Before the

**Federal Communications Commission**

**Washington, D.C. 20554**

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| In the Matter of                 | ) | File Number EB-03-LA-286        |
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| Jack Gerritsen                   | ) | NAL/Acct. No. 200532900002      |
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| Bell, California                 | ) | FRN 0005240072                  |
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|                                  | ) |                                 |
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|                                  | ) |                                 |
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|                                  | ) |                                 |
+----------------------------------+---+---------------------------------+

## FORFEITURE ORDER

**Adopted: November 30, 2005 Released: December 2, 2005**

By the Regional Director, Western Region, Enforcement Bureau:

# I. INTRODUCTION

1.  In this *Forfeiture Order* ("*Order*"), we issue a monetary
    forfeiture in the amount of twenty-one thousand dollars (\$21,000)
    to Jack Gerritsen ("Gerritsen"), for willful and repeated violation
    of Section 333 of the Communications Act of 1934, as amended
    (\"Act\").[^1] On December 2, 2004, the Enforcement Bureau's Los
    Angeles Office issued a *Notice of Apparent Liability for
    Forfeiture* ("*NAL*") in the amount of \$21,000 to Gerritsen after
    determining that Gerritsen apparently willfully, repeatedly, and
    maliciously interfered with the radio communications of authorized
    users in the Amateur Radio Service. In this *Order*, we consider
    Gerritsen's various arguments concerning his authority to operate,
    his ability to cause interference, and his inability to pay the
    forfeiture.

# II. BACKGROUND

2.  On November 14, 2001, the Commission's Wireless Telecommunications
    Bureau ("WTB") set aside, on its own motion, amateur radio station
    license KG6IRO, which was granted to Gerritsen on November 7,
    2001.[^2] Gerritsen was notified that the action was taken because
    of complaints about the operation of Gerritsen's station and because
    of questions regarding his qualification to be a licensee in light
    of his 1999 arrest and 2000 conviction for radio interference to
    police communications.[^3] Gerritsen was warned that "you have no
    authority to operate radio transmitting equipment, and such
    operation would be a violation of Section 301 of the Communications
    Act of 1934, as amended, 47 U.S.C. Section 301, subjecting you to
    monetary penalties and imprisonment."[^4] On January 30, 2002, WTB
    notified Gerritsen that his amateur application had been
    dismissed.[^5] Therefore, Gerritsen does not hold a valid amateur
    license and has no authority to operate.

3.  Beginning in July 28, 2003, the Commission's Los Angeles Office
    began receiving complaints of deliberate interference to radio
    communications over local Amateur, Business and Public Safety radio
    repeater systems.[^6] The complaints alleged that the person making
    the transmissions identified himself as "KG6IRO." The Los Angeles
    Office conducted an investigation which identified Gerritsen as the
    source of the on-going unlicensed operation. Based upon this
    evidence, a Notice of Apparent Liability for \$10,000 was issued to
    Gerritsen on June 15, 2004, for willful and repeated unlicensed
    operation of a radio station in the Amateur Radio Service in
    violation of Section 301 of the Act ("*Section 301 NAL*").[^7]

4.  On June 15, 2004, agents from the Los Angeles Office observed a
    signal on 146.405 MHz monopolizing the authorized 147.435/146.405
    MHz repeater. Using mobile direction finding techniques, the agents
    located the source of the signal to Gerritsen's residence at 6217 ½
    Palm Avenue in Bell, California. For almost an hour, Gerritsen
    maintained a steady transmission on the input frequency of 146.405
    MHz which kept all other operators from using the repeater.

5.  On June 24, 2004, the Los Angeles Office received a complaint from
    an amateur operator which recounted a broadcast made that day, on
    the repeater's output frequency, 147.435 MHz, by a man identifying
    himself as Jack Gerritsen, announcing a "hostile takeover" of the
    frequency. On July 16, 2004, the Los Angeles Office received a
    complaint alleging that Gerritsen was interfering with fire watch
    communications on the authorized 147.105/146.505 MHz repeater. In
    response, Los Angeles agents went to Gerritsen's residence to
    investigate the complaint. Gerritsen admitted operating on the
    147.105/146.505 MHz repeater to the agents. The agents warned
    Gerritsen that he did not have authority to transmit on any amateur
    band and told him to vacate all amateur frequencies.

