,
Inc., Forfeiture Order, 25 FCC Rcd 3747 (MB 2010) (forfeiture paid); WVTV Licensee, Inc., Forfeiture Order, 25
FCC Rcd 3741 (MB 2010) (forfeiture paid); KLGT Licensee, LLC, Notice of Apparent Liability for Forfeiture, 24
FCC Rcd 949 (MB 2009) (forfeiture paid); WLFL Licensee LLC, Notice of Apparent Liability for Forfeiture, 23
FCC Rcd 8182 (MB 2008) (forfeiture paid); WUXP Licensee, LLC, Notice of Apparent Liability for Forfeiture, 23
FCC Rcd 6397 (MB 2008) (forfeiture paid).
71 LOI Response at 11, Answer No. 10; Exh. 9.
72 Sinclair Broadcast Group, Inc., Annual Report (Form 10-K) at 5-10, 34-35 (Feb. 28, 2017),
https://www.sec.gov/Archives/edgar/data/912752/000091275217000006/sbgi-20161231x10k htm (describing
national scope of and annual revenues realized from Sinclair’s broadcast operations).
Federal Communications Commission FCC 17-171
13
deterrent . . . [it] must be issued at a high level . . . to guarantee that forfeitures issued against large or
highly profitable entities are not considered merely an affordable cost of doing business.”73
28. In applying the applicable statutory factors, we also consider whether there is any basis
for a downward adjustment of the proposed forfeiture. Here, we find none.
29. The purported fact that Sinclair intended to comply with the law does not warrant a
downward adjustment. Although Sinclair now contends no sponsorship identification disclosures were
required, Sinclair nonetheless claims its “senior corporate executives and legal staff always intended that
the stories would include sponsorship identification, and many stations did, in fact, include such
identification.”74 Even if true, this would not support a downward adjustment; the relevant precedent is to
the contrary.75
30. We also are cognizant of certain corrective measures Sinclair took, but it did so only after
receiving the Bureau’s LOI.76 Under the circumstances of this case, Radio License Holding XI and other
Commission precedent do not support a downward adjustment for such corrective action.77
31. Moreover, we find no basis for a downward adjustment based on the purported public
interest benefits of the HCI programming. Viewers are entitled to the protections of our laws and must be

73 Forfeiture Policy Statement, 12 FCC Rcd at 17099-100, para. 24. See Viacom, 30 FCC Rcd at 797-98, 805-06,
paras. 2, 22 (noting that an upward adjustment is appropriate in light of Viacom’s reported annual revenues and the
revenues of ESPN’s parent); Union Oil Company of California, Notice of Apparent Liability for Forfeiture, 27 FCC
Rcd 13806, 13810, para. 10 (2012) (forfeiture paid) (proposing an upward adjustment of the base forfeiture from
$26,000 to $96,200 for unauthorized operation of private land mobile radio stations after license expiration based in
part on recognition that Union Oil’s parent company, Chevron, is a multibillion dollar global enterprise and to
ensure that forfeiture liability is a deterrence and not a cost of doing business); SBC Communications Inc., Order on
Review, 17 FCC Rcd 4043, 4052, para. 20 (2002) (forfeiture paid) (“[A] large and highly profitable company . . .
should expect . . . that the forfeiture amount” may “be above, or even well above, the relevant base amount.”)
(internal quotation marks omitted; second set of alterations in original).
74 LOI Response at 4.
75 See Unipoint Technologies, 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, 1640, para. 21 (2014) (“It is immaterial whether [the licensee’s]
violations were inadvertent, the result of ignorance of the law, or the product of administrative oversight.”), default
judgment entered, United States v. Unipoint Technologies, Inc., No. 14-12020-LTS, 2016 WL 8902575, at *1-2 (D.
Mass. Apr. 27, 2016); Texas Soaring Association, Inc. Midlothian, Texas, Forfeiture Order, 28 FCC Rcd 10740,
10743-44, para. 7 (EB 2013) (forfeiture paid) (“Even if administrative oversight, inadvertence, or a lack of
familiarity with the Rules may have contributed to the violation, they do not . . . mitigate liability arising therefrom”)
(footnotes omitted); Cascade Access, L.L.C., Forfeiture Order, 28 FCC Rcd 141, 145, para. 9 (EB 2013) (forfeiture
paid) (rejecting argument that the unintentional nature of the violation justifies mitigation of the forfeiture amount),
recon. denied, Memorandum Opinion and Order, 30 FCC Rcd 14018 (EB 2015); América Móvil, S.A.B. de C.V.
Parent of Puerto Rico Telephone Company, Inc., Notice of Apparent Liability for Forfeiture, 26 FCC Rcd 8672,
8676, para. 11 (EB 2011) (forfeiture paid) (“While América Móvil claimed that the violation was a result of an
inadvertent oversight, it is well established that administrative oversight or inadvertence is not a mitigating factor
warranting a downward adjustment of a forfeiture.”).
76 See LOI Response at 4, 12-13, Answer No. 12 & Exh. 10; Supplemental LOI Response at 7, Answer No. 5(b) &
Supplemental Exh. D.
77 See Radio License Holding XI, 29 FCC Rcd at 1629-30, para. 15 (declining to reduce a per-broadcast forfeiture
even when the licensee took certain corrective action prior to receiving the Bureau’s letter of inquiry, but did not
also notify listeners of the violative announcements and did not voluntarily disclose its conduct to the Commission);
Union Broadcasting, Inc., Forfeiture Order, 19 FCC Rcd 18588, 18590, para. 10 (EB 2004) (forfeiture paid)
(specifying that “‘corrective action taken to come into compliance with Commission rules or policy is expected, and
does not nullify or mitigate any prior forfeitures or violations’”), quoting Seawest Yacht Brokers d/b/a San Juan
Marina Friday Harbor, Washington, Forfeiture Order, 9 FCC Rcd 6099, para. 7 (1994).
Federal Communications Commission FCC 17-171
14
informed of whether a third party is paying to influence them, and who that third party is, through their
local broadcasters regardless of the content of the programming.78
32. Finally, while we have taken into account that Sinclair made incomplete disclosures in a
small number of instances, we do not think the balance of considerations warrants downward adjustment
of the proposed base forfeiture where such incomplete disclosures were made—identifying the
programming as paid but not clearly identifying the sponsor. As set forth above and below, we have
already applied a lower upward adjustment to the incomplete disclosures.79
33. Neither the language of the Act nor the Rules suggests that an incomplete disclosure is
sufficient to enable consumers to know “that they are being persuaded and by whom they are being
persuaded”—the fundamental purpose of the sponsorship identification rules. Section 317 of the Act and
Section 73.1212 of the Rules clearly require broadcasters “to inform the audience of two things: that [the
audience] is hearing or viewing matter which has been paid for, and the identity of the message
sponsor.”80
34. As the Commission long ago explained: “In all cases, the public is entitled to know the
name of the company it is being asked to deal with;” speaking specifically of Section 317 of the Act: “its
plain intent is to prevent a fraud being perpetrated on the listening public by letting the public know the
people with whom they are dealing.”81 An incomplete disclosure that fails to identify the sponsor does
not inform the public of who seeks to persuade them and does not provide viewers with facts they may
find crucial in evaluating the credibility of the programming.82 Because the plain objective of the Act,
then, is fully frustrated by an incomplete disclosure, a full forfeiture is warranted. Moreover, we are
concerned that downward adjusting the forfeiture amount for such incomplete disclosures under the facts

