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Federal Communications Commission DA 18-461
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Clarity Telecom, LLC d/b/a Vast Broadband
)
)
)
)
)
)
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File No.:  EB-18-IHD-00026141
Acct. No.:  201832080004
FRN:  0023758238
ORDER
Adopted:  May 8, 2018 Released:  May 8, 2018
By the 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 Clarity Telecom, LLC d/b/a Vast 
Broadband (Vast) violated the Commission’s rules related to the sale of assets to Long Lines Metro, LLC 
(Metro) prior to receiving approval from the Commission’s Wireline Competition and International 
Bureaus.  To settle this matter, Vast admits that it failed to obtain the Commission’s approval prior to the 
sale of assets to Metro, will implement a compliance plan, and will pay a $16,000 settlement amount. 
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 Vast’s compliance with the Commission’s rules regarding the 
requirement of prior Commission approval for the sale of assets as set forth in Section 214 of the 
Communications Act of 1934, as amended (Act)
1
, and Sections 63.03, 63.04, 63.18, and 63.24 of the 
Commission’s rules (Rules)
 2
 In the absence of material new evidence relating to this matter, we do not 
set for hearing the question of Vast’s basic qualifications to hold or obtain any Commission license or 
authorization.
3
3. 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.
4. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED.  
1
 47 USC § 214.
2
 47 CFR §§ 63.03, 63.04, 63.18, 63.24.
3
 See 47 CFR § 1.93(b).
4
 47 USC § 154(i).
5
 47 CFR §§ 0.111, 0.311.
Federal Communications Commission DA 18-461
2
5. 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, James M. Gleason, President and Chief 
Executive Officer, Clarity Telecom, LLC d/b/a Vast Broadband, 912 S. Main Street, Suite 106, Sikeston, 
MO 63801 and Gregory W. Whitaker, Esq., Herman & Whiteaker, LLC, 6720-B Rockledge Drive, Suite 
150, Bethesda, MD 20817.
FEDERAL COMMUNICATIONS COMMISSION
Keith V. Morgan 
Deputy Chief 
Enforcement Bureau
Federal Communications Commission DA 18-461
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Clarity Telecom, LLC d/b/a Vast Broadband
)
)
)
)
)
)
)
File No.:  EB-18-IHD-00026141
Acct. No.:  201832080004
FRN:  0023758238
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Clarity 
Telecom, LLC d/b/a Vast Broadband (Vast), by their authorized representatives, hereby enter into this 
Consent Decree for the purpose of terminating the Enforcement Bureau’s investigation, as defined below, 
into whether Vast violated Section 214 of the Communications Act of 1934, as amended (Act)
1
, and 
Sections 63.03, 63.04, 63.18, and 63.24 of the Commission’s rules (Rules)
 2
 related to the sale of assets to 
Long Lines Metro, LLC (Metro) prior to receiving approval from the Commission’s Wireline 
Competition and International Bureaus.
3
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.
4
(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 Vast is subject 
by virtue of its business activities, including but not limited to the Section 214 
Rules.
(f) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 17
(g) “Covered Employees” means all employees and agents of Clarity who perform, or 
supervise, oversee, or manage the performance of, duties that relate to Vast’s 
responsibilities under the Communications Laws, including the Section 214 Rules.
1
 47 USC § 214.
2
 47 CFR §§ 63.03, 63.04, 63.18, 63.24.
3
  See IBFS Application No. ITC-ASG-20170905-00145; Domestic Section 214 Application Filed for the 
Acquisition of Certain Assets of Clarity Telecom, LLC d/b/a Vast Broadband to Long Lines Metro, LLC., WC 
Docket No. 17-229.
4
 47 USC § 151 et seq.
Federal Communications Commission DA 18-461
2
(h) “Effective Date” means the date by which both the Bureau and Vast have signed the 
Consent Decree.
(i) “Investigation” means the investigation commenced by the Bureau in EB-18-IHD-
00026141 regarding whether Vast violated the Section 214 Rules.
(j) “LOI” means the Letter of Inquiry issued by the Bureau to Vast on February 2, 2018 
investigating whether Vast violated the Section 214 Rules related to the transfer of 
control of the Company’s authorizations to provide domestic and international 
service pursuant to Section 214 of the Act, prior to receiving approval from the 
Commission’s Wireline Competition and International Bureaus
(k) “Metro” means Long Lines Metro, LLC (Metro) and its affiliates, subsidiaries, 
predecessors-in-interest, and successors-in-interest.
