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Federal Communications Commission DA 18-385
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Optec Displays, Inc.
)
)
)
)
)
File No.:  EB-SED-17-00024598
Acct. No.:  201832100011
FRN:  0027449628
ORDER
Adopted:  May 2, 2018 Released:  May 2, 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 Optec Displays, Inc. (Optec) 
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, Optec admits that it marketed LED signs without the required 
equipment authorization, labeling, and user manual disclosures, will implement a compliance plan, and 
will pay a $54,000 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 Optec’s compliance with the equipment authorization, labeling, and 
user manual disclosure rules in effect at the time of the violations, 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 Optec’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.
1
 47 U.S.C. § 302a(b).
2
 47 CFR §§ 2.803, 2.955, 15.19, 15.21, 15.101, 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 18-385
2
5. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED.
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 Jerry Luan, Chief Executive Officer, 
Optec Displays, Inc., 1700 S. De Soto Place, Ontario, CA 91761.
FEDERAL COMMUNICATIONS COMMISSION
Christopher L. Killion
Acting Deputy Chief 
Enforcement Bureau
Federal Communications Commission DA 18-385
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Optec Displays, Inc.
)
)
)
)
)
File No.:  EB-SED-17-00024598
Acct. No.:  201832100011
FRN:  0027449628
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Optec 
Displays, Inc. (Optec) by their authorized representatives, hereby enter into this Consent Decree for the 
purpose of terminating the Enforcement Bureau’s investigation into whether Optec violated 
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
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) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.
(e) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Optec is subject 
by virtue of its business activities, including but not limited to the Equipment 
Authorization and Marketing Rules.
(f) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 13.
(g) “Covered Employees” means all employees and agents of Optec who perform, or 
supervise, oversee, or manage the performance of, duties that relate to Optec’s 
responsibilities under the Communications Laws, including the Equipment 
Authorization and Marketing Rules.
1
 47 U.S.C. § 302a(b).
2
 47 CFR §§ 2.803, 2.955, 15.19, 15.21, 15.101, 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 18-385
2
(h) “Effective Date” means the date by which both the Bureau and Optec have signed 
the Consent Decree. 
(i) “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. 
(j) “Investigation” means the investigation commenced by the Bureau’s June 27, 2017 
Letter of Inquiry regarding whether Optec violated the Equipment Authorization and 
Marketing Rules.
6
(k) “Operating Procedures” means the standard internal operating procedures and 
compliance policies established by Optec to implement the Compliance Plan. 
(l) “Optec” or “Company” means Optec Displays and its affiliates, subsidiaries, 
predecessors-in-interest, and successors-in-interest.
(m) “Parties” means Optec 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 Ms. 
Shu Wu, President, Optec Displays, Inc. (June 27, 2017) (LOI) (on file in EB-SED-17-00024598).
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 18-385
3
first been properly authorized, identified, and labeled in accordance with the Rules, with limited 
exceptions.
10
  
5. Optec is a privately held corporation that designs, manufactures, imports, advertises, and 
sells fully assembled LED signs.  On June 27, 2017, after reviewing a complaint, the Bureau’s Spectrum 
Enforcement Division issued a Letter of Inquiry (LOI) to Optec, 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 Optec violated the Equipment Marketing and Authorization Rules by 
marketing an LED sign without the required equipment authorization and test records, and by marketing 
other LED models that lacked the proper labeling and user manual disclosures.
12
  Immediately after 
receiving the LOI, Optec began the process of bringing its LED signs into compliance with the 
Commission’s rules.  Optec subsequently resolved all matters relating to its noncompliance with the 
relevant Equipment Authorization and Marketing Rules concerning the LED signs at issue.
13
 
6. The Bureau and Optec 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.  Optec 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, Optec 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 Optec 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 
10
 See id. §§ 2.803(b), (c).
11
 See supra note 6.  
12
 See E-mail and attachments from Jerry Luan, CEO, Optec Displays, Inc., to Jennifer Burton, Spectrum 
Enforcement Division, FCC Enforcement Bureau (Correction/Amendment to LOI Response) (Apr. 13, 2018, 11:58 
EST); E-mail and attachments from Jerry Luan, CEO, Optec Displays, Inc., to Jennifer Burton, et al., Spectrum 
Enforcement Division, FCC Enforcement Bureau (Third Supplemental LOI Response) (Mar. 28, 2018, 12:45 EST); 
E-mail and attachments from Jerry Luan, CEO, Optec Displays, Inc., to Jennifer Burton, et al., Spectrum 
Enforcement Division, FCC Enforcement Bureau (Dec. 6, 2017, 15:15 EST) (Second Supplemental LOI Response); 
Letter and attachment from Ms. Shu Wu, President, Optec Displays, Inc., to Aspasia A. Paroutsas, Chief, Spectrum 
Enforcement Division, FCC Enforcement Bureau (Oct. 5, 2017) (Supplemental LOI Response); Letter and 
attachment from Ms. Shu Wu, President, Optec Displays, Inc., to Aspasia A. Paroutsas, Chief, Spectrum 
Enforcement Division, FCC Enforcement Bureau (July 17, 2017) (LOI Response) (all on file in EB-SED-17-
00024598).  
13
 See 47 CFR §§ 2.803, 2.955, 15.19, 15.21, 15.101, 15.105; Third Supplemental LOI Response.
Federal Communications Commission DA 18-385
4
question of Optec’s basic qualifications to be a Commission licensee or hold Commission licenses or 
authorizations.
14
11. Admission of Liability.  Optec 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, Optec 
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 Optec 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 or her duties.
13. Compliance Plan.  For purposes of settling the matters set forth herein, Optec 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, 
Optec will implement, at a minimum, the following procedures:
(a) Operating Procedures.  Within thirty (30) calendar days after the Effective Date, 
Optec shall establish Operating Procedures that all Covered Employees must follow 
to help ensure Optec’s compliance with the Equipment Authorization and Marketing 
Rules.  Optec’s Operating Procedures shall include internal procedures and policies 
specifically designed to ensure that all radio frequency devices to be marketed by 
Optec are properly authorized and compliant with the applicable technical and 
administrative standards and requirements prior to the initiation of marketing.
15
  
