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Federal Communications Commission DA 18- 322
Before the
Federal Communications Commission
Washington, DC 20554 
In the Matter of
Full Spectrum, Inc.
  )
  )
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  )
  
File No.:  EB-FIELDWR-17-00024047
NAL/Acct. No.:  201832030002 
FRN:  0017129206
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted:  March 30, 2018 Released:  March 30, 2018
By the Regional Director, Region Three, Enforcement Bureau:
I. INTRODUCTION
1. We propose a penalty of $22,000 against Full Spectrum, Inc. (Full Spectrum), for 
apparently willfully and repeatedly causing harmful interference to over 200 Verizon Wireless base 
stations in San José, California, operating radio transmission equipment without a license on frequencies 
785 MHz – 790 MHz, and operating radio frequency equipment without a Federal Communications 
Commission (FCC or Commission) equipment authorization.  We take this enforcement action because 
unlicensed radio operations impede the Commission’s responsibility to manage radio spectrum and 
because the unlicensed radio operations and unauthorized radio frequency equipment can cause harmful 
interference to licensed radio communications.
II. BACKGROUND
2. On April 4, 2017, a representative from Verizon Wireless
1
 contacted the FCC 
Enforcement Bureau’s San Francisco regional office (San Francisco Office) and requested assistance to 
resolve an interfering signal Verizon Wireless observed being transmitted on the uplink channel of its 
700 MHz band licensed spectrum.  Specifically, Verizon Wireless stated that, starting on March 27, 2017, 
its engineers observed an unknown signal transmitting in the 776 MHz – 787 MHz C Block Upper 
700 MHz band service in which Verizon Wireless is the sole licensee, and the signal affected all of 
Verizon Wireless’s base stations in the South Bay, which are concentrated around the east side of 
San José, California.
3. On April 5, 2017, two agents from the San Francisco Office, used a mobile direction-
finding vehicle to locate the source of the alleged interference.  The agents observed a wide band signal 
transmitting on 785 MHz to 790 MHz and traced the signal to an antenna secured to a pole next to a water 
tank located on a hill at 15815 Mt. Hamilton Road, San José, California (Mt. Hamilton Road Property).
2
1
 Verizon Wireless is the wireless communications products and services segment of Verizon Communications, Inc.  
See Verizon Communications 2016 Annual Report at 11, 
http://www.verizon.com/about/sites/default/files/annual_reports/2016/downloads/Verizon-AnnualReport2016.pdf 
(last visited Mar. 14, 2018).
2
 The agents observed a Yagi antenna, which is a directional antenna (i.e., it (i) must be pointed directly at a signal 
source for peak performance, (ii) has a high gain, typically greater than 10 dB, and (iii) consists of multiple parallel 
elements in a line, usually half-wave dipoles made of metal rods).  See The Yagi-Uda Antenna, ANTENNA-
THEORY.COM, http://www.antenna-theory.com/antennas/travelling/yagi.php (last visited Feb. 1, 2018); see also, 
(continued….)
Federal Communications Commission DA 18-322
2
4. While walking on the property, the agents used a hand-held spectrum analyzer with a 
directional antenna; and when pointing it towards the water tank, they confirmed the peak of the 
interfering signal corresponded to the antenna located next to the water tank.  The agents observed the 
antenna cable led into a building and connected to a Cobalt-Plus, model CP-1000 radio (Cobalt Radio).  
Later that day, the agents returned to the Mt. Hamilton Road Property and interviewed the property 
manager who identified Full Spectrum, Inc. (Full Spectrum)
3
 as the owner of the Cobalt Radio.  At the 
agent’s request, the property manager turned off the Cobalt Radio and the agent, using the spectrum 
analyzer, confirmed the interfering transmission had ceased.
5. The agents hand-delivered a Warning of Interference notice to the property manager 
advising him they observed interference on 777 MHz – 787 MHz.
4
  The notice also instructed him to 
review the station’s operations to ensure the interference ceases and advised that failure to take corrective 
action could result in the Commission issuing additional sanctions or forfeitures.