6.  On July 24, 2004, using mobile direction finding techniques, an
    agent from the Los Angeles Office positively identified radio
    transmissions emanating from Gerritsen's residence as the source of
    radio signals being transmitted on another authorized amateur
    repeater, the 145.240/144.640 repeater. These communications
    consisted of a 20 minute prerecorded message by Gerritsen
    threatening to "jam" any operator that would "jam" him along with a
    recording of the tone used by the phone company to indicate a phone
    is off the hook. Throughout the recording, Gerritsen identified
    himself by the call sign "KG6IRO." During Gerritsen's transmissions,
    no other amateur operator was able to use the 145.240/144.640
    repeater. On July 26, 2004, the Los Angeles Office received a
    complaint from yet another amateur operator stating that Gerritsen
    had played a recording for 48 minutes without interruption over the
    authorized "Keller Peak" repeater on 146.985/146.385 MHz.

7.  On September 13, 2004, the Los Angeles Office received a complaint
    from an Amateur Relay Radio League ("ARRL") Official Observer,
    alleging that Gerritsen deliberately and maliciously interfered with
    the Young Hams Net using the authorized Catalina Island Amateur
    Repeater Association ("CARA") repeater on 147.090/147.690 MHz on
    September 8, 2004.[^8] The complaint alleged that the prerecorded
    messages transmitted by Gerritsen were so intense and vile they were
    reported to have reduced one of the younger participants to tears.

8.  On September 15, 2004, using mobile direction finding techniques, an
    agent from the Los Angeles Office positively identified radio
    transmissions emanating from Gerritsen's residence as the source of
    radio signals monopolizing the input frequency of 147.690 MHz for
    the CARA repeater on 147.090/147.690 MHz. The agent heard Gerritsen
    transmit prerecorded messages, and also sounds, static, and tones,
    as the members of the Young Hams Net attempted to communicate.
    During Gerritsen's transmissions, which lasted for almost ten
    minutes, no other amateur operator was able to use the repeater.

9.  On December 2, 2004, the Commission's Los Angeles Office issued a
    *NAL* in the amount of \$21,000 to Gerritsen.[^9] In the *NAL*
    issued by the Los Angeles Office, the Office found that Gerritsen
    apparently willfully, repeatedly, and maliciously caused
    interference to authorized users in the Amateur Radio Service on
    June 15, 2004, July 24, 2004 and September 15, 2004.[^10] Gerritsen
    filed a response to the *NAL* on December 17, 2004 ("*Response*").
    In his *Response*, Gerritsen "denies those activities alleged
    against \[him\] that if true would be illegal." Gerritsen argues
    that his amateur license has not been suspended, terminated,
    revoked, modified or set aside; that no record of his license set
    aside exists; that he did not engage in interference; that the
    actual motive behind the *NAL* is to silence his messages in
    violation of the U.S. Constitution; and that he does not have
    sufficient income to pay the forfeiture amount proposed in the
    *NAL*.[^11]

# III. DISCUSSION

10. The proposed forfeiture amount in this case was assessed in
    accordance with Section 503(b) of the Act,[^12] Section 1.80 of the
    Rules,[^13] and *The Commission's Forfeiture Policy Statement and
    Amendment of Section 1.80 of the Rules to Incorporate the Forfeiture
    Guidelines*.[^14] In examining Gerritsen's *Response*, Section
    503(b) of the Act requires that the Commission 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 other such matters as justice
    may require.[^15]

11. Section 333 of the Act states that no person shall willfully or
    maliciously interfere with, or cause interference to, any radio
    communications of any station licensed or authorized by or under
    this Act or operated by the United States Government. The
    legislative history for Section 333 identifies willful and malicious
    interference as "intentional jamming, deliberate transmission on top
    of the transmissions of authorized users already using specific
    frequencies in order to obstruct their communications, repeated
    interruptions, and the use and transmission of whistles, tapes,
    records, or other types of noisemaking devices to interfere with the
    communications or radio signals of other stations."[^16] One
    hallmark of willful and malicious interference in the amateur radio
    service is the refusal by an operator to allow any other operator to
    talk.[^17] This can occur when an operator increases power so as to
    "capture" a repeater, to the exclusion of any other operators.[^18]
    It can also occur when an operator transmits on an amateur frequency
    slightly different than another amateur frequency but at equal
    strength. This results in an audible tone, or whistle, with a
    frequency equal to the difference in the frequencies of the two
    competing signals. This tone is often referred to as "heterodyne"
    interference.[^19]