(l) “Operating Procedures” means the standard internal operating procedures and 
compliance policies established by Vast to implement the Compliance Plan.
(m) “Parties” means Vast 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.
(o) “Section 214 Rules” means Section 214 of the Act and other provisions of the Act, 
the Rules, and Commission orders related to the construction, acquisition, operation, 
or transmission of lines of communication, including any Rules implementing 
Section 214 and any related Commission orders.
(p) “Vast” or “Company” means Clarity Telecom, LLC d/b/a Vast Broadband and its 
affiliates, subsidiaries, predecessors-in-interest, and successors-in-interest.
II. BACKGROUND
3. Section 214(a) of the Act requires telecommunications carriers to obtain a certificate of 
public convenience and necessity from the Commission before constructing, acquiring, operating, or 
engaging in the transmission of common carrier communications services over communications lines, and 
before discontinuing, reducing, or impairing service to a community.
5
  The Commission granted all 
carriers blanket authority under Section 214 to provide domestic interstate services and to construct, 
acquire, or operate any domestic transmission line.
6
  In accordance with Section 63.03 of the Rules, 
however, any domestic carrier seeking to transfer control of lines or authorization to operate pursuant to 
Section 214 of the Act resulting from an acquisition of corporate control must obtain prior approval from 
the Commission.
7
  The Commission has determined that transactions involving the sale of a 
telecommunications provider’s customer base should be treated as transfers of control requiring 
5
 See 47 USC § 214(a).
6
 47 CFR § 63.01; See Implementation of Section 402(b)(2)(A) of the Telecommunications Act of 1996; Petition for 
Forbearance of the Independent Telephone & Telecommunications Alliance, Report and Order and Second 
Memorandum Opinion and Order, 14 FCC Rcd 11364 (1999) (1999 Streamlining Order).  
7
 47 CFR § 63.03; See Implementation of Further Streamlining Measures for Domestic Section 214 Authorizations, 
Report and Order, 17 FCC Rcd 5517, 5521, para. 5 (2002) (2002 Streamlining Order).  See also 47 CFR 
§ 63.03(d)(1) (excluding all pro forma transactions, which do not result in a change in the carrier’s ultimate 
ownership or control, from the domestic Section 214 application and approval requirements), § 63.04(d)(2) 
(requiring that a post-transaction notice be filed with the Commission within 30 days of a pro forma transfer of a 
domestic Section 214 authorization to a trustee, a debtor-in-possession, or any other party pursuant to any applicable 
chapter of the Bankruptcy Code).  
Federal Communications Commission DA 18-461
3
Commission approval.
8
   Section 63.04 sets forth the required contents of domestic transfer of control 
applications.
9
  The Commission employs a public interest standard under Section 214(a) of the Act that 
involves the examination of the public interest impact of a proposed transaction.
10
4. While the Commission has granted “blanket” Section 214 authority to carriers providing 
domestic service,
11
 meaning that such carriers need not apply to the Commission before providing 
domestic service, the Commission has not done the same for providers of international 
telecommunications services.
12 
 Section 63.18 of the Rules requires any carrier that seeks Section 214 
authority “for provision of common carrier communication services between the United States, its 
territories or possessions, and a foreign point” to request such authority by application.
13
  This application 
requirement applies to carriers that resell the international services of another authorized carrier, as well 
as to facilities-based international service providers.
14
  In accordance with Section 63.24 of the Rules, an 
international Section 214 authorization may be assigned, or control of such authorization may be 
transferred by the transfer of control of any entity holding such authorization, to another party, whether 
voluntarily or involuntarily, directly or indirectly, only upon application to and prior approval by the 
Commission.
15
5. Vast is a Delaware limited liability corporation
16
 with headquarters in Sikeston, 
Missouri.
17
  Vast provided competitive local and long distance telecommunications services in Iowa and 
South Dakota.  Vast also provided domestic interstate and international services in certain communities in 
northwest Iowa and southeast South Dakota, with service areas mirroring that of the incumbent local 
exchange carrier, CenturyLink.
18
8
 See 47 CFR §§ 63.01, 63.03, 63.04, 63.18 and 63.24; see also 2002 Streamlining Order, 17 FCC Rcd at 5547-49, 
paras. 59-64 (modifying 47 CFR § 63.01 to reflect that asset purchases will no longer be subject to blanket authority, 
but rather will be treated as transfers of control).