5
  The agents then called 
the Verizon Wireless representative who made the initial complaint, and the representative confirmed the 
interference had ceased.
6. On the evening of April 5, 2017, Stewart Kantor, CEO of Full Spectrum, contacted one 
of the FCC agents in follow-up to the inspection.  Mr. Kantor confirmed the property manager gave him 
the Warning of Interference; and he explained to the agent that the Cobalt Radio devices “were designed 
to operate within a 1 MHz channel in the Upper 700 MHz A Block (787 MHz – 788 MHz) with a center 
frequency of 787.5 MHz.”
6
  Mr. Kantor also said the Cobalt Radio had been removed from the property to 
determine the cause of the out-of-band emissions.  When asked whether the radio had been certified by 
the FCC, Mr. Kantor stated that Full Spectrum had designed the unit and obtained an FCC identification 
number, but had not printed or placed the FCC certification label on the Cobalt Radio.
7
  The agent 
requested that Mr. Kantor submit documents demonstrating that the FCC certified the radio.
7. On April 6, 2017, Mr. Kantor followed up his call with an email to the FCC agent.  In the 
email, Mr. Kantor explained that Full Spectrum “had been operating [the Cobalt] [R]adio for several 
months in a 500 kHz channel in the Upper 700 MHz A Block (757 MHz – 758 MHz, 787 MHz – 
788 MHz) without causing known interference.”
8
  Mr. Kantor also stated that Full Spectrum inspected the 
Cobalt Radio and discovered that a technician mistakenly configured the Cobalt Radio to “a 5 MHz 
channel size versus a 500 kHz channel at the same center frequency of 787.5 MHz,”
9
 thereby causing the 
radio to transmit over a wider bandwidth, including spectrum outside of the Upper 700 MHz A Block.  
(Continued from previous page)  
What is a Yagi Antenna, WEBOOST.COM, https://blog.weboost.com/news/blog/what-is-a-yagi-antenna-and-how-does-
it-work/ (last visited Feb. 1, 2018).
3
 Full Spectrum, Inc. is Delaware corporation that is a supplier of private broadband cellular data network 
technology and, also designs, develops, manufactures, and sells its Software Defined Radio technology to 
companies in the utilities, defense, oil & gas, and transportation industries.  See Full Spectrum, About Us, 
http://www.fullspectrumnet.com/background/; see also, Bloomberg, Company Overview of Full Spectrum, Inc., 
https://www.bloomberg.com/research/stocks/private/snapshot.asp?privcapId=60309355 (last visited Feb. 1, 2018).
4
 Warning of Interference hand-delivered to Mt. Hamilton Road Property Manager (Apr. 5, 2017) (on file in EB-
FIELDWR-17-00024047). 
5
 Id.
6
 Email from Stewart Kantor, CEO, Full Spectrum, Inc., to FCC Field Agent, (Apr. 5, 2017, 5:23 p.m.) (on file in 
EB-FIELDWR-17-00024047).
7
 See Investigation Notes (on file in EB- FIELDWR-17-00024047).
8
 Email from Stewart Kantor, CEO, Full Spectrum, Inc., to FCC Field Agent, (Apr. 6, 2017, 6:19 p.m.) (on file in 
EB-FIELDWR-17-00024047).
9
 Id.
Federal Communications Commission DA 18-322
3
Further, Mr. Kantor explained that Full Spectrum uses the Mt. Hamilton Road Property “as a test site on 
behalf of its electric utility customers,” and had “authorization to operate a variety of frequencies for test 
purposes.”
10
  He also provided an Internet link to electronic documents demonstrating Full Spectrum had 
obtained FCC certification for several of its other radio devices.  Finally, Mr. Kantor assured the agent 
that Full Spectrum would not sell the new radio until the certification process was complete.
11
8. The agent reviewed the documentation that Full Spectrum provided and found that it did 
not include any information indicating the FCC had certified the Cobalt Radio.  On May 9, 2017, the 
agent informed Mr. Kantor that the correct information was not submitted, and requested Full Spectrum 
to submit the certification for the Cobalt Radio,
12
 as well as Full Spectrum’s license authorizing it to 
operate on 776 MHz – 787 MHz.