12. We first address Gerritsen's argument that his amateur license was
    not set aside and that no record of the set aside exists. In fact,
    Gerritsen received an official notice from the Commission informing
    him that his license was set aside and that his application was
    returned to pending status.[^20] He also received an official notice
    from the Commission when his pending application was dismissed.[^21]
    The Commission received notice that Gerritsen received each piece of
    correspondence.[^22] Consequently, we find this argument to be
    without merit.[^23]

13. Next we address Gerritsen's arguments concerning the three instances
    of interference that he caused on June 15, 2004, July 24, 2004 and
    September 15, 2004. On June 15, 2004, Los Angeles agents, using
    direction finding techniques, located the source of a signal on
    146.405 MHz, monopolizing the 146.405 MHz input frequency to the
    146.435/146.405 repeater, to Gerritsen's residence. While Gerritsen
    argues that his location is too distant and too insignificant in
    power to prevent other operators from using the repeater, he
    acknowledges that he "may have keyed \[his\] transmitter
    continuously in a 'duplex' mode of operation that allows \[him\] to
    hear 'feed back' when \[his\] signal goes thru (sic) the repeater,
    so \[he\] can then pick up the microphone and utter a few words
    before being jammed by another operator . . . ." In other words,
    Gerritsen acknowledges his efforts to monopolize the 146.435/146.405
    repeater.

14. On July 24, 2004, Los Angeles agents, using direction finding
    techniques, located the source of a signal on the 145.240/144.640
    repeater to Gerritsen's residence. Because Gerritsen effectively
    captured the 145.240/144.640 repeater during that time, and because
    of his intentional jamming, no authorized amateur operator was able
    to use the repeater. Gerritsen makes no statement, and offers no
    evidence, to refute this allegation.[^24]

15. On September 15, 2004, using mobile direction finding techniques, an
    agent from the Los Angeles Office determined that radio
    transmissions emanating from Gerritsen's residence captured the CARA
    repeater and transmitted on top of the Young Hams Net that was
    attempting to use the repeater at that time. In addition, Gerritsen
    apparently caused interference to occur, using the CARA repeater,
    and prohibited any communications to occur on the repeater at that
    time. Gerritsen argues that even if such interference took place, it
    is not evidence that other amateurs were unable to use the repeater
    because his signal was not the strongest signal reaching the CARA
    antenna. However, in describing the CARA repeater, Gerritsen also
    states that "the fact that my signal overrides or covers a signal
    out of a repeater, should be no cause for your *NAL*, as my signal
    often is a response to the fact that a repeater is turned on and
    becomes available for use . . . ." Gerritsen also states that he has
    increased by tenfold the power of the transmitter that he uses so
    that other operators can no longer override his signal.

16. In each of the three instances cited in the *NAL*, Los Angeles
    agents used direction finding equipment to locate the source of the
    interfering signal to Gerritsen's residence. In each instance, a Los
    Angeles agent monitored the signal being transmitted and heard the
    interference caused by Gerritsen. Gerritsen produced no evidence to
    refute the agents' findings.[^25] He also described in detail his
    ability to cause the interference on the days cited in the *NAL*.
    Consequently, we find Gerritsen's arguments that he did not cause
    the interference described on the three days cited in the *NAL* to
    be without merit.[^26]

17. We now consider Gerritsen's claim that the content of his
    communications and transmissions are protected by the First
    Amendment of the U.S. Constitution.[^27] The content of Gerritsen's
    transmissions are not at issue here, and, therefore, the forfeiture
    does not impair Gerritsen's First Amendment rights. As described
    above, willful and malicious interference includes intentional
    jamming, deliberate transmission on top of the transmissions of
    authorized users already using specific frequencies in order to
    obstruct their communications, repeated interruptions, and the use
    and transmission of whistles, tapes, records, or other types of
    noisemaking devices. Gerritsen's acts of transmitting obstructed the
    communications of licensed amateur operators by capturing the
    repeaters and monopolizing them, and by overriding and transmitting
    on top of the transmissions of the licensed operators. Gerritsen's
    actions violated Section 333 because his transmissions, regardless
    of their content, caused interference to licensed amateur
    operators.[^28] Therefore, we find this argument to be without merit
    as well.