9
 See 47 CFR § 63.04.
10
 See 47 USC § 214(a).
11
 47 CFR § 63.01(a) (“Any party that would be a domestic interstate communications common carrier is authorized 
to provide domestic, interstate services to any domestic point and to construct or operate any domestic transmission 
line as long as it obtains all necessary authorizations from the Commission for use of radio frequencies.”).
12 
Implementation of Section 402(b)(2)(A) of the Telecomm. Act of 1996, Report and Order in CC Docket No. 97-11, 
Second Memorandum Opinion & Order in AAD File No. 98-43, 14 FCC Rcd 11364, para. 2 & n.8 (1999) (grant of 
blanket authority is only for domestic interstate services and does not extend to the provision of international 
services).
13
 47 CFR § 63.18.
14
 Id. § 63.18(e)(1)-(2); see Start Wireless Group, Inc. d/b/a/ Page Plus Cellular, Notice of Apparent Liability for 
Forfeiture, 27 FCC Rcd 350 (Enf. Bur. 2012).
15
 47 CFR § 63.24(a.)  “The sale of a customer base, or a portion of a customer base, by a carrier to another carrier, 
is a sale of assets and shall be treated as an assignment which requires prior Commission approval under this 
section.  47 CFR § 63.24 Note to Paragraph (b). 
16
  Domestic Section 214 Application Filed for the Acquisition of Certain Assets of Clarity Telecom, LLC d/b/a Vast 
Broadband to Long Lines, Metro, LLC, Public Notice, WC Docket No. 17-229, 32 FCC Rcd 6969 (WCB 2017) at 1 
(Domestic 214 PN).  
17
 Joint Application of Clarity Telecom, LLC d/b/a Vast Broadband, Assignor, and Long Lines Metro, LLC, 
Assignee, for Consent to Assign Assets and Customers Subject to Blanket Section 214 Authority and to Partially 
Assign International Section 214 Authority Held by Clarity Telecom, LLC d/b/a Vast Broadband to Long Lines 
Metro, LLC (filed Sept. 1, 2017) at 5 (Joint Application).
18
 See Domestic 214 PN at 1.
Federal Communications Commission DA 18-461
4
6. Long Lines Metro, LLC (Metro) is a Delaware limited liability corporation
19
 with 
headquarters in Sergeant Bluff, Iowa.
20
  Metro provides competitive local and long distance services in 
Iowa and South Dakota.  Metro’s interexchange services are offered through resale arrangements with 
other carriers.
21
  Metro provides communications services throughout its services areas, and in the areas 
previously serviced by Vast and acquired by Metro over facilities acquired through the transaction at 
issue in this Investigation (Transaction).  Metro is providing domestic interstate services in the northwest 
Iowa and southeast South Dakota communities previously served by Vast.  Metro also provides local and 
long distance services in other parts of Iowa and South Dakota.
22
7. As a result of this Transaction, Metro is providing domestic and interstate and 
international services in the northwest Iowa and southeast South Dakota communities previously served 
by Vast.  Metro also provides local and long distance services in other parts of Iowa and South Dakota.
23
  
8. On June 30, 2017, Vast completed a Transaction involving the sale of certain customer 
accounts and assets used in the provision of residential and commercial cable television services, VoIP 
telephony, local exchange and interexchange services, and high-speed Internet services in the states of 
Iowa and South Dakota to Metro.
24
  The Transaction was completed without prior Commission consent.
25
  
Vast retained its international Section 214 authorizations to continue providing international services in 
the areas not covered by the Transaction.
26
  Vast admits that neither Metro nor Vast sought prior 
Commission approval for this transfer.
27
9. Vast and Metro belatedly filed applications for approval of the sale of assets with the 
Wireline Competition and International Bureaus of the FCC on September 1, 2017.
28
  At the same time, 
Vast and Metro filed requests for special temporary authority (STA) with each of the Bureaus.
29
  The 
Wireline Competition Bureau granted the STA on September 13, 2017.
30
  The International Bureau 
granted the STA on September 21, 2017.
31
  The International Bureau granted the international application 
19
 Id.
20
 Joint Application at 5.
21
 Domestic 214 PN at 1.
22
 Id. at 2.
23
 Joint Application at 5-6.
24
 Letter from Gregory W. Whiteaker, Counsel for Clarity Telecom, LLC d/b/a Vast Broadband and Long Lines 
Metro, LLC, to Marlene H. Dortch, Secretary, Federal Communications Commission at 3, (Mar. 5, 2018) (LOI 
Response).