78 See, e.g., Fox Television Stations, Inc., Notice of Apparent Liability for Forfeiture, 26 FCC Rcd 3964, 3970-71,
paras. 15-17 (EB 2011) (sponsorship identification requirements are content-neutral disclosure requirements, and
any penalty adjustment, whether upward or downward, based on an evaluation of the value of the sponsored content
would potentially raise constitutional issues under the First Amendment), aff’d, Forfeiture Order, 26 FCC Rcd 9485
(EB 2011) (forfeiture paid) (Fox Television Stations). The Commission’s role is limited to determining whether the
licensee disclosed the programming was sponsored or paid for and by whom or on whose behalf such payment or
consideration was supplied; under the First Amendment and Section 326 of the Act, “the Commission must avoid
intrusion on a broadcaster’s editorial judgments.” Fox Television Stations, 26 FCC Rcd at 3971, para. 17. See 47
U.S.C. § 326; cf. Nat’l Ass’n for Better Broad. v. FCC, 830 F.2d 270, 277 (D.C. Cir. 1987) (sponsorship
identification law must “be given its normal operative force even though the program in question might not be
regarded as entirely commercial in content”); Carolina Rays, LLC, Forfeiture Order, 28 FCC Rcd 10068, 10071,
para. 11 (MB 2013) (forfeiture paid) (rejecting licensee’s argument that forfeiture should be reduced or mitigated
based upon service to the community and significant local programming).
79 See supra para. 25 and infra para. 36.
80 Commission Reminds Broadcast Licensees and Cable Operators of Sponsorship Identification Requirements
Applicable to Paid-For “Public Service Messages,” Public Notice, 6 FCC Rcd 5861 (1991) (emphasis added). See
Radio License Holding XI, 29 FCC Rcd at 1627, para. 9, quoting Commission Reminds Broadcast Licensees, Cable
Operators and Others of Requirements Applicable to Video News Releases and Seeks Comment on the Use of Video
News Releases by Broadcast Licensees and Cable Operators, Public Notice, 20 FCC Rcd 8593, 8593-94 (2005);
Applicability of Sponsorship Identification Rules, Public Notice, 40 FCC 141, 141 (1963) (subsequent history
omitted) (“[A]s far back as the Radio Act of 1927 and continuing with Section 317 of the Communications Act of
1934 there has been an unvarying requirement that all matter broadcast by any station for a valuable consideration is
to be announced as paid for or furnished, and by whom.”).
81 Identification on Broadcast Station, Public Notice, 40 FCC 2 (1950).
82 The identity of a sponsor may substantially impact the credibility of the message. For example, a viewer may
attach different meaning to the same content where the content was generated by an organization that stands to gain
a financial benefit from the program, as compared to content generated by an organization with no similar pecuniary
interest.
Federal Communications Commission FCC 17-171
15
of this case may send the wrong message about the level of care required of broadcasters and thus
inadvertently incentivize broadcasters to invest fewer resources towards ensuring full compliance.
35. In certain limited situations, some cases have applied downward adjustments where there
were incomplete disclosures. However, those decisions are non-binding83 or distinguishable.84
Moreover, more recently in the Sonshine NAL, the Commission declined to reduce a forfeiture based on
the licensee’s argument of a purported “good faith” attempt to comply with sponsorship identification
requirements.85 According to the record in this case, Sinclair was manifestly aware of the need to include
fully compliant sponsorship identification disclosures in its paid programming,86 and effectuating the

