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 Federal  Communications  Commission  DA  06-  2229 
 Before  the  Federal  Communications  Commission 
 Washington,  D.  C.  20554 
 In  the  Matter  of  )  ) 
 Vitec  Group  Communications  Limited  )  File  No.  EB-  05-  SE-  172  Cambridge,  United  Kingdom  )  NAL/  Acct.  No.  200632100009 
 )  FRN  0012947594  ) 


 FORFEITURE  ORDER 
 Adopted  Date:  October  31,  2006  Released  Date:  November  2,  2006 
 By  the  Chief,  Spectrum  Enforcement  Division,  Enforcement  Bureau: 
 I.  INTRODUCTION 
 1.  In  this  Forfeiture  Order  (  Order),  we  issue  a  monetary  forfeiture  in  the  amount  of  eleven  thousand  two  hundred  dollars  ($  11,200)  to  Vitec  Group  Communications  Limited  (  Vitec)  for 
 willful  and  repeated  violation  of  Section  302(  b)  of  the  Communications  Act  of  1934,  as  amended  (  Act),  1  and  Section  2.803(  a)(  1)  of  the  Commissions  Rules  (  Rules).  2  The  noted  violations  involve 
 Vitecs  marketing  of  unauthorized  radio  frequency  devices  in  the  United  States. 
 II.  BACKGROUND 
 2.  In  May  2005,  the  Enforcement  Bureau  (  Bureau)  received  a  complaint  alleging  that  Clear-  Com  Communication  Systems  3  was  marketing  unapproved  radiofrequency  devices  in  the  United 
 States  in  violation  of  Section  302(  b)  of  the  Act  and  Section  2.803(  a)  of  the  Rules.  Specifically,  the  complaint  indicated  that  Vitec  advertised  an  unapproved  digital  wireless  intercom  system  called  the 
 CellCom  Digital  Wireless  Intercom  (  CellCom)  in  the  April  2005  issue  of  Broadcast  Engineering  and  also  displayed  it  at  the  2005  National  Association  of  Broadcasters  (  NAB)  trade  show  in  Las  Vegas,  NV. 
 Digital  wireless  intercom  systems,  such  as  the  CellCom,  are  classified  as  intentional  radiators  4  and  are  required  by  Section  15.201  of  the  Rules  5  to  be  approved  prior  to  marketing  through  the  equipment 
 certification  6  procedures  described  in  Sections  2.1031    2.1060  of  the  Rules.  7 
 1  47  U.  S.  C.    302a(  b). 
 2  47  C.  F.  R.    2.803(  a)(  1). 
 3  Clear-  Com  Communications  Systems  is  a  trade  name  that  Vitec,  a  British  company,  uses  in  the  United  States.  In 
 this  Forfeiture  Order,  we  will  refer  to  the  company  as  Vitec  throughout. 
 4  An  intentional  radiator  is  A  device  that  intentionally  generates  and  emits  radio  frequency  energy  by  radiation  or 
 induction.  47  C.  F.  R.    15.  3  (o). 
 5  47  C.  F.  R.    15.201. 


 6  A  certification  is  an  equipment  authorization  issued  by  the  Commission,  based  on  representations  and  test  data 
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 3.  The  Bureaus  Spectrum  Enforcement  Division  (Division)  subsequently  began  an  investigation  of  Vitecs  marketing  activities.  As  part  of  the  investigation,  the  Division  obtained  a  copy  of 
 the  April  2005  issue  of  Broadcast  Engineering  and  confirmed  that  it  contains  an  advertisement  for  the  CellCom.  Section  2.803(  c)  of  the  Rules  8  allows  the  advertising  or  display  of  radio  frequency  devices 
 prior  to  equipment  authorization  only  if  the  following  disclaimer  notice  is  provided: 
 This  device  has  not  been  authorized  as  required  by  the  rules  of  the  Federal  Communications  Commission.  This  device  is  not,  and  may  not  be,  offered  for  sale  or  lease,  or  sold  or  leased,  until 
 authorization  is  obtained. 
 The  Broadcast  Engineering  advertisement  does  not  contain  this  notice. 
 4.  The  Bureau  determined  through  internet  research  that  the  website  www.  clearcom.  com  contained  photographs  of  Vitecs  display  of  the  CellCom  at  the  2005  National  Association  of 
 Broadcasters  (  NAB)  trade  show,  which  took  place  April  16-  21,  2005.  The  disclaimer  notice  specified  by  Section  2.  803(  c)  of  the  Rules  is  not  visible  in  the  photographs  of  Vitecs  NAB  display.  The  Bureaus 
 internet  research  also  established  that  Vitec  was  advertising  the  CellCom  on  the  website  and  that  this  advertising  did  include  the  notice  specified  by  Section  2.803(  c)  of  the  Rules. 