25
 See International Authorizations Granted, Public Notice, Rep. No. TEL-01871, 32 FCC Rcd 7520 (IB 2017) 
(International 214 Grant PN). 
26
 LOI Response at 3.
27
 See LOI Response at 6; Joint Application at 4
28
 See Joint Application.  See also IBFS Application No. ITC-ASG-20170905-00145; Domestic Section 214 
Application Filed for the Acquisition of Certain Assets of Clarity Telecom, LLC d/b/a Vast Broadband to Long 
Lines Metro, LLC., Public Notice, WC Docket No. 17-229, 32 FCC Rcd 6969 (WCB 2017). 
29
 See Letter from Gregory W. Whiteaker, Counsel for Clarity Telecom, LLC d/b/a Vast Broadband and Long Lines 
Metro, LLC, to Marlene H. Dortch, Secretary, Federal Communications Commission (Sept. 1, 2017) (STA 
Request); https://ecfsapi.fcc.gov/file/1091597677814/17-229.pdf; see also LOI Response at 5.
30
 See LOI Response at 6; STA Request; https://ecfsapi.fcc.gov/file/1091597677814/17-229.pdf.
31
 See International 214 Grant PN at 2; ITC-STA-20170905-00146. 
Federal Communications Commission DA 18-461
5
on October 6, 2017.
32
  The Wireline Competition Bureau granted the domestic application on October 16, 
2017.
33
  
10. On February 2, 2018, the Enforcement Bureau (Bureau) issued a Letter of Inquiry (LOI) 
regarding the matters referenced above.
34
  On March 5, 2018, Vast filed its response to the LOI.
35
  The 
Parties negotiated the following terms and conditions of settlement and hereby enter into this Consent 
Decree as provided below.
III. TERMS OF AGREEMENT
11. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.
12. Jurisdiction.  Vast 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.
13. 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.  
14. 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, Vast 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 Vast 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 Vast’s basic qualifications to be a Commission licensee or hold Commission licenses or 
authorizations.
36
  
15. Admission of Liability.  Vast admits for the purpose of this Consent Decree and for 
Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 14 herein, 
that its actions described in paragraph 8, herein, violated the Section 214 Rules. 
16.  Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Vast 
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 Vast 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 
32
 See International Authorizations Granted, Public Notice, Rep. No. TEL-01871, 32 FCC Rcd 7561 (rel. Oct. 12, 
2017; ITC-ASG-20170905-00145.
33
 See Notice of Domestic Section 214 Authorization Granted, Public Notice, WC Docket No. 17-229, DA 17-1016, 
32 FCC Rcd 7561 (rel. Oct. 16, 2017).
34
 See Letter from Jeffrey J. Gee, Chief, Investigations and Hearings Division, FCC Enforcement Bureau, to James 
Gleason, Chief Executive Officer, Clarity Telecom, LLC d/b/a/ Vast Broadband (Feb. 2, 2018) (on file in EB-IHD-
18-00026141) (LOI).
35
 See LOI Response.
36
 See 47 CFR 1.93(b).
Federal Communications Commission DA 18-461
6
discharge his or her duties under this Consent Decree, the Compliance Officer shall have specific 
knowledge of the Section 214 Rules prior to assuming his/her duties.
17. Compliance Plan.  For purposes of settling the matters set forth herein, Vast 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 Section 214 Rules, Vast will implement, at a 
minimum, the following procedures:
(a) Operating Procedures.  Within thirty (30) calendar days after the Effective Date, 
Vast shall establish Operating Procedures that all Covered Employees must follow 
to help ensure Vast’s compliance with the Section 214 Rules.  In addition to 
implementing the required policies and procedures in the Section 214 Rules, Vast’s 
Operating Procedures shall include internal procedures and policies specifically 
designed to ensure that Vast complies with the Section 214 Rules.  Vast shall also 
develop a Compliance Checklist that describes the steps a Covered Employee must 
follow to ensure compliance with the Section 214 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 Section 214 Rules and 
set forth the Operating Procedures that Covered Employees shall follow to help 
ensure Vast’s compliance with the Section 214 Rules.  Vast shall periodically 
review and revise the Compliance Manual as necessary to ensure that the 
information set forth therein remains current and accurate.  Vast shall distribute any 
revisions to the Compliance Manual promptly to all Covered Employees.
