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                         Federal Communications Commission            DA 18-655 

                                   Before the 
                         Federal Communications Commission 
                              Washington, DC 20554 
  
 In the Matter of                       )         
                                        )         
 EBSCO Sign Group, LLC                  )        File No.:  EB-SED-17-00024691 
                                        )        Acct. No.:  201832100021 
                                        )        FRN:  0027631522 
                                         
                                    ORDER 
  
 Adopted:  June 29, 2018                                    Released:  June 29, 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 EBSCO Sign Group, LLC (EBSCO) 
 violated the Commission s rules by marketing light-emitting diode (LED) signs used in digital billboards 
 and other commercial and industrial applications, without the required equipment authorization, labeling, 
 and user manual disclosures.  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, EBSCO 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 $55,000 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 EBSCO 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, 2.925, 2.955, 15.19, 15.21, 15.101 and 15.105 of the 
Commission s rules (Rules).2 
      3. In the absence of material new evidence relating to this matter, we do not set for hearing the 
question of EBSCO 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 Act4 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, 2.925, 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 (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 18-655 

       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 Mel Blackwell, President, EBSCO Sign 
 Group, LLC, 1400 8th St N, Clanton, AL 35045, and to Walt Sapronov, Esq., Sapronov & Associates, 
 P.C., 1200 Abernathy Rd. Ste 1700, Atlanta, GA  30328. 
  
  
                                     FEDERAL COMMUNICATIONS COMMISSION 
  
  
  
  
                                     Christopher L. Killion 
                                     Deputy Chief 
                                     Enforcement Bureau 
  


                                       2 
                        Federal Communications Commission            DA 18-655 

                                  Before the 
                        Federal Communications Commission 
                             Washington, D.C. 20554 
 
 
In the Matter of                       )     
                                       )     
EBSCO Sign Group, LLC                  )       File No.:  EB-SED-17-00024691 
                                       )       Acct. No.:  201832100021 
                                       )       FRN:  0027631522 
                                       ) 
                                        
                              CONSENT DECREE 
 
      1. The Enforcement Bureau of the Federal Communications Commission and EBSCO Sign 
Group, LLC (EBSCO), by their authorized representatives, hereby enter into this Consent Decree for the 
purpose of terminating the Enforcement Bureau s investigation into whether EBSCO 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 EBSCO is 
               subject by virtue of its business activities, including but not limited to the 
               Equipment 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 EBSCO who perform, or 
               supervise, oversee, or manage the performance of, duties that relate to EBSCO s 
               responsibilities under the Communications Laws, including the Equipment 
               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 (2017) (Equipment Authorization Order).  This settlement resolves violations prior to the effective 
date of the amended rules and sets forth obligations for compliance with the current rules. 
3 47 U.S.C. § 151 et seq. 
                         Federal Communications Commission            DA 18-655 

             (h)  EBSCO  or  Company  means EBSCO Sign Group, LLC and its affiliates, 
                subsidiaries, predecessors-in-interest, and successors-in-interest. 
             (i)  Effective Date  means the date by which both the Bureau and EBSCO have signed 
                the Consent Decree. 
             (j)  Equipment 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 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 in File No. EB-
                SED-17-00024691 regarding whether EBSCO violated the Equipment Marketing 
                Rules.6 
             (l)  Operating Procedures  means the standard internal operating procedures and 
                compliance policies established by EBSCO to implement the Compliance Plan. 
             (m)  Parties  means EBSCO 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 Revised Letter of Inquiry from Aspasia A. Paroutsas, Chief, Spectrum Enforcement Division, FCC 
 Enforcement Bureau, to Tim Collins, President and Chief Executive Officer, EBSCO Signs and Displays (July 21, 
 2017) (LOI) (on file in EB-SED-17-00024691). 
 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). 