13
  On May 9, Mr. Kantor responded that he would send the information 
as soon as possible.
14
  On May 23, 2017, the agent sent a follow-up email, again, requesting copies of Full 
Spectrum’s license and equipment certification.
15
9. Full Spectrum did not produce either.  With regard to a license, on May 24, 2017, rather 
than submitting a copy of its license, Mr. Kantor provided a copy of an April 2015 letter from BPC 
Spectrum, LLC (BPC Spectrum), the licensee of the Upper 700 MHz A band (757 MHz – 758 MHz and 
787 MHz – 788 MHz), in which it granted Full Spectrum permission to conduct testing on their 
frequencies at the Mt. Hamilton Road Property for two months beginning April 10, 2015.
16
  The letter, 
however, was signed only by Mr. Kantor and not by BPC Spectrum’s representative.
17
  In a follow-up 
email dated May 26, 2017, Full Spectrum claims it had permission to use BPC Spectrum’s frequencies 
until April 18, 2016.
18
  The May 26, 2017, email includes an April 12, 2016, email from BPC Spectrum 
advising Full Spectrum to discontinue using BPC’s Spectrum License before April 18, 2016, because 
BPC Spectrum had a pending contract to transfer control of its 700 MHz licenses to CaHRA. The 
Commission’s Universal Licensing System shows no record of a spectrum lease from BPC Spectrum to 
Full Spectrum.
10. With regard to an equipment certification, Mr. Kantor informed the agent that Full 
Spectrum completed the FCC authorization process for the Cobalt Radio at the Bay Area Compliance 
Laboratory.
19
  Mr. Kantor, however, did not produce a certification from the FCC for the Cobalt Radio to 
substantiate his claims.
10
 Id.
11
 Id.
12
 Email from FCC Field Agent to Stewart Kantor, CEO, Full Spectrum, Inc. (May 9, 2017, 11:23 a.m.) (on file in 
EB-FIELDWR-17-00024047).
13
 Id. at May 9, 2017, 12:22 p.m. (on file in EB-FIELDWR-17-00024047).
14
 Email from Stewart Kantor, CEO, Full Spectrum, Inc., to FCC Field Agent (May 9, 2017, 1:07 p.m.) (on file in 
EB-FIELDWR-17-00024047).
15
 Email from FCC Field Agent to Stewart Kantor, CEO, Full Spectrum, Inc. (May 23, 2017, 8:47 a.m.) (on file in 
EB-FIELDWR-17-00024047).
16
 Email from Stewart Kantor, CEO, Full Spectrum, Inc., to FCC Field Agent, (May 24, 2017, 8:13 p.m.) (May 24 
Email) (on file in EB-FIELDWR-17-00024047).  Mr. Kantor told the agent that BPC Spectrum sold its spectrum to 
the California High-Speed Rail Authority (CaHRA) on March 5, 2016, but Full Spectrum had not reached yet an 
agreement with CaHRA to continue using the spectrum.  Id.
17
 See May 24 Email, at Attachment.
18
 Email from Stewart Kantor, CEO, Full Spectrum, Inc., to FCC Field Agent, (May 26, 2017, 1:31 p.m.) (on file in 
EB-FIELDWR-17-00024047).  See Email from Robert Finch, Beach Point Capital to Stewart Kantor, Full Spectrum 
(Apr. 12, 2016, 6:33 a.m.) (on file in EB-FIELDWR-17-00024047).
19
 May 24 Email.
Federal Communications Commission DA 18-322
4
11. On August 11, 2017, the Enforcement Bureau’s Los Angeles Regional Office issued a 
Notice of Unlicensed Operation (NOUO) to Full Spectrum advising the Company that operation of the 
Cobalt Radio was found to have caused interference to Verizon Wireless C Block Upper 700 MHz 
spectrum, affecting over 200 Verizon Wireless base stations in San Jose, California.