83 See Comcast Corp. v. FCC, 526 F. 3d 763, 769-70 (D.C. Cir. 2008) (“an agency is not bound by the actions of its
staff if the agency has not endorsed those actions”) (internal quotation marks omitted); Radio License Holding XI,
29 FCC Rcd at 1628, para. 12.
84 For example, in Jacor, a licensee broadcast a series of “60-second announcements promoting the commercial
services and attractions of Cripple Creek, Colorado,” without specifically identifying their sponsor, the Cripple
Creek Chamber of Commerce. Jacor Broadcasting of Colorado, Inc., Memorandum Opinion and Order and
Forfeiture Order, 12 FCC Rcd 9969, 9969, paras. 2 (1997) (Jacor). The Commission rejected the licensee’s
argument that Section 73.1212(f) applied, deeming the area services and attractions were “not obviously intertwined
in the public mind” with the Chamber of Commerce. Id. at 9970, para. 2. However, the Commission recalculated
its forfeiture from $10,000 to $4,000, because “the commercial nature of the announcements was clear to even the
most casual listener.” Id. at 9971, para. 6. In contrast, Sinclair’s long-form programs were not merely 60 seconds
long, but 30 minutes long, and could not be considered “clear” commercials as Sinclair itself claimed they were part
of a campaign to “educate the public about cancer, available treatments, preventative measures and related issues”
and “aimed at increasing national awareness of the Huntsman Cancer Institute’s clinical services and research
operations.” LOI Response at 3, 7, n.7, 9-10, Answer No. 9(b) (“[T]he Huntsman Agreement is a joint effort to
increase awareness about the Huntsman Institute’s medical services and research initiatives and to educate the public
about cancer, available treatments, preventive measures and related issues”). Moreover, we already have
determined Sinclair’s purported attempts to comply with the law, or its mistakes about the nature of the disclosures
the law requires, do not warrant a downward adjustment. See supra para. 29. Older decisions on delegated
authority to the Mass Media Bureau also have on occasion suggested that forfeiture reductions were justified by a
“partial, albeit incomplete, sponsorship identification broadcast” or “good faith” intentions. See, e.g., Channel 36
Licensee Corporation, Notice of Apparent Liability for Forfeiture, 7 FCC Rcd 6541, 6541 (MMB 1992) (Channel
36); Great Trails Broadcasting Corporation, Memorandum Opinion and Order, 8 FCC Rcd 2089, 2089, para. 5
(MMB 1993) (construing Channel 36); WTOP NAL, 10 FCC Rcd at 11002. To the degree that these cases suggest
that incomplete disclosures generally warrant downward adjustments, we overrule them. (Sonshine previously cited
Channel 36 favorably for a different proposition, Sonshine NAL, 22 FCC Rcd at 18693, para. 15 & n.39 (citing
Channel 36 for the proposition that “the Commission has found that the phrase ‘sponsored by’ may be used in place
of ‘paid for,’ but no other substitute words or phrases have been specifically allowed”), and we do not disturb the
holding of Channel 36 as to that point. Here, the evidence shows that Sinclair understood the need to fully comply
with the disclosure obligation, and we already have determined purported attempts to comply with the laws, or its
mistakes about the nature of the disclosures the laws require, do not warrant a downward adjustment. See supra
para. 29.
85 Sonshine M&O, 24 FCC Rcd at 14834, para. 13; see Radio License Holding XI, 29 FCC Rcd at 1629, para. 14
(rejecting licensee’s argument that inadvertent actions or omissions justified a downward adjustment of the
forfeiture amount); Southern California Broadcasting Company, 6 FCC Rcd at 4387-88, paras. 3-4 (rejecting
licensee’s arguments that violations were inadvertent and that it had made good faith attempts to comply with the
sponsorship identification requirements).
86 LOI Response, Exh. 10; see, e.g., id. at 2, 4, 9-10, 11-12, 16-17, Answer Nos. 8(e), 9(b) 11, 16, 17(d). For 90
years, since the inception of commercial broadcasting, broadcasters have been subject to remarkably consistent
sponsorship identification requirements. Section 317 of the Act was included in and has remained largely
unchanged since the passage of the Communications Act of 1934. In fact, Section 317 was taken nearly word-for-
word from Section 19 of the Radio Act of 1927 (Radio Act), which in turn was informed by postal policy regarding
subsidized postage from the late 19th and early 20th centuries. See Richard Kielbowicz and Linda Lawson,
Unmasking Hidden Commercials in Broadcasting: Origins of the Sponsorship Identification Regulations, 1927-
1963, 56 Fed. Comm. L.J. 329, 334-336 (2004).
Federal Communications Commission FCC 17-171
16
broadcast of fully compliant disclosures in accordance with the straightforward precepts of Section 317 of
the Act and Section 73.1212 of the Rules should pose no challenge.
36. Therefore, after applying the 1997 Forfeiture Policy Statement, Section 1.80 of the
Rules, and the statutory factors, we propose a total forfeiture of $13,376,200, for which Sinclair is
apparently liable. The proposed forfeiture is calculated as follows:
Apparent Violation Number of Apparent
Violations
Proposed Forfeiture
Per Apparent
Violation
Total
Sinclair stations—no
disclosures
1,366

$7,800 $10,654,800

Sinclair stations—
incomplete disclosures
71 $7,000 $497,000
Non-Sinclair stations—
no disclosures
278 $7,800 $2,168,400
Non-Sinclair stations—
incomplete disclosures
8

$7,000 $56,000

Total 1,723 NA $13,376,200

IV. CONCLUSION
37. We have determined that Sinclair apparently willfully and repeatedly violated Sections
317 and 507 of the Act and Section 73.1212 of the Rules. As such, Sinclair is apparently liable for a
forfeiture of $13,376,200.
V. ORDERING CLAUSES
38. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act87 and Section
1.80 of the Rules,88 Sinclair Broadcast Group, Inc. is hereby NOTIFIED of its APPARENT
LIABILITY FOR A FORFEITURE in the amount of thirteen million three hundred seventy-six
thousand two hundred dollars ($13,376,200) for willful and repeated violations of Sections 317 and 507
of the Act89 and Section 73.1212 of the Rules.90
39. IT IS FURTHER ORDERED that pursuant to Section 1.80 of the Rules,91 within 30
calendar days of the release date of this Notice of Apparent Liability for Forfeiture, Sinclair Broadcast
Group, Inc. 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 40 below.
40. 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. Sinclair Broadcast
Group, Inc. shall send electronic notification of payment to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov,
Matthew L. Conaty at Matthew.Conaty@fcc.gov, Luba Shur at Luba.Shur@fcc.gov, and Melanie A.

