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Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of )
) File No. ENF-98-06
ConQuest Operator Services Corp. )
) NAL/Acct. No. 816EF0004
Apparent Liability for Forfeiture )
ORDER OF FORFEITURE
Adopted: July 22, 1999 Released: July 26, 1999
By the Commission:
I. INTRODUCTION
1. With this order, we impose a forfeiture against a carrier that has
repeatedly failed to make its required universal service support
contributions. In the 1996 Telecommunications Act, Congress
expressed the importance of achieving universal service for all
consumers of telecommunications and information services. However,
since the Commission's implementation of universal service support
mechanisms, certain carriers have continually refused to contribute
to the program. This creates a variety of difficulties that the
Commission will no longer countenance. First, delinquent carriers
deprive the universal service support mechanisms of the funds
necessary to carry out the goals of this important statutory
program. The support mechanisms cannot be fully effective if,
because of carrier delinquencies, they are only partially funded.
Second, by withholding their universal service payments, delinquent
carriers likely enjoy a competitive advantage over those carriers
that are complying with the law and our regulations and making their
payments on a timely basis. We view contribution to the universal
service support mechanisms as the obligation of all responsible
carriers, and we will not permit carriers to shirk their
responsibilities in an attempt to gain an advantage over their
law-abiding competitors. Accordingly, with this and subsequent
orders, we demonstrate our intention to move aggressively to ensure
the full and timely funding of the universal service support
mechanisms.
II. BACKGROUND
2. On August 14, 1998, we released a Notice of Apparent Liability (NAL)
in this proceeding. In the NAL, we concluded that, by failing to pay
its universal service contribution for January 1998, ConQuest
Operator Services Corp. appeared to have willfully or repeatedly
violated section 254 of the Communications Act of 1934, as amended,
(the Act) and Commission rules and orders issued pursuant thereto.
We found that ConQuest was apparently liable for a forfeiture in the
amount of seventy thousand and thirty-three dollars ($70,033) for
non-payment of the January 1998 contribution and allowed ConQuest to
respond either by paying the forfeiture, or by presenting evidence
and argument showing why no forfeiture should be imposed or some
lesser amount should be assessed. On September 18, 1998, ConQuest
filed its response to the NAL asking that we either decline entirely
to impose a forfeiture or impose one smaller than that initially
proposed. We have reviewed ConQuest's response and, for the reasons
discussed more fully below, find that it does not justify a
reduction in the proposed forfeiture.
3. As we discussed in the NAL, section 254 of the Act states that
"[e]very telecommunications carrier that provides interstate
telecommunications services shall contribute, on an equitable and
nondiscriminatory basis, to the . . . mechanisms established by the
Commission to preserve and advance universal service." Our
regulations restate the statutory requirement that telecommunication
carriers "must contribute to the universal service support
programs." To this end, we have directed that the Universal Service
Administrative Company (USAC) distribute, receive, and process the
Universal Service Worksheet on which carriers are required to report
the categories of revenue used to calculate their universal service
contribution; from the information in the worksheet, USAC is
required to adjust carriers' contributions in accordance with
contribution factors established by the Commission. In light of the
importance of ensuring universal service, our regulations provide
that the failure "to submit the required . . . contributions may
subject the contributor to the enforcement provisions of the Act and
any other applicable law."
4. As we noted in the NAL, on January 15, 1998, USAC sent ConQuest an
invoice for its January universal service contribution. The invoice
stated that the contribution was due by February 16, 1998. When
ConQuest failed to make payment by the date specified in the
invoice, USAC personnel contacted ConQuest both by telephone and by
mail on several different occasions. Despite these numerous
communications, however, ConQuest declined to comply with its
statutory obligation and pay its assessed contribution for January.
Indeed, on August 14, 1998, when we issued the NAL, ConQuest had
also failed to pay its universal service contributions for the
months of February through June.
III. CONQUEST'S RESPONSE TO THE NAL
5. In its response to the NAL, ConQuest concedes that it, like "all
telecommunications carriers," is "required to pay the [universal
service] fees calculated and assessed by" USAC. In opposing the
imposition of a forfeiture, ConQuest argues primarily that its "new
management" was unaware of the corporation's long-standing
delinquency in its payments to the universal service fund. ConQuest
asserts that this claimed ignorance of its obligations, and its
consequent, "inadvertent failure to pay" its universal service
assessment, grew out of the confusion surrounding the January 1,
1998, acquisition of ConQuest by SmarTalk Teleservices, Inc.
