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Federal Communications Commission DA 18-334
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Boyce Industries, Inc.
d/b/a VISIONTECH
)
)
)
)
)
File No.:  EB-SED-17-00024684
Acct. No.:  201832100008 
FRN:  0027389345 
ORDER
Adopted:  April 20, 2018 Released:  April 20, 2018
By the Acting Deputy Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission has 
entered into a Consent Decree to resolve its investigation into whether Boyce Industries, Inc. d/b/a 
VISIONTECH (Boyce) marketed LED signs used in digital billboards and other commercial and 
industrial applications, without the required equipment authorization, labeling, and user manual 
disclosures in violation of the Commission’s rules.  These rules ensure that radio-frequency devices 
marketed in the United States do not interfere with authorized communications, thereby maintaining 
network integrity and security and protecting consumers.  To settle this matter, Boyce admits that it 
marketed LED signs without the required equipment authorization, labeling, and user manual disclosures, 
will implement a compliance plan, and will pay an $39,500 civil penalty.
2. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
referenced investigation regarding Boyce’s compliance with equipment authorization, labeling and user 
manual disclosure rules in effect at the time of the violation, Section 302(b) of the Communications Act 
of 1934, as amended (Act)
1
, and Sections 2.803, 2.955, 15.19, 15.21, 15.101, and 15.105 of the 
Commission’s rules.
2
3. In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of Boyce’s basic qualifications to hold or obtain any Commission license or authorization.
3
4. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act
4
 and the 
authority delegated by Sections 0.111 and 0.311 of the Rules,
5
 the attached Consent Decree IS 
ADOPTED and its terms incorporated by reference.
5. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED.
1
 47 U.S.C. § 302a(b).
2
 47 CFR §§ 2.803, 2.955, 15.19, 15.21, 15.101, and 15.105 (2017).  Some of the rules in effect at the time the 
violations occurred were subsequently amended.  The new rules became effective on November 2, 2017.  See 
Amendment of Parts 0, 1, 2, 15, and 18 of the Commission’s Rules regarding Authorization of Radiofrequency 
Equipment, Report and Order, 32 FCC Rcd 8746 (July 2017).
3
 See 47 CFR § 1.93(b).
4
 47 U.S.C. § 154(i).
5
 47 CFR §§ 0.111, 0.311.
Federal Communications Commission DA 18-334
2
6. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Vernon Boyce, President, Boyce 
Industries, Inc.2340 N. Tyler Avenue, Springfield, MO 65803 and to Glenn S. Richards, Partner, 
Pillsbury Winthrop Shaw Pittman LLP, 1200 Seventeenth Street, NW, Washington, DC 20036-3006.
FEDERAL COMMUNICATIONS COMMISSION
Christopher L. Killion
Acting Deputy Chief 
Enforcement Bureau
Federal Communications Commission DA 18-334
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Boyce Industries, Inc.
d/b/a VISIONTECH
)
)
)
)
)
)
)
File No.:  EB-SED-17-00024684
Acct. No.:  201832100008 
FRN:  0027389345 
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Boyce 
Industries, Inc. d/b/a VISIONTECH (Boyce) by their authorized representatives, hereby enter into this 
Consent Decree for the purpose of terminating the Enforcement Bureau’s investigation into whether 
Boyce violated Section 302(b) of the Communications Act of 1934,
1
 as amended (Act), and Sections 
2.803, 2.955, 15.19, 15.21, 15.101, and 15.105 of the Commission’s rules.
2
 
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended.
3
(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(d) “Boyce” or “Company” means Boyce Industries, Inc. d/b/a VISIONTECH and its 
affiliates, subsidiaries, predecessors-in-interest, and successors-in-interest.
(e) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.
(f) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Boyce is subject 
by virtue of its business activities, including but not limited to the Equipment 
Authorization and Marketing Rules.
(g) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 13.