87 47 U.S.C. § 503(b).
88 47 CFR § 1.80.
89 47 U.S.C. §§ 317, 508.
90 47 CFR § 73.1212.
91 47 CFR § 1.80.
Federal Communications Commission FCC 17-171
17
Godschall at Melanie.Godschall@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.92 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.
• 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.
41. 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 20554.93 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.
42. 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 Section 1.16 and 1.80(f)(3) of the Rules.94 The written statement must be mailed to the Office of the
Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, ATTN:
Enforcement Bureau ? Investigations and Hearings Division, and must include the NAL/Acct Number
referenced in the caption. The statement must also be e-mailed to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov,
Matthew L. Conaty at Matthew.Conaty@fcc.gov, Luba Shur at Luba.Shur@fcc.gov, and Melanie A.
Godschall at Melanie.Godschall@fcc.gov.
43. The Commission will not consider reducing or canceling a forfeiture in response to a
claim of inability to pay unless Sinclair Broadcast Group, Inc. 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.
44. 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 to Barry M. Faber,
Esq., Executive Vice President and General Counsel, Sinclair Broadcast Group, Inc., 10706 Beaver Dam

92 An FCC Form 159 and detailed instructions for completing the form may be obtained at
http://www fcc.gov/Forms/Form159/159.pdf.
93 47 CFR § 1.1914.
94 47 CFR §§ 1.16, 1.80(f)(3).
Federal Communications Commission FCC 17-171
18
Road, Cockeysville, Maryland 21030, and to Miles S. Mason, Esq., Pillsbury Winthrop Shaw Pittman
LLP, 1200 Seventeenth Street, NW, Washington, DC 20036-3006.

FEDERAL COMMUNICATIONS COMMISSION

Marlene H. Dortch
Secretary
19
Federal Communications Commission FCC 17-171
ATTACHMENT A

SINCLAIR STATIONS

LICENSEE/
STATION1

2
6/5/2016
7/24/2016
Sinclair
Portland
Licensee,
LLC/KATU,
Portland, OR 0023174519

21649

27
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
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7/1/2016
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7/15/2016
7/22/2016

1 6/5/2016

1 Third Supplemental Response, Exh. 2 & 3.
2 Third Supplemental Response, Exh. 3.
20
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

33543

3
6/3/2016
6/10/2016
6/24/2016

2
6/5/2016
7/23/2016
Sinclair
Bakersfield
Licensee,
LLC/KBAK,
Bakersfield,
CA 0023174451

4148 23
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
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1 6/5/2016
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Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

FRN2 FID # ON-AIR STORIES WITHOUT
SPONSORSHIP ID
LONG-FORM PROGRAMS
WITHOUT SPONSORSHIP ID
LONG-FORM
PROGRAMS WITH
INCOMPLETE
SPONSORSHIP ID
Apparent
Violations
Broadcast Dates Apparent
Violations
Broadcast Dates Apparent
Violations
Broadcast
Dates
Sinclair
Bakersfield
Licensee,
LLC/KBFX-
CD,
Bakersfield,
CA 0023174451 51501 26
1/22/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
Sinclair Boise
Licensee,
LLC/KBOI-
TV, Boise, ID 0023174428

49760

27
1/15/2016
1/22/2016
2/4/2016
2/12/2016
2/19/2016
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3/4/2016
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4/1/2016
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5/27/2016
6/3/2016
6/10/2016
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6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

2
6/5/2016
7/24/2016
22
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

33764

15
4/1/2016
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5/6/2016
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6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/15/2016
7/22/2016

1 6/5/2016
KDNL
Licensee,
LLC/KDNL-
TV, St. Louis,
MO 0002144459

56524 21
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
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1 6/5/2016
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STATION1

56029 24
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7/1/2016
7/8/2016
7/15/2016
7/22/2016

Sinclair
Yakima
Licensee,
LLC/KIMA-
TV, Yakima,
WA

0023174543 56033 24
1/22/2016
2/5/2016
2/12/2016
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3/4/2016
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1 6/5/2016
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STATION1

33691

28
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4/1/2016
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4/15/2016
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5/6/2016
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5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
KFDM
Licensee,
LLC/KFDM,
Beaumont, TX 0021268396

22589

25
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1/22/2016
1/29/2016
2/12/2016
2/19/2016
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5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016

2
6/5/2016
7/24/2016
25
Federal Communications Commission FCC 17-171
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STATION1

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1 6/5/2016
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STATION1

25685 29
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5/6/2016
5/6/20163
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6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

6/5/2016
KGBT
Licensee,
LLC/KGBT-
TV, Harlingen,
TX 0022491526

34457

3 The on-air story apparently aired twice on 5/6/2016, during the 6:00 a.m. hour and the 6:00 p.m. hour. Second Supplemental Response.
27
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

FRN2 FID # ON-AIR STORIES WITHOUT
SPONSORSHIP ID
LONG-FORM PROGRAMS
WITHOUT SPONSORSHIP ID
LONG-FORM
PROGRAMS WITH
INCOMPLETE
SPONSORSHIP ID
Apparent
Violations
Broadcast Dates Apparent
Violations
Broadcast Dates Apparent
Violations
Broadcast
Dates
KHGI
Licensee,
LLC/KHGI-
TV, Kearney,
NE; KHGI-CD,
North Platte,
NE; KWNB-
TV, Hayes
Center, NE4 0009529157
21160
168339
21162 21
6/10/2016
6/10/2016
6/10/2016
6/17/2016
6/17/2016
6/17/2016
6/24/2016
6/24/2016
6/24/2016
7/1/2016
7/1/2016
7/1/2016
7/8/2016
7/8/2016
7/8/2016
7/15/2016
7/15/2016
7/15/2016
7/22/2016
7/22/2016
7/22/2016