20
  In addition, the 
NOUO notified Full Spectrum that it must have a station license to operate the Cobalt Radio on the 
776 MHz – 787 MHz frequency band as required by Section 301 of the Communications Act of 1934, as 
amended (Act), and that the Cobalt Radio at issue had no label with an FCC ID and was not FCC-
certified as required by Section 27.51(a) of the Commission’s rules.
21
12. On August 18, 2017, Full Spectrum responded to the NOUO, reiterating that its operation 
on 785 MHz – 790 MHz was inadvertent due to installer error and that, upon learning about the resulting 
interference, it ceased operations.
22
  In addition, Full Spectrum stated that its previous authority to operate 
on the subject frequencies had expired.
23
  Moreover, Full Spectrum stated it would not resume operations 
until it obtained authorization from the current licensee and corrected the error in the radio 
configuration.
24
  Full Spectrum also indicated the Cobalt Radio had been certified under FCC ID X27FS-
CP757787.
25
  A review of the Commission’s Office of Engineering and Technology Equipment 
Authorization database shows the Cobalt Radio was certified for use, but not until July 6, 2017.
26
III. DISCUSSION
13. We find that Full Spectrum, by its own admissions, apparently willfully and repeatedly 
violated Section 301 of the Act and Sections 1.903(a), 2.805(a), and 27.51(a) of the Commission’s rules.  
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.
27
  Section 1.903(a) of the Commission’s rules requires that stations in the Wireless Radio 
Services
28
 must be used and operated only in accordance with the rules applicable to their particular 
service and with a valid authorization granted by the Commission.
29
  Section 2.805(a) requires radio 
frequency equipment to be authorized by the Commission prior to operation.
30
  Section 27.51(a) of the 
Commission’s rules provides that each transmitter utilized for operation must be of the type that has been 
authorized by the Commission under its certification procedure.
31
 
20
 Notice of Unlicensed Operation to Stewart Kantor, San Jose, CA (dated Aug. 11, 2017) (on file in EB-FIELDWR-
17-00024047).
21
 Id.
22
 Response to the Notice of Unlicensed Operation from Stewart Kantor to Lark Hadley, Regional Director, Region 
Three, Enforcement Bureau (dated Aug. 18, 2017) (on file in EB-FIELDWR-17-00024047).
23
 Id.
24
 Id.
25
 Id.
26
 See Office of Engineering and Technology Equipment Authorization Database, https://ebats.fcc.gov/ebats-
appfiles/documents/FCC_OET_TCB_Electronic_Fi_ijcm2vrusg.pdf.
27
 47 U.S.C. § 301.
28
 The term “Wireless Radio Services” is defined as including wireless communications services authorized under 
Part 27 of the Commission’s rules, therefore encompassing frequencies 785 MHz – 790 MHz.  47 CFR § 1.907.
29
 Id. § 1.903(a).
30
 Id. § 2.805(a).
31
 Id. § 27.51.
Federal Communications Commission DA 18-322
5
A. Full Spectrum is Apparently Liable for Causing Harmful Interference to Verizon 
Wireless’s Upper 700 MHz C Block Service in San José, California 
14. Full Spectrum apparently willfully and repeatedly violated Section 301 of the Act by 
causing harmful interference to a licensed operator.  Section 301 requires that a person or entity shall not 
use or operate a device to transmit a broadcast signal when such use or operation causes interference.
32
  
As discussed above, on April 5, 2017, agents from the San Francisco Office determined by radio 
direction-finding techniques that the Cobalt Radio was the source of unauthorized transmissions that 
caused harmful interference to the Verizon Wireless 776 MHz – 787 MHz C Block Upper 700 MHz band 
service, affecting over 200 Verizon Wireless base stations in San José, California from March 27, 2017, 
to April 5, 2017.  Verizon Wireless confirmed the unauthorized transmissions ceased immediately when 
Full Spectrum shut off the radio at 15815 Mt. Hamilton Road.  Moreover, as discussed above, Full 
Spectrum admitted that “one of [its] technicians mistakenly misconfigured the radio to transmit over a 
wider bandwidth than intended,” partially overlapping the adjacent licensee, Verizon Wireless’s, 
channel.
33
  Therefore, based on the record before us, Full Spectrum apparently willfully and repeatedly 
violated Section 301 of the Act.