 5.  The  Bureau  sent  Vitec  a  letter  of  inquiry  (  LOI)  9  on  October  24,  2005.  Vitec  submitted  responses  both  directly  10  and  through  its  counsel.  11  In  its  direct  response,  Vitec  stated  that  it  obtained 
 equipment  certifications  covering  its  digital  wireless  intercom  system  on  November  2,  2005  12  and  that  it  did  not  sell  or  distribute  the  product  in  the  United  States  prior  to  the  grant  of  the  certifications.  Vitec 
 acknowledged,  however,  that  the  advertising  in  Broadcast  Engineering  and  display  at  NAB  did  take  place  as  you  note  during  April  2005,  the  object  being  to  market  this  product  prior  to  launch.  In  the 
 subsequent  response  submitted  through  its  counsel,  Vitec  denied  any  violation  of  the  Act  or  the  Rules.  Vitec  stated  that  it  manufactures  its  CellCom  10  digital  wireless  intercom  system  in  England  and 
 imports  it  into  the  United  States.  Vitec  further  stated  that  it  displayed  the  system  at  the  2005  NAB  trade  show  and  advertised  it  on  its  website  and  in  at  least  Broadcast  Engineering  magazine.  Vitec  asserted, 


 submitted  by  the  applicant.  See  47  C.  F.  R.    2.907(  a). 
 7  47  C.  F.  R.    2.1031    2.  1060 


 8  47  C.  F.  R.    2.803(  c). 
 9  Letter  from  Kathryn  S.  Berthot,  Deputy  Chief,  Spectrum  Enforcement  Division,  Enforcement  Bureau,  to  Clear-Com 
 Communications  Systems  (October  24,  2005). 
 10  Letter  from  Chris  Exelby,  Managing  Director,  Vitec  Group  Communications,  to  Thomas  D.  Fitz-  Gibbon, 
 Spectrum  Enforcement  Division,  Enforcement  Bureau  (November  25,  2005). 
 11  Letter  from  Christopher  D.  Imlay,  Esq.  to  Kathryn  S.  Berthot  and  Thomas  D.  Fitz-  Gibbon,  Spectrum  Enforcement 
 Division,  Enforcement  Bureau  (December  6,  2005). 
 12  The  Commissions  equipment  authorization  data  base  indicates  that,  November  2,  2005,  Vitec  was  granted 
 equipment  certifications  FCC  ID  #  S30-  CEL-  BP  (portable  two-  way  radios)  and  FCC  ID  #  S30-  CEL-  TA  (base  station)  for  the  Vitec  CellCom  10  Digital  Wireless  Intercom. 
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 however,  that  it  did  not  market  or  sell  the  system  in  the  United  States  prior  to  receipt  of  the  equipment  certifications  on  November  2,  2005. 
 6.  On  April  14,  2006,  the  Bureaus  Spectrum  Enforcement  Division  issued  a  Notice  of  Apparent  Liability  for  Forfeiture  (  NAL)  to  Vitec  in  the  amount  of  fourteen  thousand  dollars  ($  14,000) 
 for  apparent  willful  and  repeated  violation  of  Section  302(  b)  of  the  Act  and  Sections  2.803(  a)(  2)  of  the  Rules.  13  In  its  response,  Vitec  argues  that  the  proposed  forfeiture  should  be  cancelled  because  its  pre-certification 
 advertising  of  the  Cellcom  10  digital  wireless  system  did  not  violate  the  Section  302(  b)  of  the  Act  or  Section  2.803(  a)(  2)  of  the  Rules,  and  that,  if  there  is  basis  for  a  monetary  forfeiture,  the  amount 
 proposed  by  the  NAL  is  excessive.  14 
 III.  DISCUSSION 
 7.  The  forfeiture  amount  proposed  in  this  case  was  assessed  in  accordance  with  Section  503(  b)  of  the  Communications  Act  of  1934,  as  amended  (  Act),  15  Section  1.80  of  the  Rules,  16  and  the 
 Commissions  Forfeiture  Policy  Statement  and  Amendment  of  Section  1.80  of  the  Rules  to  Incorporate  the  Forfeiture  Guidelines.  17  In  assessing  forfeitures,  Section  503(  b)(  2)(  D)  of  the  Act  requires  that  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.  18 
 8.  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.  Section  2.803(  a)(  1)  of  the  Rules  provides  that: 
 Except  as  provided  elsewhere  in  this  section,  no  person  shall  sell  or  lease,  or  offer  for  sale  or  lease  (including  advertising  for  sale  or  lease),  or  import,  ship,  or  distribute  for  the 
 purpose  of  selling  or  leasing  or  offering  for  sale  or  lease,  any  radio  frequency  device  19  unless    [i]  n  the  case  of  a  device  that  is  subject  to  certification,  such  device  has  been 
 authorized  by  the  Commission  in  accordance  with  the  rules  in  this  chapter  and  is  properly  identified  and  labeled  as  required  by    2.925  and  other  relevant  sections  in  this  chapter 
 [emphasis  added]. 