KHQA
Licensee,
LLC/KHQA-
TV, Hannibal,
MO 0022491609

4690

27
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

6/5/2016

4 These stations all apparently aired the on-air stories on the same dates and times. Second Supplemental Response.
28
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

51488

1 6/5/2016
KOKH
Licensee,
LLC/KOKH-
TV, Oklahoma
City, OK 0006587109

35388

24
1/29/2016
2/4/2016
2/12/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

2
6/5/2016
7/24/2016
29
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

21656

28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
KRCG
Licensee,
LLC/KRCG,
Jefferson City,
MO 0022491815

41110

24
1/22/2016
1/29/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
30
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

10179 27
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

2
6/5/2016
7/23/2016
KTUL
Licensee,
LLC/KTUL,
Tulsa, OK 0023870496

35685

2
6/5/2016
7/22/2016
31
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

22570

2
6/5/2016
7/24/2016
KTVO
Licensee,
LLC/KTVO,
Kirksville, MO 0022491534

21251

6
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/4/20165
2/12/2016

1 6/5/2016

5 The on-air story apparently aired twice on 2/4/2016, during the 6:00 a.m. hour and the 10:00 p.m. hour. Second Supplemental Response.
32
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

35823

1 6/5/2016
Sinclair Eugene
Licensee,
LLC/KVAL-
TV, Eugene,
OR

0023174535

49766

27
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
33
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

0022490221

40446

28
1/22/2016
1/29/2016
2/1/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

2
6/5/2016
7/24/2016
WACH
Licensee,
LLC/WACH,
Columbia, SC

0022491450

19199

12
2/19/2016
2/26/2016
3/4/2016
3/11/2016
4/1/2016
4/8/2016
4/22/2016
5/18/2016
6/3/2016
6/24/2016
7/8/2016
7/15/2016

1 6/5/2016
Chesapeake
Television
Licensee,
LLC/WBFF,
Baltimore, MD

0004970679

10758

5
2/4/2016
2/13/2016
4/1/2016
4/22/2016
6/10/2016

2
6/5/2016
7/23/2016

WBMA
Licensee,
LLC/WBMA-
LD,
Birmingham,
AL

0023870462

60214

9
1/15/2016
1/22/2016
1/29/2016
2/4/2016
3/4/2016
3/25/2016
4/1/2016
7/8/2016
7/22/2016

1 6/5/2016
34
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

WCHS
Licensee,
LLC/WCHS-
TV,
Charleston,
WV

0002144434

71280 28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/27/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

2
6/5/2016
7/24/2016

WMMP
Licensee
L.P./WCIV,
Charleston, SC

0004970851

9015

28
1/15/2016
1/22/2016
1/28/2016
1/29/2016
2/4/2016
2/8/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/2/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/14/2016
6/21/2016
7/11/2016

2
6/5/2016
7/24/2016
35
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

71363

22
1/29/2016
2/5/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
4/8/2016
4/15/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
WFXL
Licensee,
LLC/WFXL,
Albany, GA 0022490171

70815

6
2/4/2016
2/4/2166
5/12/2016
6/3/2106
6/15/2016
6/24/2016

6 The on-air story apparently aired twice on 2/4/2016, during the 10:00 p m. hour. Second Supplemental Response.
36
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

25683

1 6/5/2016
37
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

58262 497
1/15/2016
1/22/2016
2/19/2016
2/19/2016
2/26/2016
2/26/2016
2/28/2016
3/4/2016
3/4/2016
3/11/2016
3/11/2016
3/18/2106
3/18/2016
3/25/2016
3/25/2016
4/4/2016
4/4/2016
4/8/2016
4/8/2016
4/15/2016
4/15/2016
4/22/2016
4/22/2016
4/29/2016
4/29/2016
5/6/2016
5/6/2016
5/13/2016
5/13/2016
5/20/2016
5/20/2016
5/27/2016
5/27/2016
6/3/2016
6/3/2016
6/10/2016
6/10/2016
6/17/2016
6/17/2016
6/24/2016
6/24/2016
7/1/2016
7/1/2016
7/8/2016
7/8/2016
7/15/2016
7/15/2016
7/22/2016
7/22/2016
2 6/5/2016 6/5/20168

7 The on-air stories apparently aired on WGXA-2 on the following dates during the 6:00 a.m. hour: 2/19/2016; 2/26/2016; 3/4/2016; 3/11/2016; 3/18/2016;
3/25/2016; 4/4/2016; 4/8/2016; 4/15/2016; 4/22/2016; 4/29/2016; 5/6/2016; 5/13/2016; 5/20/2016; 5/27/2016; 6/3/2016; 6/10/2016; 6/17/2016; 6/24/2016;
7/1/2016; 7/8/2016; 7/15/2016; and 7/22/2016. Second Supplemental Response.
8 The long-form program apparently aired on 6/5/2016 on WGXA at 6:00 a m. and WGXA-2 at 5:30 a.m. Id.
38
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

72313

1 6/5/2016
WICD
Licensee,
LLC/WICD,
Champaign, IL

0022116842 25684

1 6/5/2016

9 On May 9, 2017, the Media Bureau granted a pro forma application for the assignment of WHP-TV’s license to Harrisburg Licensee, LLC, File No. BALCDT-
20170425AAV. Broadcast Actions, Public Notice, Report No. 48984 (MB May 12, 2017), 2017 WL 2115643. Sinclair subsequently consummated this license
assignment on May 19, 2017. Consummation Notice (May 23, 2017) (reporting the May 19, 2017 consummation of the pro forma assignment of license to
Harrisburg Licensee, LLC), Federal Communications Commission, WHP-TV Application Search Details, Consummation Notice, https://licensing fcc.gov/cgi-
bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu hts?context=25&appn=101757567&formid=905&fac num=72313.
39
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