(h) “Covered Employees” means all employees and agents of Boyce who perform, or 
supervise, oversee, or manage the performance of, duties that relate to Boyce’s 
1
 47 U.S.C. § 302a(b).
2
 47 CFR §§ 2.803, 2.955, 15.19, 15.21, 15.101, and 15.105.  Some of the rules in effect at the time the violations 
occurred were subsequently amended and became effective on November 2, 2017.  See Amendment of Parts 0, 1, 2, 
15, and 18 of the Commission’s Rules regarding Authorization of Radiofrequency Equipment, Report and Order, 32 
FCC Rcd 8746 (July 2017) (Equipment Authorization Order).  This settlement resolves the rule violations listed in 
para. 1 of this Consent Decree and sets forth obligations for compliance with the current rules.
3
 47 U.S.C. § 151 et seq.
Federal Communications Commission DA 18-334
2
responsibilities under the Communications Laws, including the Equipment 
Authorization and Marketing Rules.
(i) “Effective Date” means the date by which both the Bureau and Boyce have signed 
the Consent Decree.
(j) “Equipment Authorization and Marketing Rules” means Section 302(b) of the Act;
4
 
Sections 2.803, 2.938 or 2.955, 2.1077, 15.19, 15.21, 15.101, and 15.105 of the 
Commission’s rules;
5
 and other provisions of the Act, the Rules, and Commission 
orders related to the authorization of radio frequency devices and the marketing of 
such devices.
(k) “Investigation” means the investigation commenced by the Bureau’s July 17, 2017, 
Letter of Inquiry to Boyce regarding whether the Company violated the Equipment 
Authorization and Marketing Rules.
6
(l) “Operating Procedures” means the standard internal operating procedures and 
compliance policies established by Boyce to implement the Compliance Plan.
(m) “Parties” means Boyce and the Bureau, each of which is a “Party.”
(n) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
II. BACKGROUND
3. Section 302 of the Act authorizes the Commission to promulgate reasonable regulations 
to minimize harmful interference by equipment that emits radio frequency energy.
7
   Specifically, Section 
302(b) of the Act provides that “[n]o person shall manufacture, import, sell, offer for sale, or ship devices 
or home electronic equipment and systems, or use devices, which fail to comply with regulations 
promulgated pursuant to this section.”
8
  The purpose of Section 302 of the Act is to ensure that radio 
transmitters and other electronic devices meet certain standards to control interference before they reach 
the market.
4. The Commission carries out its responsibilities under Section 302 of the Act in two ways.  
First, the Commission establishes technical requirements for transmitters and other equipment to 
minimize their potential for causing interference to authorized radio services.  Second, the Commission 
administers an equipment authorization program to ensure that equipment reaching the market in the 
United States complies with the technical and administrative requirements set forth in the Rules.  The 
equipment authorization program requires, among other things, that radio frequency devices must be 
tested for compliance with the applicable technical requirements prior to marketing.
9
   In that regard, 
Section 2.803(b) of the Rules prohibits the marketing of radio frequency devices unless the device has 
4
 Id. § 302a(b).
5
 47 CFR §§ 2.803, 2.938, 2.1077, 15.19, 15.101 (2018); id. §§ 2.803, 2.955, 15.19, 15.21, 15.101, 15.105 (2017).  
6
 See Letter from Aspasia A. Paroutsas, Chief, Spectrum Enforcement Division, FCC Enforcement Bureau, to 
Vision Tech c/o Mr. Vernon Boyce, President, Boyce Industries, Inc. (July 21, 2017) (amended LOI); Letter from 
Aspasia A. Paroutsas, Chief, Spectrum Enforcement Division, FCC Enforcement Bureau, to Vision Tech c/o Mr. 
Vernon Boyce, President, Boyce Industries, Inc. (July 17, 2017) (LOI) (both on file in EB-SED-17-00024684). 
7
 47 U.S.C. § 302a.
8
 Id. § 302a(b).
9
 The term “marketing” is defined in the Rules and includes the “sale or lease, or offering for sale or lease, including 
advertising for sale or lease, or importation, shipment, or distribution for the purpose of selling or leasing or offering 
for sale or lease.”  47 CFR § 2.803(a).