B. Full Spectrum is Apparently Liable for Operating in the Upper 700 MHz Spectrum 
Band without Commission Authorization 
15. Full Spectrum apparently willfully and repeatedly violated Section 301 of the Act and 
Section 1.903(a) of the Commission’s rules by operating in the 700 MHz band without a valid 
Commission authorization.  Section 301 of the Act requires that, in order to transmit a radio frequency 
signal, a person must first obtain and hold a valid authorization from the Commission.
34
  Section 1.903(a) 
of the Commission’s rules requires Full Spectrum to have a valid license for the 776 MHz – 787 MHz 
band before it began transmitting in this frequency range.
35
  As detailed above, Full Spectrum did not 
have a Commission license to operate on this spectrum before it began its transmissions.  Nor did it have 
a spectrum lease.
36
  Moreover, even if Full Spectrum had a basis for thinking it had a valid spectrum lease 
with BPC Spectrum, Full Spectrum admitted that its purported authority to operate in this frequency band 
would have terminated on April 18, 2016, almost a year before the transmissions as issue.
37
  Finally, Full 
Spectrum’s assertion that it had been “operating [the radio for several months without causing any known 
interference”
38
 does not excuse its failure to have a license to operate in the first place.  Rather, Full 
32
 47 U.S.C. § 301.
33
 As the Commission has repeatedly held, violations resulting from inadvertent error or failure to become familiar 
with the FCC’s requirements can be and often are willful violations.  See Acumen Commc’ns, Forfeiture Order, 30 
FCC Rcd 6472, 6475 (2015) citing Emery Telephone, Memorandum Opinion and Order, 13 FCC Rcd 23854, 23859, 
para. 12 (1998) (by issuing forfeitures for inadvertent violations corrected after the fact, “the Bureau impels 
licensees to be more familiar with the applicable rules in structuring future conduct”), recon. dismissed in part and 
denied in part, Memorandum Opinion and Order, 15 FCC Rcd 7181 (1999).
34
 47 U.S.C. § 301.
35
 47 CFR § 1.903(a).
36
 See supra para. 9.
37
 In the August 10, 2015, letter agreement, BPC Spectrum, LLC attempted to grant Full Spectrum authority to test 
the performance of its type accepted FullMax radios within the South Bay Area of Silicon Valley “in accordance 
with Section 2.803(e)(3)(iii) of the FCC’s rules.”  We note the referenced section was not a valid section within Title 
47 of the Code of Federal Regulations when the contract was executed.  Notwithstanding, Full Spectrum was not 
authorized to operate in the Upper 700 MHz A Block because (i) the letter agreement expired and, (ii) the licensee 
never filed the leasing arrangement with the Commission as required by Section 1.9020(e) of the Commission’s 
rules.  Id. § 1.9020(e).
38
 See supra note 5.
Federal Communications Commission DA 18-322
6
Spectrum operated without a required instrument of authorization for at least the period of March 27, 
2017, to April 5, 2017.  Therefore, based on the record before us, we determine that Full Spectrum 
apparently willfully and repeatedly violated Section 301 of the Act and Section 1.903(a) of the 
Commission’s rules.
39
C. Full Spectrum is Apparently Liable for Use of Unauthorized Radio Frequency 
Equipment
16. Full Spectrum apparently operated unauthorized radio equipment in violation of the 
Commission’s rules.  Section 2.805(a) of the Commission’s rules provides in relevant part that, except in 
a few narrow circumstances not pertinent here, “[a] radio frequency device may not be operated prior to 
equipment authorization.”
40
  In addition, Section 27.51(a) of the Commission’s rules requires radio 
frequency devices operating in Wireless Communications Services frequencies under Part 27 of the 
Commission’s rules to be authorized in accordance with the Commission’s certification procedures.