(c) Compliance Training Program.  Vast shall establish and implement a Compliance 
Training Program on compliance with the Section 214 Rules and the Operating 
Procedures.  As part of the Compliance Training Program, Covered Employees shall 
be advised of Vast’s obligation to report any noncompliance with the Section 214 
Rules under paragraph 18 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.  Vast 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.
18. Reporting Noncompliance.  Vast shall report any noncompliance with the Section 214 
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 Vast 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 Vast has taken or will take 
to prevent the recurrence of any such noncompliance.  All reports of noncompliance shall be submitted to 
the Chief, Investigations and Hearings Division, Enforcement Bureau, Federal Communications 
Commission, 445 12
th
 Street, SW Room 4-C224, Washington, DC 20554, with a copy submitted 
electronically to Jeffrey.Gee@fcc.gov, Kalun.Lee@fcc.gov and to Pam.Slipakoff@fcc.gov.
19. Compliance Reports.  Vast shall file compliance reports with the Commission ninety 
(90) calendar days after the Effective Date, twelve (12) months after the Effective Date and twenty-four 
(24) months after the Effective Date. 
Federal Communications Commission DA 18-461
7
(a) Each Compliance Report shall include a detailed description of Vast’s efforts during 
the relevant period to comply with the terms and conditions of this Consent Decree 
and the Section 214 Rules.  In addition, each Compliance Report shall include a 
certification by the Compliance Officer, as an agent of and on behalf of Vast, stating 
that the Compliance Officer has personal knowledge that Vast: (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 18 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.
37
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Vast, 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 Vast 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 Vast 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 the Chief, Investigations and Hearings 
Division, Enforcement Bureau, Federal Communications Commission, 445 12
th
 
Street, SW Room 4-C224, Washington, DC 20554, with a copy submitted 
electronically to Jeffrey.Gee@fcc.gov, Kalun.Lee@fcc.gov and to 
Pam.Slipakoff@fcc.gov.
20. Termination Date.  Unless stated otherwise, the requirements set forth in paragraphs 16 
through 19 of this Consent Decree shall expire twenty-four (24) months after the Effective Date.
21. Section 208 Complaints; Subsequent Investigations.  Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
Section 208 of the Act
38
 against Vast or its affiliates for alleged violations of the Act, or for any other type 
of alleged misconduct, regardless of when such misconduct took place.  The Commission’s adjudication 
of any such complaint will be based solely on the record developed in that proceeding.  Except as 
expressly provided in this Consent Decree, this Consent Decree shall not prevent the Commission from 
investigating new evidence of noncompliance by Vast with the Communications Laws.  
22. Settlement Amount.  Vast will make a settlement payment to the United States Treasury 
in the amount of sixteen thousand dollars ($16,000) within thirty (30) calendar days of the Effective Date.  
Vast shall send electronic notification of payment to the Chief, Investigations and Hearings Division, 
Enforcement Bureau, Federal Communications Commission, 445 12
th
 Street, SW Room 4-C224, 
Washington, DC 20554, with a copy submitted electronically to Jeffrey.Gee@fcc.gov, 
Kalun.Lee@fcc.gov and to Pam.Slipakoff@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 
37
 47 CFR § 1.16.
38
 47 USC. § 208.
Federal Communications Commission DA 18-461
8
(Remittance Advice) must be submitted.
39
  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.
23. Waivers.  As of the Effective Date, Vast 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.  Vast 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 Vast nor the Commission shall contest the validity of the Consent 
Decree or the Adopting Order, and Vast shall waive any statutory right to a trial de novo.  Vast hereby 
agrees to waive any claims it may otherwise have under the Equal Access to Justice Act
40
 relating to the 
matters addressed in this Consent Decree.
24. 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.
25. 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.
26. 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 Vast does not expressly consent) 
that provision will be superseded by such Rule or Order.
39
 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
40
 See 5 USC § 504; 47 CFR §§ 1.1501–1.1530.
Federal Communications Commission DA 18-461
9
27. Successors and Assigns.  Vast agrees that the provisions of this Consent Decree shall be 
binding on its successors, assigns, and transferees.
28. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.  
29. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
30. 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.
31. 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.
32. 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.
________________________________
Keith V. Morgan 
Deputy Chief
Enforcement Bureau
________________________________
Date
________________________________
James M. Gleason
President and Chief Executive Officer
Clarity Telecom, LLC d/b/a Vast Broadband 
________________________________
Date