18. Finally, we address Gerritsen's claim that he is unable to pay the
    proposed forfeiture. Specifically, Gerritsen states that he did not
    file any tax returns for the most recent three year period because
    his income was insufficient to require a tax return. We note that in
    the *NAL*, the Los Angeles Office instructed Gerritsen, if he sought
    cancellation or reduction of the forfeiture, to supply:

    \(1\) federal tax returns for the most recent three-year period; (2)
    financial statements prepared according to generally accepted
    accounting practices (\"GAAP\"); or (3) some other reliable and
    objective documentation that accurately reflects the petitioner's
    current financial status. Any claim of inability to pay must
    specifically identify the basis for the claim by reference to the
    financial documentation submitted.[^29]

    Gerritsen submitted no documentation that reflects his current
    financial status. Therefore, he has provided us with no basis to
    support cancellation or reduction of the forfeiture based on his
    inability to pay.[^30]

19. We have examined Gerritsen's *Response* to the *NAL* pursuant to the
    statutory factors above, and in conjunction with the *Forfeiture
    Policy Statement*. As a result of our review, we conclude that
    Gerritsen willfully and repeatedly violated Section 333 of the Act.
    Considering the entire record and the factors listed above, we find
    that neither reduction or cancellation of the proposed \$21,000
    forfeiture is warranted

# IV. ORDERING CLAUSES

20. **ACCORDINGLY, IT IS ORDERED** that, pursuant to Section 503(b) of
    the Communications Act of 1934, as amended ("Act"), and Sections
    0.111, 0.311 and 1.80(f)(4) of the Commission's Rules, Jack
    Gerritsen **IS LIABLE FOR A MONETARY FORFEITURE** in the amount of
    \$21,000 for willfully and repeatedly violating Section 333 of the
    Act.[^31]

21. Payment of the forfeiture shall be made in the manner provided for
    in Section 1.80 of the Rules within 30 days of the release of this
    *Order*. If the forfeiture is not paid within the period specified,
    the case may be referred to the Department of Justice for collection
    pursuant to Section 504(a) of the Act.[^32] Payment of the
    forfeiture must be made by check or similar instrument, payable to
    the order of the Federal Communications Commission.  The payment
    must include the NAL/Acct. No. and FRN No. referenced above. 
    Payment by check or money order may be mailed to Federal
    Communications Commission, P.O. Box 358340, Pittsburgh, PA
    15251-8340.  Payment by overnight mail may be sent to Mellon
    Bank /LB 358340, 500 Ross Street, Room 1540670, Pittsburgh, PA
    15251.   Payment by wire transfer may be made to ABA
    Number 043000261, receiving bank Mellon Bank, and account
    number 911- 6106. Requests for full payment under an installment
    plan should be sent to: Associate Managing Director -- Financial
    Operations, Room 1A625, 445 12th Street, S.W., Washington, D.C.
    20554.[^33]

22. **IT IS FURTHER ORDERED** that a copy of this *Order* shall be sent
    by First Class Mail and Certified Mail Return Receipt Requested to
    Jack Gerritsen at his address of record.

**FEDERAL COMMUNICATIONS COMMISSION**

Rebecca L. Dorch

Regional Director, Western Region

Enforcement Bureau

[^1]: 47 U.S.C. § 333.

[^2]: The action was taken pursuant to Section 1.113(a) of the Rules
    which states that "within 30 days after public notice has been given
    of any action taken pursuant to delegated authority, the person,
    panel, or board taking the action may modify or set it aside on its
    own motion." 47 C.F.R. § 1.113(a).