Additionally, ConQuest's response states that its officer
responsible for universal service compliance has left the company
and that, eight months after SmarTalk acquired ConQuest, both
companies relocated their headquarters.
6. Given the confusion that ConQuest claims surrounded its operations
in 1998, "including SmarTalk's lack of knowledge of ConQuest's
failure to pay [and] the logistical confusion resulting from the
acquisition," ConQuest asserts that its violation of the statute and
our rules was merely "inadvertent." Thus, ConQuest argues, its
violation was neither willful nor repeated, as is necessary to
support a forfeiture under section 503(b) of the Act. ConQuest's
response also asserts its good faith in attempting to make good on
its universal service obligations since receiving the NAL. We find
none of ConQuest's arguments to be persuasive.
IV. DISCUSSION
A. ConQuest's Claimed Lack of Knowledge
7. As a basis for avoiding forfeiture in this proceeding, the claimed
ignorance of ConQuest's or SmarTalk's current management is both
legally insufficient and factually suspect. At the outset, we note
that ConQuest has not argued that it has ceased operation as a
corporate entity. The NAL response states that ConQuest is a wholly
owned subsidiary of SmarTalk, but nowhere does it appear that
ConQuest has ceased to exist. Indeed, we note that ConQuest, rather
than SmarTalk or some other entity, responded to the NAL. Given
ConQuest's continued corporate existence, it does not appear that
the claimed ignorance of its parent company (or some other corporate
affiliate) regarding ConQuest's universal service obligations has
any relevance to our assessment of a forfeiture. As an ongoing
entity that provides interstate telecommunications services,
ConQuest is responsible for ensuring its compliance with its
statutory and regulatory obligations, regardless of what knowledge
any parent corporation may have of those obligations.
8. Moreover, a review of the record in this case raises serious
questions about ConQuest's representations that its management was
unaware of its universal service obligations. Before we adopted the
NAL, USAC personnel contacted ConQuest, several times both by phone
and in writing, to discuss its obligation to the universal service
fund. During one of these conversations, on March 9, 1998, Marianne
Townsend, ConQuest's vice president and secretary, stated that
payment of the company's contribution would be sent shortly. On
March 24, 1998, Ms. Townsend stated that the payment had been mailed
on March 16, 1998. On at least three other occasions between May and
August 1998, USAC personnel spoke with representatives of either
ConQuest or SmarTalk about the carrier's delinquent status. On
February 24, 1998, Ed Kincaide, who identified himself as an
employee of SmarTalk, asked for and received by facsimile a copy of
ConQuest's universal service account statement. On August 6, 1998,
Nicole Evans, who identified herself as an employee of New
Millennium, apparently also a ConQuest affiliate, asked for and
received a copy of ConQuest's account statement after describing to
USAC personnel SmarTalk's acquisition of ConQuest and stating that
she would attempt to address ConQuest's delinquent status.
9. This record of USAC's repeated contact with personnel at both
SmarTalk and ConQuest demonstrates more than adequate notice of
ConQuest's universal service obligation. On at least two occasions,
USAC sent statements of ConQuest's account to employees of ConQuest
or its affiliates. These statements were sent at the specific
request of the individuals receiving them and were in addition to
the regular invoices that USAC continued to send ConQuest on a
monthly basis. Moreover, Ms. Townsend, a vice president of ConQuest,
spoke on at least two occasions with USAC and acknowledged the
carrier's delinquency. The record shows more than adequate notice to
both SmarTalk and ConQuest of the substantial delinquency to the
universal service fund.