                                       2 
                         Federal Communications Commission            DA 18-655 

first been properly authorized, identified, and labeled in accordance with the Rules, with limited 
exceptions.10 
       5. EBSCO is an Alabama-based company that imports light-emitting diode (LED) modules for 
assembly into LED signs, which the company then advertises and sells.11  On July 12, 2017, after 
 reviewing a complaint, the Bureau s Spectrum Enforcement Division issued a Letter of Inquiry (LOI) to 
 EBSCO, directing it to submit a sworn written response to a series of questions relating to its marketing 
 of LED signs in the United States.12  The investigation revealed that EBSCO violated the Equipment 
 Marketing Rules by marketing LED signs without the required equipment authorization, labeling, and 
 user manual disclosures, and by failing to retain required test records.13  After receiving the LOI, EBSCO 
acted to bring the models at issue into compliance with the Commission s Equipment Marketing Rules, 
by ensuring that each was properly tested, authorized, and accompanied by the proper disclosures.14  
EBSCO received one complaint of interference concerning one model marketed by the Company during 
 the period covered by the Investigation.15  The Company achieved full compliance with the relevant 
 Equipment Marketing Rules in May 2018 for the LED signs at issue.16 
       6. The Bureau and EBSCO 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.  EBSCO 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, EBSCO agrees to the terms, 
                                                      
 10 See id. §§ 2.803(b), (c). 
 11 See Letter of Inquiry Response from Walt Sapronov, Sapronov & Associates, P.C., Counsel for EBSCO Sign 
 Group, LLC, to Christopher Sova, Investigations and Hearings Division, FCC Enforcement Bureau (Aug. 15, 2017) 
 (LOI Response). 
 12 See supra note 6.   
 13 See, e.g., LOI Response; Supplemental Letter of Inquiry Response from Walt Sapronov, Sapronov & Associates, 
P.C., Counsel for EBSCO Sign Group, LLC, to Eric Ehrenreich, Spectrum Enforcement Division, FCC Enforcement 
Bureau (Oct. 12, 2017); Supplemental Letter of Inquiry Response from Walt Sapronov, Sapronov & Associates, 
P.C., Counsel for EBSCO Sign Group, LLC, to Eric Ehrenreich, Spectrum Enforcement Division, FCC Enforcement 
Bureau (Nov. 22, 2017); Supplemental Letter of Inquiry Response from Walt Sapronov, Sapronov & Associates, 
P.C., Counsel for EBSCO Sign Group, LLC, to Eric Ehrenreich, Spectrum Enforcement Division, FCC Enforcement 
Bureau (Jan. 23, 2018); Supplemental Letter of Inquiry Response from Walt Sapronov, Sapronov & Associates, 
P.C., Counsel for EBSCO Sign Group, LLC, to Eric Ehrenreich, Spectrum Enforcement Division, FCC Enforcement 
Bureau (April 16, 2018) (all on file in EB-SED-17-00024691). 
 14 Id.; see, also Email and attachments from Nicole Bilodeau, Sapronov & Associates, P.C., Counsel for EBSCO 
Sign Group, LLC to Eric Ehrenreich, Spectrum Enforcement Division, FCC Enforcement Bureau (Mar. 6, 2018, 
14:30 EST) (on file in EB-SED-17-00024691). 
 15 See LOI Response at 6. 
 16 Cf. 47 CFR §§ 2.803, 2.955, 15.19, 15.21, 15.101, 15.105 (2017).   

                                       3 
                         Federal Communications Commission            DA 18-655 

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 EBSCO 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 EBSCO s basic qualifications to be a Commission licensee or hold Commission licenses 
 or authorizations.17 
       11. Admission of Liability.  EBSCO 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 Marketing Rules in effect during 
the Investigation. 
       12. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, EBSCO 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 EBSCO 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 Marketing Rules prior to assuming his or her duties. 
       13. Compliance Plan.  For purposes of settling the matters set forth herein, EBSCO 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 Marketing Rules, EBSCO will implement, at a 
 minimum, the following procedures: 
             (a) Operating Procedures.  Within thirty (30) calendar days after the Effective Date, 
                EBSCO shall establish Operating Procedures that all Covered Employees must 
                follow to help ensure EBSCO s compliance with the Equipment Marketing Rules.  
                EBSCO s Operating Procedures shall include internal procedures and policies 
                specifically designed to ensure that all radio frequency devices to be marketed by 
                EBSCO are properly authorized and compliant with the applicable technical and 
                administrative standards and requirements prior to the initiation of marketing.18  
                Additionally, EBSCO will establish a procedure for retaining documentation 
                supporting device compliance prior to the initiation of marketing.19  EBSCO shall 
                also develop a Compliance Checklist that describes the steps that a Covered 
                Employee must follow to ensure compliance with the Equipment 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 
                Marketing Rules and set forth the Operating Procedures that Covered Employees 
                shall follow to help ensure EBSCO s compliance with the Equipment Marketing 
                Rules.  EBSCO shall periodically review and revise the Compliance Manual as 
                                                      