[^3]: *See* November 21, 2001, letter from W. Riley Hollingsworth,
    Special Counsel, Enforcement Bureau, Federal Communications
    Commission, to Mr. Jack Gerritsen ("*Enforcement Bureau Letter*").
    On December 28, 1999, Gerritsen was arrested by the California
    Highway Patrol and charged with violating sections of the California
    Penal Code that prohibit intercepting, obstructing and/or
    interfering with police radio communications. Gerritsen was
    convicted of interfering with police radio communications on June 6,
    2000. Gerritsen's subsequent probation included that he not possess
    any radio transmitting devices and not interfere with police or FCC
    activity. *See* Municipal Court of Long Beach Judicial District,
    County of Los Angeles, State of California, Case No. 0SE01792:
    People vs. Jack Gerritsen, June 6, 2000. On January 29, 2002,
    Officers from the Bell Police Department and the California Highway
    Patrol arrested Gerritsen for violation of his probation. *See* Bell
    Police Department-Supplemental/Arrest Report 01-6723, dated January
    29, 2002. On May 7, 2002, Gerritsen was found to have violated his
    probation and sentenced. *See* The Municipal Court of Long Beach
    Judicial District County of Los Angeles, State of California, Case
    No. 0SE01792: People vs. Jack Gerritsen, May 7, 2002, Affirmed in
    part, reversed in part, BR 042769, Los Angeles County Superior
    Court, September 22, 2004.

[^4]: *Enforcement Bureau Letter*.

[^5]: *See* Notice Of Dismissal, dated January 30, 2002 ("*Dismissal
    Notice*").

[^6]: *See e.g.,* September 19, 2003, Amateur Radio Relay League
    ("ARRL") Complaint; November 6, 2003 Bell Gardens Police Department
    Sgt. Jerry Winfrey's complaint.

[^7]: 47 U.S.C. § 301. A Forfeiture Order concerning the same violation
    was issued for \$10,000 on October 5, 2004. *Jack Gerritsen*, 19 FCC
    Rcd 19,520 (EB 2004), *petition for reconsideration denied* 20 FCC
    Rcd 4273 (EB 2005).

[^8]: The Young Hams Net is directed by a 15 year old high school
    student and comprised of young people between the ages of seven and
    twenty.

[^9]: *Notice of Apparent Liability for Forfeiture,* NAL/Acct. No.
    200532900002 (Enf. Bur., Western Region, Los Angeles Office,
    released December 2, 2004). The Los Angeles Office found, based on
    the criteria in Section 503(b)(2)(D) of the Act, and the upward
    adjustment criteria in the Forfeiture Policy Statement, that an
    upward adjustment of the base forfeiture amount of \$7,000 was
    warranted because Gerritsen's willful, repeated, and malicious
    interference with the radio communications of licensed amateur
    stations was egregious. The Los Angeles Office found that Gerritsen
    knowingly operated, without a license, radio transmission equipment
    while announcing his intentions to interfere with licensed amateur
    operators, and that he willfully and maliciously interfered with the
    transmissions of licensed amateurs on a repeated basis, disregarding
    the Commission's requirement that amateur stations be licensed and
    operated according to good amateur practice.

[^10]: While the *NAL* details complaints alleging Gerritsen caused
    interference on multiple occasions, the Los Angeles Office found
    that Gerritsen caused interference on June 15, 2004, July 24, 2004
    and September 15, 2004.

[^11]: Gerritsen also argues that his criminal case, Municipal Court of
    Long Beach Judicial District, County of Los Angeles, State of
    California, Case No. 0SE01792: People vs. Jack Gerritsen, was
    reversed by the Los Angeles County Superior Court. In fact, only the
    order of the trial court on November 22, 2002, which revoked
    Gerritsen's probation and lifted the stay on his previously imposed
    jail sentence was reversed. Gerritsen's underlying conviction was
    not reversed. *See* n. 3, *supra.*

[^12]: 47 U.S.C. § 503(b).

[^13]: 47 C.F.R. § 1.80.

[^14]: 12 FCC Rcd 17087 (1997), recon. denied, 15 FCC Rcd 303 (1999).

[^15]: 47 U.S.C. § 503(b)(2)(D).

[^16]: H.R. Rep. No. 101-316, at 13 (1989). Section 97.101(a) of the
    Commission's Rules ("Rules") states that "each amateur station must
    be operated in accordance with good engineering and good amateur
    practice." 47 C.F.R. § 97.101(a). Section 97.101(d) of the Rules
    states that "\[n\]o amateur operator shall willfully or maliciously
    interfere with or cause interference to any radio communication or
    signal." 47 C.F.R. § 97.101(d).

[^17]: *U.S. v. Richard*, (1998 WL 830654 (E.D. La.)). *See also John B.
    Genovese*, 10 FCC Rcd 7594 (CIB 1995).