25686

1 6/5/2016
40
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

73120

4610
1/28/2016
1/28/2016
2/5/2016
2/5/2016
2/12/2016
2/12/2016
2/19/2016
2/19/2016
2/26/2016
2/26/2016
3/4/2016
3/4/2016
3/11/2016
3/11/2016
3/18/2106
3/18/2016
3/25/2016
3/25/2016
4/1/2016
4/1/2016
4/8/2016
4/8/2016
4/15/2016
4/15/2016
4/22/2016
4/22/2016
4/29/2016
4/29/2016
5/6/2016
5/6/2016
5/13/2016
5/13/2016
5/20/2016
5/20/2016
5/27/2016
5/27/2016
6/3/2016
6/3/2016
6/10/2016
6/10/2016
6/16/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016 1 6/5/2016

WJAR
Licensee,
LLC/WJAR,
Providence, RI 0023893225

50780

1 1/15/2016

1 6/5/2016

10 The on-air stories apparently aired twice on the following dates, during the 5:00 a m. and 6:00 a m. hours: 1/28/2016; 2/5/2016; 2/12/2016; 2/19/2016;
2/26/2016; 3/4/2016; 3/11/2016; 3/18/2016; 3/25/2016; 4/1/2016; 4/8/2016; 4/15/2016; 4/22/2016; 4/29/2016; 5/6/2016; 5/13/2016; 5/20/2016; 5/27/2016;
6/3/2016; and 6/10/2016. Second Supplemental Response.
41
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

1051

16
1/15/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
7/15/2016

1 6/12/2016
WKEF
Licensee
L.P./WKEF,
Dayton, OH 0004970844

73155 28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
42
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

11289

26
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

2
6/5/2016
7/24/2016
WLOS
Licensee,
LLC/WLOS,
Asheville, NC 0004676755

56537 27
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

2
6/5/2016
7/24/2016
43
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

4150

1 6/5/2016
WNWO
Licensee,
LLC/WNWO-
TV, Toledo,
OH 0022491864

73354 27
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016
2
6/5/2016
7/23/2016
44
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

69618

4
2/12/2016
3/18/2016
4/15/2016
7/8/2016

2
6/5/2016
7/22/2016
WPBN
Licensee,
LLC/WPBN-
TV, Traverse
City, MI 0022491765

21253 26
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
WPDE
Licensee,
LLC/WPDE-
TV, Florence,
SC 0022491583

17012

2
1/15/2016
3/4/2016

1 6/5/2016
45
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

52527 24
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
7/15/2016
7/22/2016
1 6/5/2016

WRGB
Licensee,
LLC/WRGB,
Schenectady,
NY 0021268289

73942 7
1/16/2016
2/4/2016
2/13/2016
2/14/2016
2/17/2016
2/19/2016
2/26/2016

2
6/5/2016
7/24/2016
WRLH
Licensee,
LLC/WRLH-
TV, Richmond,
VA 0006551782

412

21
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/29/2016
5/2/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/17/2016
6/24/2016
6/28/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
46
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

73988 26
1/15/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

2
6/5/2016
7/23/2016
WSTQ
Licensee,
LLC/WSTM-
TV, Syracuse,
NY 0022491633

21252

6
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
3/4/2016

2
6/5/2016
7/24/2016

47
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

56549 24
1/22/2016
1/29/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/22/2016

2
6/5/2016
7/23/2016
WTOV
Licensee,
LLC/WTOV-
TV,
Steubenville,
OH 0022463913

74122 28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
48
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

22590 28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
WWMT
Licensee,
LLC/WWMT,
Kalamazoo, MI 0021268263

74195 27
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
49
Federal Communications Commission FCC 17-171
LICENSEE/
STATION1

414 21
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
WZTV
Licensee,
LLC/WZTV,
Nashville, TN 0006551758

418

1 6/5/2016
TOTALS NA NA 1,357 9 71

50
Federal Communications Commission FCC 17-171
NON-SINCLAIR STATIONS (AGREEMENT STATIONS)

LICENSEE/
STATION11

FRN12 FID # ON-AIR STORIES WITHOUT
SPONSORSHIP ID
LONG-FORM
PROGRAMS WITHOUT
SPONSORSHIP ID
LONG-FORM
PROGRAMS WITH
INCOMPLETE
SPONSORSHIP ID
Apparent
Violations
Broadcast Dates Apparent
Violations
Broadcast
Dates
Apparent
Violations
Broadcast
Dates

Second Generation of
Iowa, Ltd./KFXA,
Cedar Rapids, IA13 0004294120 35336 28
1/15/2016
1/22/2016
1/29/2016
2/5/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

6/5/2016

11 Third Supplemental Response, Exh. 3.
12 Id.
13 The station also apparently broadcast additional on-air stories on 1/15/2016, 1/29/2016, 3/2/2016, 3/30/2016, 4/13/2016, 4/22/2016, 5/4/2016, 7/2/2016,
7/9/2016, 7/16/2016, and 7/23/2016, and an additional long-form program on 7/23/2016. Second Supplemental Response; Third Supplemental Response, Exh. 5.
51
Federal Communications Commission FCC 17-171
LICENSEE/
STATION11

Waitt Broadcasting,
Inc./KMEG, Sioux
City, IA 0004957650 39665 27
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

KMTR Television,
LLC/KMTR, Eugene,
OR 0022745715 35189 28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
52
Federal Communications Commission FCC 17-171
LICENSEE/
STATION11

Sierra
Communications,
LLC14/KRNV-DT,
Reno, NV15 0018489757 60307 28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
HSH Flint (WEYI)
Licensee,
LLC/WEYI-TV,
Saginaw, MI16 0022522981 72052