Federal Communications Commission DA 18-334
3
first been properly authorized, identified, and labeled in accordance with the Rules, with limited 
exceptions.
10
5. Boyce is a privately held, family-owned, domestic S Corporation that advertises, imports, 
assembles, and sells LED display signs.  On July 17, 2017, after reviewing a complaint, the Bureau’s 
Spectrum Enforcement Division issued a Letter of Inquiry (LOI) to Boyce, directing it to submit a sworn 
written response to a series of questions relating to its marketing of LED signs in the United States.
11
  The 
investigation revealed that Boyce violated the Equipment Marketing and Authorization Rules by 
marketing LED signs without the required equipment authorization, labeling, and user manual 
disclosures, and by failing to retain required test records.
12
  After receiving the LOI, Boyce discontinued 
marketing its noncompliant models and began the process of developing solutions to bring those models 
into compliance with the Commission’s rules.  Boyce subsequently resolved all matters relating to its 
noncompliance with the Commission’s Equipment Authorization and Marketing Rules. 
6. The Bureau and Boyce negotiated the following terms and conditions of settlement and 
hereby enter into this Consent Decree as provided herein.
III. TERMS OF AGREEMENT
7. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.
8. Jurisdiction.  Boyce agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
9. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.  
10. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation.  In consideration for the termination of the Investigation, Boyce agrees to the 
terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the absence of new 
material evidence, it will not use the facts developed in the Investigation through the Effective Date, or 
the existence of this Consent Decree, to institute, on its own motion, any new proceeding, formal or 
informal, or take any action on its own motion against Boyce concerning the matters that were the subject 
of the Investigation.  The Bureau also agrees that, in the absence of new material evidence, it will not use 
the facts developed in the Investigation through the Effective Date, or the existence of this Consent 
Decree, to institute on its own motion any proceeding, formal or informal, or to set for hearing the 
question of Boyce’s basic qualifications to be a Commission licensee or hold Commission licenses or 
authorizations.
13
10
 See id. §§ 2.803(b), (c).
11
 See supra note 6.
12
 See E-mail from Jessica T. Nyman, Associate, Pillsbury Winthrop Shaw Pittman LLP, to Leslie Barnes, Spectrum 
Enforcement Division, FCC Enforcement Bureau (Dec. 15, 2017, 13:32 EST); Letter from Jessica T. Nyman, 
Associate, Pillsbury Winthrop Shaw Pittman LLP, to Leslie Barnes, Spectrum Enforcement Division, FCC 
Enforcement Bureau (Oct. 11, 2017); Letter from Glenn S. Richards, Partner, Pillsbury Winthrop Shaw Pittman 
LLP, to Christopher Sova, Deputy Division Chief, Investigations and Hearings Division, FCC Enforcement Bureau 
(Sept. 1, 2017); Letter from Glenn S. Richards, Partner, Pillsbury Winthrop Shaw Pittman LLP, to Christopher 
Sova, Deputy Division Chief, Investigations and Hearings Division, FCC Enforcement Bureau (Aug. 7, 2017) (all 
on file in EB-SED-17-00024684).
13
 See 47 CFR § 1.93(b).
Federal Communications Commission DA 18-334
4
11. Admission of Liability.  Boyce admits for the purpose of this Consent Decree and for 
Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 10 herein, 
that its actions described in paragraph 5, herein, violated the Equipment Authorization and Marketing 
Rules in effect during the Investigation.   
12. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Boyce 
shall designate a senior corporate manager with the requisite corporate and organizational authority to 
serve as a Compliance Officer and to discharge the duties set forth below.  The person designated as the 
Compliance Officer shall be responsible for developing, implementing, and administering the Compliance 
Plan and ensuring that Boyce complies with the terms and conditions of the Compliance Plan and this 
Consent Decree.   In addition to the general knowledge of the Communications Laws necessary to 
discharge his or her duties under this Consent Decree, the Compliance Officer shall have specific 
knowledge of the Equipment Authorization and Marketing Rules prior to assuming his/her duties.