[^18]: The "capture effect\" occurs when the repeater, or any FM
    receiver, responds to only the strongest signal received on a
    frequency and rejects any weaker competing signals. *See Unlicensed
    Operation in the TV Broadcast Bands*, 19 FCC Rcd 10018, 10036
    (2004).

[^19]: *9 kHz Channel Spacing for AM Broadcasting*, 88 FCC 2d 290, ¶ 69,
    (1981).

[^20]: *See Enforcement Bureau Letter, supra.*

[^21]: *See Dismissal Notice, supra*.

[^22]: Gerritsen signed the "Return Receipt Requested" postal card when
    he received the *Enforcement Bureau Letter*. He also sent a reply to
    WTB when he received the *Dismissal Notice.*

[^23]: Gerritsen also demands that certain complaints and documents
    described in the *NAL* be made available to him. We note that such
    requests are governed by the Commission's procedures concerning
    Freedom of Information Act ("FOIA") requests. These procedures are
    found in Sections 0.441 -- 0.470 of the Rules. 47 C.F.R. §§ 0.441 --
    0.470.

[^24]: Gerritsen does argue that his transmissions on this date are
    protected by the U.S. Constitution. We address that argument in ¶
    17, below.

[^25]: In response to a Notice of Apparent Liability, the "respondent
    will be afforded a reasonable period of time (usually 30 days from
    the date of the notice) to show, in writing, why a forfeiture
    penalty should not be imposed or should be reduced, or to pay the
    forfeiture. Any showing as to why the forfeiture should not be
    imposed or should be reduced shall include a detailed factual
    statement and such documentation and affidavits as may be
    pertinent." Section 1.80(f)(3) of the Rules. 47 C.F.R. § 1.80(f)(3).

[^26]: Gerritsen also raises arguments concerning other alleged
    instances of interference that are described in the *NAL*, beyond
    those that occurred on June 15, 2004, July 24, 2004 and September
    15, 2004. Because the Los Angeles Office found that Gerritsen
    apparently caused interference only on June 15, 2004, July 24, 2004
    and September 15, 2004, we do not reach Gerritsen's arguments
    concerning the other instances described in the *NAL.*

[^27]: We note that some types of communications by amateur operators
    using amateur frequencies are prohibited by the Commission's Rules.
    Section 97.113(a) of the Rules, 47 C.F.R. § 97.113, prohibits
    amateur stations from transmitting:

    > \(1\) Communications specifically prohibited elsewhere in this
    > Part;
    >
    > \(2\) Communications for hire or for material compensation, direct
    > or indirect, paid or promised, except as otherwise provided in
    > these rules;
    >
    > \(3\) Communications in which the station licensee or control
    > operator has a pecuniary interest, including communications on
    > behalf of an employer. Amateur operators may, however, notify
    > other amateur operators of the availability for sale or trade of
    > apparatus normally used in an amateur station, provided that such
    > activity is not conducted on a regular basis;
    >
    > \(4\) Music using a phone emission except as specifically provided
    > elsewhere in this Section; communications intended to facilitate a
    > criminal act; messages in codes or ciphers intended to obscure the
    > meaning thereof, except as otherwise provided herein; obscene or
    > indecent words or language; or false or deceptive messages,
    > signals or identification;
    >
    > \(5\) Communications, on a regular basis, which could reasonably
    > be furnished alternatively through other radio services.
    >
    > 47 C.F.R. § 97.113(a).

[^28]: We also note that Gerritsen, in each instance, caused
    interference to licensed amateur operators while he held no valid
    amateur license. His unlicensed operation on amateur frequencies is
    not protected by the U.S. Constitution as it is well established
    that the right to free speech does not include the right to use
    radio facilities without a license and that the licensing system
    established by Congress in the Communications Act was a proper
    exercise of Congress' power over commerce. *National Broadcasting
    Company v. U.S.*, 319 U.S. 190, 227 (1943).

[^29]: *NAL* at ¶ 21.

[^30]: *See* *Webnet Communications, Inc.*, 18 FCC Rcd 6870, 6878 ¶ 16
    (2003).

[^31]: 47 U.S.C. §§ 333, 503(b), 47 C.F.R. §§ 0.111, 0.311, 1.80(f)(4).

[^32]: 47 U.S.C. § 504(a).

[^33]: *See* 47 C.F.R. § 1.1914.