1 6/5/2016

14 On September 27, 2017, the Media Bureau granted an application for the assignment of KRNV-DT’s license to Reno (KRNV-TV) Licensee, Inc., File No.
BALCDT-20131218CHO. Broadcast Actions, Public Notice, Report No. 49079 (MB Sept. 27, 2017), 2017 WL 4342102.
15 The station also apparently broadcast the long-form program on 7/24/2016. Third Supplemental Response, Exh. 5.
16 The station also apparently broadcast the long-form program on 7/23/2016. Id.
53
Federal Communications Commission FCC 17-171
LICENSEE/
STATION11

New Age Media of
Gainesville License,
LLC/WGFL, High
Springs, FL 0015435407 7727 20
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/15/2016
7/22/2016

Deerfield Media
(Rochester) Licensee,
LLC/WHAM-TV,
Rochester, NY 0022244495 73371 28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016
54
Federal Communications Commission FCC 17-171
LICENSEE/
STATION11

Deerfield Media
(Mobile) Licensee,
LLC/WPMI-TV,
Mobile, AL 0022238794 11906 13
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016

1 6/5/2016
Deerfield Media
(Cincinnati)
Licensee,
LLC/WSTR-TV,
Cincinnati, OH 0022238810 11204 16
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
3/18/2016
3/25/2016
4/8/2016
4/29/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
7/1/2016
7/8/2016
7/22/2016

WVAH Licensee,
LLC/WVAH-TV,
Charleston, WV 0007283054 417 28
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/27/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

55
Federal Communications Commission FCC 17-171
LICENSEE/
STATION11

WRGT Licensee,
LLC/WRGT-TV,
Dayton, OH17 0007282114 411 27
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/22/2016

1 6/5/2016
Columbus (WTTE-
TV) Licensee,
Inc./WTTE,
Columbus, OH18 0003778925 74137 26
1/22/2016
1/29/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016
3/11/2016
3/18/2016
3/25/2016
4/1/2016
4/8/2016
4/15/2016
4/22/2016
4/29/2016
5/6/2016
5/13/2016
5/20/2016
5/27/2016
6/3/2016
6/10/2016
6/17/2016
6/24/2016
7/1/2016
7/8/2016
7/15/2016
7/22/2016

1 6/5/2016

17 The station also apparently aired the long-form program on 7/24/2016. Third Supplemental Response, Exh. 5.
18 The station also apparently aired the long-form program on 7/24/2016. Id.
56
Federal Communications Commission FCC 17-171
LICENSEE/
STATION11

WTVH License
LLC/WTVH,
Syracuse, NY 0006583298 74151 8
1/15/2016
1/22/2016
1/29/2016
2/4/2016
2/12/2016
2/19/2016
2/26/2016
3/4/2016 1 6/5/2016

TOTALS NA NA 277 1 8
Federal Communications Commission FCC 17-171
57
STATEMENT OF
CHAIRMAN AJIT PAI

Re: Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748.

Today, the Federal Communications Commission proposes the largest forfeiture in the history of
this agency for a violation of our sponsorship identification rules. Indeed, the proposed forfeiture of over
$13 million is more than three times any penalty that has ever been imposed for violating our sponsorship
identification rules. Among other things, because of the seriousness of these violations, we have taken
the base forfeiture amount for each and every apparent violation of our rules at issue here and adjusted it
upward.
My dissenting colleagues, however, demanded that the Commission increase the amount of the
proposed forfeiture here by over six times, to more than $82 million. At no point, however, have they
cited a single Commission precedent involving sponsorship identification—or any precedent from any
other area for that matter—to justify their position. And a brief review of the Commission’s two most
recent sponsorship identification actions, both taken under the prior Administration, reveals how divorced
their demand is from past practice.
In 2016, the Enforcement Bureau and Cumulus entered into a consent decree to settle 178
violations of the Commission’s sponsorship identification rules. That consent decree involved a penalty
of $540,000, or approximately $3,000 per violation. And in 2014, the Enforcement Bureau and Journal
Broadcast Corporation entered into a consent decree to settle 27 violations of the Commission’s
sponsorship identification rules. That consent decree involved a penalty of $115,000, or approximately
$4,250 per violation.
In this Notice of Apparent Liability, we are proposing a forfeiture of $13,376,200 for 1,723
apparent violations of our sponsorship identification rules. That works out to over $7,700 per violation—
a significantly higher penalty per violation than in recent cases but one that is appropriate given the
factors spelled out in the Notice of Apparent Liability. By contrast, my colleagues have sought to propose
a forfeiture of $48,114 per violation, or 1,504% higher than the most recent penalty we’ve imposed.
Their position deviates so wildly from our precedent that it will no doubt strike reasonable people as
suspicious. But I will leave it to others to speculate as to why they wish to punish this particular company
in this particular way.

Federal Communications Commission FCC 17-171
58
DISSENTING STATEMENT OF
COMMISSIONER MIGNON L. CLYBURN

Re: Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748.