 17 See 47 CFR § 1.93(b). 
 18 See supra note 9 and accompanying text. 
 19 See 47 CFR §§ 2.938, 2.945 (2018); id. § 2.955 (2017); see also Equipment Authorization Order, 32 FCC Rcd at 
 8786-88, Appx. A. 

                                       4 
                         Federal Communications Commission            DA 18-655 

                necessary to ensure that the information set forth therein remains current and 
                accurate.  EBSCO shall distribute any revisions to the Compliance Manual promptly 
                to all Covered Employees. 
             (c) Compliance Training Program.  EBSCO shall establish and implement a 
                Compliance Training Program in compliance with the Equipment Marketing Rules 
                and the Operating Procedures.  As part of the Compliance Training Program, 
                Covered Employees shall be advised of EBSCO s obligation to report any 
                noncompliance with the Equipment 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.  EBSCO 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.  EBSCO shall report any noncompliance with the Equipment 
 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 EBSCO 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 
 EBSCO has taken or will take to prevent the recurrence of any such noncompliance.  All reports of 
 noncompliance shall be submitted to Matthew L. Conaty, 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 Eric.Ehrenreich@fcc.gov. 
       15. Compliance Reports.  EBSCO 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 EBSCO s efforts 
                during the relevant period to comply with the terms and conditions of this Consent 
                Decree and the Equipment Marketing Rules.  In addition, each Compliance Report 
                shall include a certification by the Compliance Officer, as an agent of and on behalf 
                of EBSCO, stating that the Compliance Officer has personal knowledge that 
                EBSCO:  (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.20 
             (c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
                Officer, as an agent of and on behalf of EBSCO, shall provide the Commission with 
                a detailed explanation of the reason(s) why and describe fully:  (i) each instance of 

                                                      
 20 47 CFR § 1.16. 

                                       5 
                         Federal Communications Commission            DA 18-655 

                noncompliance; (ii) the steps that EBSCO 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 EBSCO 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 Matthew L. Conaty, 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 Eric.Ehrenreich@fcc.gov. 
       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.  EBSCO will pay a civil penalty to the United States Treasury in the amount 
 of fifty-five thousand dollars ($55,000) within thirty (30) calendar days of the Effective Date.  EBSCO 
shall send electronic notification of payment to Eric Ehrenreich at Eric.Ehrenreich @fcc.gov and to 
SED s mailbox at EB-SED-Response@fcc.gov on the date each 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.21  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, EBSCO 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.  EBSCO 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 EBSCO nor the Commission shall contest the validity of the 
 Consent Decree or the Adopting Order, and EBSCO shall waive any statutory right to a trial de novo.  

                                                      
 21 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf. 

                                       6 
                         Federal Communications Commission            DA 18-655 

EBSCO hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice Act22 
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. 
       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 EBSCO does not expressly consent) that 
 provision will be superseded by such Rule or Order. 
       22. Successors and Assigns.  EBSCO 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. 


                                                      
 22 See 5 U.S.C. § 504; 47 CFR §§ 1.1501 1.1530. 

                                       7 
                         Federal Communications Commission            DA 18-655 

       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 
 Deputy Chief 
 Enforcement Bureau 
  
 ________________________________ 
 Date 
  
  
  
  
 ________________________________ 
 Mel Blackwell 
President 
 EBSCO Sign Group, LLC 
  
 ________________________________ 
 Date 


                                       8