10. At certain points in its NAL response, ConQuest also appears to
contend that, in assessing a forfeiture, we should be guided by the
actual knowledge of its current management regarding the company's
universal service obligations. It thus appears to contend that the
repeated communications that USAC had with ConQuest employees did
not provide the corporation with effective notice of its universal
service obligations because the company's "new management" allegedly
was unaware of them. This argument wholly disregards fundamental
principles of the law of agency. It is well established that notice
to a corporation's employee of matters actually or apparently within
that employee's area of responsibility serves as notification of the
corporation. Regardless of the actual knowledge of "new management"
on the issue, USAC's records unquestionably reflect contact with the
carrier's employees -- discussed at length above -- that is
sufficient to place the carrier on constructive notice of its
universal service delinquency.
11. We note with some concern the portion of ConQuest's response that
offers Ms. Townsend's departure from the company as a justification
for its alleged ignorance of its universal service obligations.
Shortly after we issued the NAL, Ms. Townsend contacted the
Commission staff responsible for this matter to discuss the NAL,
stating that she was working on the matter as a consultant. It thus
appears that ConQuest's statement regarding Ms. Townsend's departure
from its employ was, although possibly technically accurate, also
disingenuous. We remind ConQuest that, under our rules, the parties
and their lawyers appearing in Commission proceedings are under the
obligation to be truthful and forthright in their written
submissions. In appropriate cases, violation of the duties imposed
in these sections of our rules may serve as an independent basis for
the issuance of a notice of apparent liability or other sanction by
the Commission.
B. ConQuest's Claim of Good-Faith Response to the NAL
12. As an additional factor in its defense, ConQuest points to its
alleged good faith in attempting to bring itself current in its
universal service obligations after receiving the NAL. Thus, it
states that it "has proposed a payment schedule to resolve the
past-due ConQuest payments." The proposal to which ConQuest refers
appears in a September 1, 1998, letter from Thaddeus Bereday,
SmarTalk's vice president and general counsel. That letter proposes
"an immediate 25% downpayment of the current balance owed, as
calculated by USAC, with payment of the remaining balance . . . in
pro rata installments over the next 12 months." The letter further
states that "SmarTalk will commit to paying all additional
[universal service] payment obligations accruing during that
12-month period in a timely manner."
13. ConQuest's subsequent actions fall far short of the optimistic
representations in Mr. Bereday's letter and in the NAL response. On
September 23, 1998, USAC received a payment on ConQuest's account in
the amount of $50,000. At the time, the carrier's outstanding
universal service liability was in excess of $800,000. Indeed, the
payment was less than half of ConQuest's liability for the month of
January alone, $100,067.83. Rather than the promised "immediate 25%
downpayment of the current balance owed," ConQuest has paid less
than 7 percent of its outstanding liability. Furthermore, before its
bankruptcy filing, ConQuest appears to have made little effort to
live up to Mr. Bereday's commitment to make monthly payments on the
delinquency as well as timely paying its newly accruing liability.
Apart from the one-time payment in late September, ConQuest has made
no further universal service payments -- on either its new or its
delinquent obligations. We are therefore doubtful of ConQuest's
professed good-faith desire to bring itself current.
C. Willful and Repeated Nature of ConQuest's Violation
14. Under section 503(b) of the Act, the Commission is empowered to
impose a forfeiture when it has determined that a carrier has
"willfully or repeatedly failed to comply with any of the provisions
of this Act or of any rule, regulation or order issued by the
Commission under this Act." Based on our review of the record in
this proceeding, as described below, we conclude ConQuest's actions
violate section 254(d) and section 54.703(a) of our rules, both of
which impose on interstate carriers the obligation to contribute to
universal service support programs.
15. ConQuest's refusal to make the required contribution for January
continued despite repeated communications from USAC, the
administrator of the universal service program. In at least two
separate letters, USAC informed ConQuest that its universal service
contributions were required both by statute and by the Commission's
rules. USAC also repeatedly contacted ConQuest regarding its
delinquent status. In the face of these repeated communications
regarding its universal service obligation, the carrier's persistent
refusal to make the required payment rises to the level of a willful
failure to comply with section 254 and our rules.
16. We also find that ConQuest's violation of the Act and our rules is a
repeated one within the meaning of section 503(b). As we noted in
the NAL, ConQuest's failure to pay its January universal service
contribution first became a violation of the statute and our
regulations on February 17, 1998, the day after its payment was due.
Each subsequent day on which ConQuest failed to make the required
payment continued the violation and amounted to an additional,
repeated violation of the statute and our rules.