On first read, one might easily conclude that today’s enforcement action by the Republican-led
FCC represents a strong stand against a company with a history of skirting FCC rules. But take a closer
look: contrary to what the FCC majority would have you believe, the nearly $13.4 million fine levied
against Sinclair Broadcast Group represents a mere slap on the wrist.
Simply put, the ‘punishment does not fit the crime’ against a company that grossed more than
$2.7 billion in revenue last year.
What we are talking about is an egregious violation of the Commission’s rules by a company that
knows better. Specifically, this Notice of Apparent Liability (NAL) finds that Sinclair violated the FCC’s
sponsorship identification disclosure requirements more than 1,700 times – a well-known, well-
established rule intended to ensure viewers know the origin of the content they are viewing, including any
paid sponsorships. What makes today’s action noteworthy is that the FCC is more than willing to propose
fines in excess of $100 million against a single individual who may never pay. Yet when it comes to a
multi-billion-dollar company that misleads millions of viewers, the majority levies a fine that is just one-
sixth of the statutory maximum and represents 0.5% of the company’s 2016 revenues. For context, we
routinely fine companies between 3-8% of their gross revenues for egregious violations of our rules. Does
this mark yet another example of special treatment by the FCC majority? You decide.
We have seen violations of this nature before by this company. In 2007, Sinclair was fined
$36,000 after it aired programming on nine stations without disclosing that the commentator had ties to
the Department of Education’s No Child Left Behind program. And during the past decade and a half,
Sinclair has been fined at least eight additional times, totaling almost $10 million for various violations,
including of the Children’s Television Rules. In 2001 the company was fined $40,000 for illegally
exercising control of its business partner Glencairn Ltd. Most recently, in 2016, the FCC reached a
consent decree with Sinclair for nearly $9.5 million after it was found to have violated its obligation to
negotiate in good faith when they engaged in prohibited joint retransmission consent negotiations.
The facts in this case are clear: Sinclair willfully and repeatedly violated the Commission’s
sponsorship identification rules. The NAL notes in fact, that “there are few, if any, actual disputes about
the key facts associated with the apparent violations.”
For all the above reasons, while I agree with the FCC acting against Sinclair for violating the
FCC’s rules, I dissent because of such a meager fine, which fails to match the scope and egregious nature
of the violations that were committed.

Federal Communications Commission FCC 17-171
59
STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY

Re: Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748.

While I generally don’t comment on the Commission’s issuance of a Notice of Apparent Liability
done via circulation, it seems appropriate and necessary to do so in this instance.
With this item, the Commission proposes a forfeiture of more than $13 million for a violation of
our sponsorship identification rules—the largest penalty the Commission has proposed for such a
violation. This figure was calculated by taking the base forfeiture amount for each apparent violation, and
then upwardly adjusting it. At this point in the process, this seems like stern but fitting action, as the
Commission considered several factors and determined that they did not warrant downward adjustment,
including the fact that it appears that the failure to disclose this information was unintentional, the content
in question involved a cancer institute, some incomplete disclosures were provided, and Sinclair took
corrective measures, including publicly acknowledging and apologizing for its failure to provide
sponsorship identification through a five-week series of announcements in October 2016.
Our action is consistent with how the Commission has assessed forfeitures for sponsorship
identification violations in the past: by multiplying the base forfeiture by the number of violations and
then adjusting the fine upward or downward based on the unique facts of the case. In fact, this is
precisely what the previous Commission did under similar circumstances.
I look forward to reading any response from the affected party and reaching a conclusion in this
enforcement matter.
Federal Communications Commission FCC 17-171
60
STATEMENT OF
COMMISSIONER BRENDAN CARR

Re: Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748.

The FCC’s sponsorship identification rules require every broadcaster that airs paid programming
to include both an announcement that the broadcaster was paid to run the program and a statement that
identifies the sponsor of the program. These rules provide important consumer protections by ensuring
that the public can distinguish paid programming from independently-generated content. They also
prevent companies from gaining a commercial advantage by purchasing sponsored content that is not
identified as such. Today, we advance these goals by proposing the largest fine in the history of the
agency for a violation of our sponsorship identification rules.
In this case, as in all matters, our obligation is to apply the law to the facts. At this stage in our
proceeding, the facts indicate that Sinclair failed to comply with our sponsorship identification rules when
it aired paid programming regarding the Huntsman Cancer Institute. While the base forfeiture in this case
would have resulted in a proposed fine in excess of $6 million, I agree that the totality of the
circumstances warrant a significant upward adjustment. I therefore support the proposal to fine Sinclair
over $13 million for these apparent violations. Doing so is consistent with the law and the facts.
Federal Communications Commission FCC 17-171
61
DISSENTING STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL

Re: Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748.

Take note of 1,723. This is the extraordinary number of violations by Sinclair Broadcasting at
issue in this enforcement action. What this means is that over the course of roughly six months last year,
Sinclair Broadcasting aired sponsored pay-for-play programming on 77 different stations 1,723 times.
Some of this content was dressed up like real news but made no mention of who paid for it to be put on
the air. In an era where true facts too often are derided as fake news, this behavior is troubling.
Moreover, it is a clear violation of Sections 317 and 507 of the Communications Act, as well as Section
73.1212 of the Commission’s rules.
The unprecedented volume of these violations deserves an unprecedented response. But instead
of seeking the maximum fine allowable under our rules, this notice cuts the company a break. In fact, the
fine that is proposed amounts to only .5 percent of its revenue last year and only .3 percent of the value of
the merger it currently has pending before this agency.
Moreover, this is a company with a history of flouting statutory requirements under the
Communications Act and Children’s Television Act. These violations include a 2000 Forfeiture Order
for Station WBFF, a 2001 Notice of Apparent Liability for Forfeiture for unauthorized transfer of control
of several broadcast television stations, a 2007 Forfeiture Order for Station KOCB; a 2008 Forfeiture
Order for Station WZTV, a 2009 Notice of Apparent Liability for Forfeiture for Station WUCW, a 2010
Notice of Apparent Liability for Station WLOS, a 2010 Notice of Apparent Liability for Station KRRT-
TV, a 2010 Forfeiture Order for Station WVTV, and a 2014 Letter of Admonishment issued for Station
KVCW. Moreover, last year, Sinclair Broadcasting paid $9.49 million to settle investigations into the
company’s retransmission negotiation practices and related issues, just days after they broke the rules
they are being held accountable for today.
In light of this substantial history of failure to comply with our policies and the sheer number of
violations before the agency now, the immediate notice should seek the highest fines permissible under
our rules. But instead of doing so, we offer unreasonable and suspicious favor to a company with a clear
record of difficulty complying with the law. Because I think the fine here falls short of what is warranted,
I respectfully dissent.