Additionally, Optec will establish a procedure for retaining documentation 
supporting device compliance prior to the initiation of marketing.
16
  Optec 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 Optec’s compliance with the 
Equipment Authorization and Marketing Rules.  Optec shall periodically review and 
revise the Compliance Manual as necessary to ensure that the information set forth 
therein remains current and accurate.  Optec shall distribute any revisions to the 
Compliance Manual promptly to all Covered Employees. 
(c) Compliance Training Program.  Optec shall establish and implement a 
Compliance Training Program on compliance with the Equipment Authorization and 
14
 See 47 CFR § 1.93(b).
15
 See supra note 9 and accompanying text. 
16
 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 18-385
5
Marketing Rules and the Operating Procedures.  As part of the Compliance Training 
Program, Covered Employees shall be advised of Optec’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 
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.  Optec 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.  Optec 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 Optec 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 the Optec 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 12th Street, SW, Rm. 3-C366, Washington, DC 
20554, with a copy submitted electronically to Jennifer.Burton@fcc.gov.
15. Compliance Reports.  Optec 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 Optec’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 Optec, stating that the Compliance Officer has personal 
knowledge that Optec:  (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.
17
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Optec, 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 Optec 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 Optec has taken or will take to prevent the recurrence 
of any such noncompliance, including the schedule on which such preventive action 
will be taken.
17
 47 CFR § 1.16.
Federal Communications Commission DA 18-385
6
(d) All Compliance Reports shall be submitted to Chief, Spectrum Enforcement 
Division, Enforcement Bureau, Federal Communications Commission, 445 12th 
Street, SW, Rm. 3-C366, Washington, DC 20554, with a copy submitted 
electronically to Jennifer.Burton@fcc.gov.
16. Termination Date.  Unless stated otherwise, the requirements set forth in paragraphs 13 
through 15 of this Consent Decree shall expire thirty-six (36) months after the Effective Date. 
17. Civil Penalty.  Optec will pay a civil penalty to the United States Treasury in the amount 
of fifty-four thousand dollars ($54,000).  Such payment shall be made in four installments (each an 
Installment Payment).  The first Installment Payment in the amount of thirteen thousand five hundred 
dollars ($13,500) is due within thirty (30) calendar days of the Effective Date.  The second Installment 
Payment in the amount of thirteen thousand five hundred dollars ($13,500) shall be paid within four (4) 
months of the Effective Date.  The third Installment Payment in the amount of thirteen thousand five 
hundred dollars ($13,500) shall be paid within eight (8) months of the Effective Date.  The fourth and 
final Installment Payment in the amount of thirteen thousand five hundred dollars ($13,500) shall be paid 
within twelve (12) months of the Effective Date.  Optec acknowledges and agrees that upon execution of 
this Consent Decree, the civil penalty and each Installment Payment shall become a “Claim” or “Debt” as 
defined in 31 U.S.C. § 3701(b)(1).
18
  Upon an Event of Default (as defined below), all procedures for 
collection as permitted by law may, at the Commission’s discretion, be initiated.  Optec shall send 
electronic notification of payment to Jennifer.Burton@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.
19
  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
 Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996).
19
 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
Federal Communications Commission DA 18-385
7
18. Event of Default.  Optec agrees that an Event of Default shall occur upon the failure by 
Optec to pay the full amount of any Installment Payment on or before the due date specified in this 
Consent Decree.
19. Interest, Charges for Collection, and Acceleration of Maturity Date.  After an Event 
of Default has occurred under this Consent Decree, the then unpaid amount of the civil penalty shall 
accrue interest, computed using the U.S. Prime Rate in effect on the date of the Event of Default plus 4.75 
percent, from the date of the Event of Default until payment in full.  Upon an Event of Default, the then 
unpaid amount of the civil penalty, together with interest, any penalties permitted and/or required by the 
law, including but not limited to 31 U.S.C. § 3717 and administrative charges, plus the costs of collection, 
litigation, and attorneys’ fees, shall become immediately due and payable, without notice, presentment, 
demand, protest, or notice of protest of any kind, all of which are waived by Optec.   
20. Waivers.  As of the Effective Date, Optec 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.  Optec 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 Optec nor the Commission shall contest the validity of the Consent 
Decree or the Adopting Order, and Optec shall waive any statutory right to a trial de novo.  Optec hereby 
agrees to waive any claims it may otherwise have under the Equal Access to Justice Act
20
 relating to the 
matters addressed in this Consent Decree.
21. 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.
22. 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.
23. 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 Optec does not expressly 
consent) that provision will be superseded by such Rule or Order.
24. Successors and Assigns.  Optec agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees.
25. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.  
26. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
27. 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.
28. 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 
20
 See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530.
Federal Communications Commission DA 18-385
8
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.
29. 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
________________________________
Jerry Luan
Chief Executive Officer
Optec Displays, Inc.
________________________________
Date