D. Amount of the Forfeiture
17. Section 503(b) of the Act requires that, in determining the amount
of a forfeiture, we "take into account the nature, circumstances,
extent, and gravity of the violation and, with respect to the
violator, the degree of culpability, any history of prior offenses,
ability to pay, and such other matters as justice may require."
ConQuest's NAL response contends that the claimed inadvertence of
the violation "suggests that the extent and gravity of this
violation is de minimis." As we have set out above, we view the
record in this proceeding as supporting a finding that the violation
in the period before the bankruptcy filing was willful, rather than,
as ConQuest contends, merely inadvertent. We further note that
ConQuest has not claimed to have been unable, before its bankruptcy
petition, to pay its universal service obligation; however, apart
from a payment of $50,000 in late September of 1998, ConQuest has
done nothing to reduce its outstanding universal service liability,
which amounted to more than $1.1 million as of December 31, 1998.
18. The provision of universal service throughout the country
represented one of the primary goals of the 1996 Telecommunications
Act. To that end, Congress explicitly provided, in section 254 that:
Consumers in all regions of the Nation, including low-income consumers and
those in rural, insular, and high cost areas, should have access to
telecommunications and information services . . . that are reasonably
comparable to those services provided in urban areas that are available at
rates that are reasonably comparable to rates charged for similar services
in urban areas.
Naturally, the universal service support mechanisms are necessary to
effectuate this central statutory goal. Those mechanisms cannot function
effectively if carriers do not remit their universal service contributions
on a timely and regular basis. We view ConQuest's violation of the Act and
our rules as substantially damaging to a program that is both an important
congressional goal and a primary focus of this Commission. We therefore
impose a forfeiture of $70,033 for its non-payment of its January 1998
contribution as proposed in the NAL.
19. As we discussed in the NAL, this forfeiture consists of two
components. First, we have assessed a figure of $20,000 as a general
penalty for failure to pay the assessed universal service
contribution in an appropriately timely manner. Given the vital
importance of universal service, it is necessary to set a presumed
forfeiture figure that will deter delinquencies regardless of their
amount. The remainder of the forfeiture figure, $50,033, amounts to
one half of the unpaid universal service contribution for January
1998, the delinquency on which we base this forfeiture order. We
have imposed this second component of the forfeiture to recognize
that a delinquent carrier's culpability, and the consequent damage
it causes to the goal of universal service, may vary with the amount
by which it is in arrears. As noted above, the forfeiture imposed in
this order relates to ConQuest's delinquency that accumulated before
the carrier filed for bankruptcy. As a general rule, however, if it
becomes necessary to issue more than one NAL to compel a carrier's
compliance with its universal service obligations, the subsequent
notices may well propose substantially greater forfeitures than
those proposed in this proceeding.
20. Finally, we note with substantial concern the significant pattern of
non-compliance that has emerged during the first year of our
universal service rules. As of February 1, 1999, USAC's records
reflected more than $27.5 million in unpaid universal service
contributions. As we noted at the outset, these delinquencies tend
to undermine the efficiency and effectiveness of the universal
service support mechanisms. Furthermore, recalcitrant carriers may
gain a competitive advantage over those industry members that are
complying with the Act and our rules. Both of these consequences of
non-compliance are unacceptable, and we are moving aggressively to
prevent their continuation. Accordingly, the Commission will be
issuing additional notices of apparent liability and taking other
enforcement action as necessary to ensure full and timely funding of
the universal service support mechanisms. Additionally, those
carriers contemplating continued non-payment should be aware that,
in light of the accumulating record of non-compliance, we are
prepared to impose substantially greater forfeitures in the future.
We originally restricted ourselves to basing the proposed forfeiture
in this proceeding on ConQuest's first month of non-payment.
However, our future notices likely will cover greater periods of
non-payment than a single month; they similarly will be based on
some variant of the above formula, which includes, as a component of
the forfeiture, one half of the unpaid contribution amount for the
period in question.
V. CONCLUSION
21. After reviewing ConQuest's response to the NAL, we find that it has
failed to identify any facts or circumstances to persuade us that
there is any basis for reconsidering the NAL. Neither has ConQuest
shown any mitigating circumstances sufficient to warrant a reduction
of the $70,033 for which we previously found it apparently liable.