41
  
Despite repeated requests by the agent for Full Spectrum to produce the authorization documentation 
specific to the Cobalt Radio, Full Spectrum could not do so.  Instead, Full Spectrum said it had completed 
the FCC authorization process at the Bay Area Compliance Laboratory.  This, however, is not the same as 
gaining certification from the Commission.  More importantly, according to OET’s Equipment 
Authorization database, the Cobalt Radio was not certified until July 6, 2017, four months after the 
operations at issue.  Because Full Spectrum operated an unauthorized device from at least 
March 27, 2017, through April 5, 2017, we find Full Spectrum apparently willfully and repeatedly 
violated Sections 2.805(a) and 27.51(a) of the Commission’s rules.
42
D. Proposed Forfeiture Amount
17. Section 503(b) of the Act authorizes the Commission to impose a forfeiture against any 
entity that willfully or repeatedly fails to comply substantially with the terms and conditions of any 
license, or willfully or repeatedly fail[s] to comply with any of the provisions of [the Act] or of any rule, 
regulation, or order issued by the Commission.”
43
  Here, Section 503(b)(2)(D) of the Act authorizes us to 
assess a forfeiture against Full Spectrum of up to $19,639 for each day of a continuing violation, up to a 
statutory maximum of $147,290 for a single act or failure to act.
44
  In exercising our forfeiture authority, 
39
 Section 312(f)(1) of the Act defines “willful” as the “conscious and deliberate commission or omission of [any] 
act, irrespective of any intent to violate” the law.  47 U.S.C. § 312(f)(1).  The Commission may also assess a 
forfeiture for violations that are merely repeated, and not willful.  See e.g., Callais Cablevision, Inc., Notice of 
Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359, 1362, para. 10 (2001) (proposing a forfeiture for, 
inter alia, a cable television operator’s repeated signal leakage) (Callais Cablevision), Forfeiture Order, 17 FCC Rcd 
22626 (2002).  The term “repeated” means the commission or omission of such act more than once or for more than 
one day.  See 47 U.S.C. § 312(f)(2); Callais Cablevision, 16 FCC Rcd at 1362, para. 9.
40
 47 CFR § 2.805(a).
41
 Id. § 27.51(a).
42
 We also remind Full Spectrum that the Commission prohibits licensees and regulatees from marketing uncertified 
radio frequency equipment.  Section 2.803(g) of the Commission’s rules provides, in pertinent part, that “radio 
frequency devices that could not be authorized or legally operated under the current Rules...shall not be operated, 
advertised, displayed, offered for sale or lease, sold or leased, or otherwise marketed absent a license issued under 
part 5 of this chapter or a special temporary authorization issued by the Commission.”  Id. § 2.803(g).
43
 47 U.S.C. § 503(b).
44
 See 47 U.S.C. § 503(b)(2)(D); 47 CFR §§ 1.80(b)(7), (9).  The Federal Civil Penalties Inflation Adjustment Act of 
1990, as amended, requires agencies, starting in 2017, to adjust annually the civil monetary penalties covered 
thereunder, and to publish each such annual adjustment by January 15 of each year.  28 U.S.C. § 2461 note, citing 
the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended, § 4(a).  See also 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 
(continued….)
Federal Communications Commission DA 18-322
7
Section 503(b)(2)(E) requires that we consider the “nature, circumstances, extent, and gravity of the 
violation and, with respect to the violator, the degree of culpability, any history of prior offenses, ability 
to pay, and such other matters as justice may require.”
 
45
  In addition, the Commission has established 
forfeiture guidelines that establish base penalties for certain violations and identify criteria that we 
consider when determining the appropriate penalty in any given case.
46
18. Pursuant to the Commission’s Forfeiture Policy Statement and Section 1.80(b) of the 
Commission’s rules, the base forfeiture amount for operations without an instrument of authorization for 
the service is $10,000, the base forfeiture amount for harmful interference to radio communications is 
$7,000, and the base forfeiture for using unauthorized equipment is $5,000.  As detailed above, we find 
that Full Spectrum is apparently liable for each of these violations.  Accordingly, we propose a total base 
forfeiture of $22,000.
19. In addition, the Commission has identified criteria under which we may adjust a 
forfeiture upward for violations that are egregious, intentional, or repeated, or that cause substantial harm 
or generate substantial economic gain for the violator, or where there are prior violations of any FCC 
requirements.