13. Compliance Plan.  For purposes of settling the matters set forth herein, Boyce agrees 
that it shall, within sixty (60) calendar days after the Effective Date, develop and implement a 
Compliance Plan designed to ensure future compliance with the Communications Laws and with the 
terms and conditions of this Consent Decree.  With respect to the Equipment Authorization and 
Marketing Rules, Boyce will implement, at a minimum, the following procedures:
(a) Operating Procedures.  Within thirty (30) calendar days after the Effective Date, 
Boyce shall establish Operating Procedures that all Covered Employees must follow 
to help ensure Boyce’s compliance with the Equipment Authorization and 
Marketing Rules.  Boyce’s Operating Procedures shall include internal procedures 
and policies specifically designed to ensure that all radio frequency devices to be 
marketed by Boyce are properly authorized and compliant with the applicable 
technical and administrative standards and requirements prior to the initiation of 
marketing.
14
  Additionally, Boyce will establish a procedure for retaining 
documentation supporting device compliance prior to the initiation of marketing.
15
  
Boyce shall also develop a Compliance Checklist that describes the steps that a 
Covered Employee must follow to ensure compliance with the Equipment 
Authorization and Marketing Rules.
(b) Compliance Manual.  Within sixty (60) calendar days after the Effective Date, the 
Compliance Officer shall develop and distribute a Compliance Manual to all 
Covered Employees.  The Compliance Manual shall explain the Equipment 
Authorization and Marketing Rules and set forth the Operating Procedures that 
Covered Employees shall follow to help ensure Boyce’s compliance with the 
Equipment Authorization and Marketing Rules.  Boyce shall periodically review and 
revise the Compliance Manual as necessary to ensure that the information set forth 
therein remains current and accurate.  Boyce shall distribute any revisions to the 
Compliance Manual promptly to all Covered Employees.
(c) Compliance Training Program.  Boyce shall establish and implement a 
Compliance Training Program on compliance with the Equipment Authorization and 
Marketing Rules and the Operating Procedures.  As part of the Compliance Training 
Program, Covered Employees shall be advised of Boyce’s obligation to report any 
noncompliance with the Equipment Authorization and Marketing Rules under 
paragraph 14 of this Consent Decree and shall be instructed on how to disclose 
noncompliance to the Compliance Officer.  All Covered Employees shall be trained 
14
 See, e.g., supra note 10.
15
 See 47 CFR §§ 2.945; 2.938 (2018); id. § 2.955 (2017); see also Equipment Authorization Order, 32 FCC Rcd 
8746.
Federal Communications Commission DA 18-334
5
pursuant to the Compliance Training Program within sixty (60) calendar days after 
the Effective Date, except that any person who becomes a Covered Employee at any 
time after the initial Compliance Training Program shall be trained within thirty (30) 
calendar days after the date such person becomes a Covered Employee.  Boyce shall 
repeat compliance training on an annual basis, and shall periodically review and 
revise the Compliance Training Program as necessary to ensure that it remains 
current and complete and to enhance its effectiveness.
14. Reporting Noncompliance.  Boyce shall report any noncompliance with the Equipment 
Authorization and Marketing Rules and with the terms and conditions of this Consent Decree within 
fifteen (15) calendar days after discovery of such noncompliance.  Such reports shall include a detailed 
explanation of: (i) each instance of noncompliance; (ii) the steps that Boyce has taken or will take to 
remedy such noncompliance; (iii) the schedule on which such remedial actions will be taken; and (iv) the 
steps that Boyce has taken or will take to prevent the recurrence of any such noncompliance.  All reports 
of noncompliance shall be submitted to Chief, Spectrum Enforcement Division, Enforcement Bureau, 
Federal Communications Commission, 445 12
th
 Street, SW, Rm. 3-C366, Washington, DC 20554, with a 
copy submitted electronically to Neal.McNeil@fcc.gov.