VI. ORDERING CLAUSES
22. Accordingly, IT IS ORDERED, pursuant to Section 503(b) of the Act,
47 U.S.C. S: 503(b), and section 1.80(f)(4) of the Commission's
rules, 47 C.F.R. S:1.80(f)(4), that ConQuest Operator Services,
Inc., SHALL FORFEIT to the United States Government the sum of
seventy thousand and thirty-three dollars ($70,033) for violating
the provisions of the Act and the Commission's rules requiring
carriers to make payment to the universal service support
mechanisms.
23. IT IS FURTHER ORDERED that a copy of this Order of Forfeiture shall
be sent by certified United States mail to Thaddeus Bereday, vice
president and general counsel of SmarTalk at 5080 Tuttle Crossing
Boulevard, Dublin, Ohio 43016-3566.
FEDERAL COMMUNICATIONS COMMISSION
Magalie Roman Salas
Secretary
See 47 U.S.C. S: 254(b)(3).
We note that the carrier to which this order is addressed, ConQuest
Operator Services Corp., is now in bankruptcy. This order is issued in
accordance with section 362(b)(4) of the United States Bankruptcy Code, 11
U.S.C. S: 101-1330, as an exercise of the regulatory power of the
Commission to determine the appropriateness of ConQuest's conduct before
its bankruptcy filing. Of course, everything herein shall be subject to
the provisions of the Bankruptcy Code to the extent that those provisions
relate to ConQuest.
ConQuest Operator Services Corp., Notice of Apparent Liability for
Forfeiture, 13 FCC Rcd. 16075 (1998) (NAL).
ConQuest is an inter-exchange carrier based in Dublin, Ohio. On its first
Universal Service Worksheet, it reported total yearly revenues in excess
of $21 million. See FCC Form 457 in Sealed Appendix to NAL.
Section 503 of the Act empowers the Commission to impose a forfeiture when
it has determined that a carrier has "willfully or repeatedly failed to
comply with any of the provisions of this Act or of any rule, regulation
or order issued by the Commission under this Act." 47 U.S.C. S:
503(b)(1)(B).
47 U.S.C. S: 254(d). See also 47 U.S.C. S: 153(44) (defining
"telecommunications carrier"); 47 U.S.C. S: 153(46) (defining
"telecommunications service"); 47 U.S.C. S: 153(43) (defining
"telecommunications").
47 C.F.R. S: 54.703(a).
See FCC Form 457.
See Changes to the Board of Directors of the National Exchange Carrier
Association, Inc., Federal-State Joint Board on Universal Service, Report
& Order and Second Order on Reconsideration, 12 FCC Rcd. 18400, 18424-25,
P:P: 43-45 (1997) (NECA Governance Order). See also 47 C.F.R. S:
54.711(a).
47 C.F.R. S: 54.713.
See NAL, 13 FCC Rcd. at 16078.
Id.
ConQuest Response at 2.
See id. at 3.
Id. at 1.
See id. at 4.
See id. at 3.
See id. at 4.
See id. at 3-4.
See id. at 2.
See NAL, 13 FCC Rcd. at 16078.
See id. See also March 9, 1998 Customer History Sheet in Sealed Appendix 1
to NAL. We issued the NAL with sealed appendices because of
confidentiality concerns that arose in a related proceeding. We note,
however, that ConQuest has not requested confidential treatment for any of
its universal service materials. Accordingly, this order discusses certain
information in the sealed appendices that accompanied the NAL.
USAC's records indicate that USAC personnel spoke with employees at
ConQuest or its affiliates on May 19, July 31 and August 6, 1998. See
Robert Haga Affidavit at 2.
See id.
See id.
See id.
See ConQuest Response at 3 (discussing knowledge of "Conquest's new
management").
Id.
See, e.g., Restatement (Second) of Agency S: 268.
See also 47 U.S.C. S: 217 ("the act omission, or failure of any officer,
agent, or other person acting for or employed by any common carrier . . .
acting within the scope of his employment, shall in every case be also
deemed to be the act, omission, or failure of such carrier").
See ConQuest Response at 3.