47
  In applying the applicable statutory factors, we also consider whether there is any basis 
for a downward adjustment of the proposed forfeiture.
48
  Based on the facts of this case, we decline to 
propose either an upward or downward adjustment.  Therefore, after applying the Forfeiture Policy 
Statement, Section 1.80 of the Commission’s rules, and the statutory factors, as well as considering the 
facts in this case, we propose a total forfeiture of $22,000 for which Full Spectrum is apparently liable.
IV. CONCLUSION
20. We have determined that Full Spectrum apparently willfully and repeatedly violated 
Section 301 of the Act and Sections 1.903(a), 2.805(a), and 27.51(a) of the Commission’s rules.
49
  
Accordingly, we find Full Spectrum is apparently liable for a total forfeiture of $22,000.
V. ORDERING CLAUSES
21. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act
50
 and Section 
1.80 of the Commission’s rules,
51
 Full Spectrum, Inc. is hereby NOTIFIED of this APPARENT 
LIABILITY FOR A FORFEITURE in the amount of Twenty-Two Thousand dollars ($22,000) for 
willful and repeated violations of Section 301 of the Act, and willful and repeated violations of Sections 
1.903(a), 2.805(a), and 27.51(a) of the Commission’s rules.
52
(Continued from previous page)  
Improvements Act of 2015, M-17-11, Dec. 16, 2016 at 1.  The Bureau released the order making the 2018 annual 
adjustment on January 5, 2018.  See Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment of Civil 
Monetary Penalties to Reflect Inflation, Order, DA 18-12 (EB 2018), 2018 WL 305640.  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.
45
 47 U.S.C. § 503(b)(2)(E).
46
 47 CFR § 1.80(b)(8), Note to paragraph (b)(8). 
47
 Id.
48
 Id.
49
 47 U.S.C. § 301; 47 CFR §§ 1.903(a), 2.805(a), and 27.51(a).
50
 47 U.S.C. § 503(b).
51
 47 CFR § 1.80.
52
 47 U.S.C. § 301.
Federal Communications Commission DA 18-322
8
22. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Commission’s rules,
 
within thirty (30) calendar days of the release date of this Notice of Apparent Liability for Forfeiture, Full 
Spectrum, 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 paragraphs 25 and 
26 below.
23. 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.  Full Spectrum, Inc., 
shall send electronic notification of payment to Field@fcc.gov and Joy.Ragsdale@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.
53
  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.
24. 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.
54
  Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by phone, 1-877-480-3201, or by e-mail, 
ARINQUIRIES@fcc.gov. 
25. The written statement seeking reduction or cancellation of the proposed forfeiture, if any, 
must include a detailed factual statement supported by appropriate documentation and affidavits pursuant 
to Sections 1.16 and 1.80(f)(3) of the Commission’s rules.
55
  The written statement must be mailed to the 
Office of the Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, DC 
20554, ATTN: Joy M. Ragsdale, Enforcement Bureau, Field Counsel, and must include the 
NAL/Account Number referenced in the caption.  The statement must also be e-mailed to Field@fcc.gov 
and Joy M. Ragsdale, joy.ragsdale@fcc.gov.
26. The Commission will not consider reducing or canceling a forfeiture in response to a 
claim of inability to pay unless the petitioner submits: (1) federal tax returns for the most recent three-
year period; (2) financial statements prepared according to generally accepted accounting practices; or (3) 
some other reliable and objective documentation that accurately reflects the petitioner’s current financial 
53
 A copy of an FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
54
 See 47 CFR § 1.1914.
55
 Id. §§ 1.16, 1.80(f)(3).
Federal Communications Commission DA 18-322
9
status.  Any claim of inability to pay must specifically identify the basis for the claim by reference to the 
financial documentation.  
27. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by both certified mail, return receipt requested, and regular mail to Stewart Kantor, 
CEO, Full Spectrum, Inc., 687 N. Pastoria Avenue, Sunnyvale, California 94085.
FEDERAL COMMUNICATIONS COMMISSION
Lark Hadley
Regional Director
Region Three
Enforcement Bureau