15. Compliance Reports.  Boyce shall file compliance reports with the Commission ninety 
(90) calendar days after the Effective Date, twelve (12) months after the Effective Date, twenty-four (24) 
months after the Effective Date, and thirty-six (36) months after the Effective Date.
(a) Each Compliance Report shall include a detailed description of Boyce’s efforts 
during the relevant period to comply with the terms and conditions of this Consent 
Decree and the Equipment Authorization and Marketing Rules.  In addition, each 
Compliance Report shall include a certification by the Compliance Officer, as an 
agent of and on behalf of Boyce, stating that the Compliance Officer has personal 
knowledge that Boyce:  (i) has established and implemented the Compliance Plan; 
(ii) has utilized the Operating Procedures since the implementation of the 
Compliance Plan; and (iii) is not aware of any instances of noncompliance with the 
terms and conditions of this Consent Decree, including the reporting obligations set 
forth in paragraph 14 of this Consent Decree.
(b) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and shall comply with Section 1.16 of the 
Rules and be subscribed to as true under penalty of perjury in substantially the form 
set forth therein.
16
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Boyce, shall provide the Commission with a 
detailed explanation of the reason(s) why and describe fully:  (i) each instance of 
noncompliance; (ii) the steps that Boyce has taken or will take to remedy such 
noncompliance, including the schedule on which proposed remedial actions will be 
taken; and (iii) the steps that Boyce has taken or will take to prevent the recurrence 
of any such noncompliance, including the schedule on which such preventive action 
will be taken.
(d) All Compliance Reports shall be submitted to Chief, Spectrum Enforcement 
Division, Enforcement Bureau, Federal Communications Commission, 445 12
th
 
Street, SW, Rm. 3-C366, Washington, DC 20554, with a copy submitted 
electronically to Neal.McNeil@fcc.gov and EB-SED-Response@fcc.gov.
16
 47 CFR § 1.16.
Federal Communications Commission DA 18-334
6
16. Termination Date.  Unless stated otherwise, the requirements set forth in paragraphs 12 
through 15 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
17.  Civil Penalty.  Boyce will pay a civil penalty to the United States Treasury in the 
amount of thirty-nine thousand, five hundred dollars ($39,500) within thirty (30) calendar days of the 
Effective Date.  Boyce shall send electronic notification of payment to Neal McNeil at 
Neal.McNeil@fcc.gov and to SED’s mailbox at EB-SED-Response@fcc.gov on the date said payment is 
made.  The payment must be made by check or similar instrument, wire transfer, or credit card, and must 
include the Account Number and FRN referenced above.  Regardless of the form of payment, a 
completed FCC Form 159 (Remittance Advice) must be submitted.
17
  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.
Questions regarding payment procedures should be addressed to the Financial Operations Group 
Help Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
18. Waivers.  As of the Effective Date, Boyce waives any and all rights it may have to seek 
administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest the 
validity of this Consent Decree and the Adopting Order.  Boyce shall retain the right to challenge 
Commission interpretation of the Consent Decree or any terms contained herein.  If either Party (or the 
United States on behalf of the Commission) brings a judicial action to enforce the terms of the Consent 
Decree or the Adopting Order, neither Boyce nor the Commission shall contest the validity of the Consent 
Decree or the Adopting Order, and Boyce shall waive any statutory right to a trial de novo.  Boyce hereby 
agrees to waive any claims it may otherwise have under the Equal Access to Justice Act
18
 relating to the 
matters addressed in this Consent Decree.
19. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
17
 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
18
 See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530.
Federal Communications Commission DA 18-334
7
20. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding.
21. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent Rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which Boyce does not expressly 
consent) that provision will be superseded by such Rule or Order.
22. Successors and Assigns.  Boyce agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees.
23. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.
24. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
25. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
26. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions.
27. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Christopher L. Killion
Acting Deputy Chief
Enforcement Bureau
________________________________
Date
________________________________
Vernon Boyce
President 
Boyce Industries, Inc.
________________________________
Date