Our Rule 1.17 prohibits the filing of written statements with the
Commission that contain "any misrepresentation or willful material
omission bearing on any matter within the jurisdiction of the Commission."
47 C.F.R. S: 1.17. Similarly, Rule 1.52 provides that counsel's
subscription of any document filed with the Commission constitutes a
representation that the lawyer "has read the document; that to the best of
his knowledge, information and belief there is good ground to support it;
and that it is not interposed for delay." Id. S: 1.52.
ConQuest Response at 3.
Mr. Bereday's letter is attached as Exhibit A to ConQuest's Response.
ConQuest Response, Exhibit A.
Id.
We recognize that, after its January 19, 1999, bankruptcy petition,
ConQuest was not in a position to make payments on its universal service
obligation. Our analysis of ConQuest's payment failures, despite its
representations that payment would be made, is therefore limited to the
period before the bankruptcy filing.
47 U.S.C. S: 503(b)(1)(B).
See 47 U.S.C. S: 254(d); 47 C.F.R. S: 54.703(a).
See February 26, 1998 letter of Nancy Thomas to ConQuest in Sealed
Appendix 1 to NAL; March 6, 1998 letter from USAC Billing and Collection
Manager to Marianne Townsend in Sealed Appendix 1 to NAL.
See United States v. Summa Corp., 447 F. Supp. 923, 928 (D. Nev. 1978)
(continued non-compliance with Act in the face of warning from Commission
amounts to willful violation under section 503(b)(1)(B)). Indeed, we have
held that a party need not have known that it was acting unlawfully to
support a finding of willfulness under section 503(b) of the Act. That
section requires only a showing that the party knew it was doing the acts
in question. See The Computer Force, Letter Ruling, 7 FCC Rcd 2687, 2687
(Field Operations Bur. 1992); Desert Empire Television Corp., Forfeiture
Order, 88 FCC2d 1413, 1417, P: 11 (1982).
See NAL, 13 FCC Rcd at 16079.
See United States v. WIYN Radio, Inc., 614 F.2d 495, 497 (5th Cir. 1980)
("continuous violation is made a separate offense each day it occurs and
so becomes `repeated' on the second day of the violation") (quoting S.
Rept. No. 95-580, at 24, reprinted in 1978 U.S.C.C.A.N. 109, 132
(legislative history of amendment and reenactment of 47 U.S.C. S:
503(b))); United States v. Daniels, 418 F. Supp. 1074, 1081 (D.S.D. 1976)
(violation of Commission rule for 14 consecutive days qualified as
"repeated" under section 503(b)(1)(B)). As noted above, these findings as
to continuing violation relate to the period prior to the bankruptcy
petition, when ConQuest was under no legal disability from making its
payments.
47 U.S.C. S: 503(b)(2)(D).
ConQuest Response at 4.
Pub. L. No. 104-104, 110 Stat. 56 (1996).
47 U.S.C. S: 254(b)(3).
On January 19, 1999, during the pendency of this forfeiture proceeding,
ConQuest declared bankruptcy. This does not, however, affect our decision
to impose a forfeiture for ConQuest's statutory and rule violations for
the period prior to the bankruptcy filing. Particularly where, as here, a
carrier's violation reduces the funds available for a congressionally
designated purpose, we will impose the forfeiture for the pre-bankruptcy
conduct notwithstanding the subsequent declaration of bankruptcy.
See NAL, Appendix 2.
This figure represents only the unpaid contributions of carriers that have
filed their Universal Service Worksheets, but then declined to pay some
portion of the requested funds. We also note that other carriers have
declined even to file their worksheet. Carriers in this category also will
be the focus of our future enforcement actions.
See supra P: .
Naturally, enforcement of the forfeiture obligation imposed in this order
will be subject to the appropriate standards associated with ConQuest's
bankruptcy proceeding.
In his September 1, 1998, letter to USAC, Mr. Bereday requested that all
communications regarding either ConQuest or SmarTalk be directed to him.
Federal Communications Commission FCC 99-194
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Federal Communications Commission FCC 99-194
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Federal Communications Commission FCC 99-194
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Federal Communications Commission FCC 99-194
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Federal Communications Commission FCC 99-194
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Federal Communications Commission FCC 99-194
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