 13  Vitec  Group  Communications,  Ltd.,  21  FCC  Rcd  4025  (Enf.  Bur.,  Spectrum  Enf.  Div.,  2006). 
 14  Letter  from  Christopher  D.  Imlay,  Esq.  to  Chief,  Spectrum  Enforcement  Division,  Enforcement  Bureau  (May  18, 
 2006)  (  NAL  response). 
 15  47  U.  S.  C.    503(  b). 


 16  47  C.  F.  R.    1.80. 
 17  12  FCC  Rcd  17087  (1997),  recon.  denied,  15  FCC  Rcd  303  (1999)  (  Forfeiture  Policy  Statement). 
 18  47  U.  S.  C.    503(  b)(  2)(  D). 
 19  47  C.  F.  R.    2.801  defines  a  radiofrequency  device  as  any  device  which  in  it  its  operation  is  capable  of  emitting 
 radiofrequency  energy  by  radiation,  conduction,  or  other  means. 
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 9.  Vitec  provides  a  Statement  Under  Penalty  of  Perjury  indicating  that  it  did  provide  the  disclaimer  notice  specified  by  Section  2.  803(  c)  of  the  Rules  when  it  displayed  the  CellCom  10  at  the 
 NAB  convention  between  April  16  and  21,  2005.  20  On  the  basis  of  that  information,  we  find  the  display  of  the  CellCom  at  the  NAB  convention  did  not  violate  Section  302(  b)  of  the  Act  or  Section  2.803(  a)(  1)  of 
 the  Rules. 
 10.  Vitec  admits  that  it  advertised  its  digital  wireless  intercom  system  in  the  April  2005  issue  of  Broadcast  Engineering  before  the  grant  of  an  equipment  authorization  and  furnishes  a  copy  of  the 
 advertisement,  which  does  not  include  the  disclaimer  notice  specified  by  Section  2.803(  c)  of  the  Rules.  21  Vitec,  however,  argues  that  it  was  not  required  to  include  the  disclaimer  notice  because  the  Broadcast 
 Engineering  advertisement  did  not  offer  or  advertise  the  CellCom  10  for  sale  or  lease.  22  We  reject  this  argument.  The  purpose  of  Vitecs  Broadcast  Engineering  advertisement  was  to  generate  future  sales  by 
 advertising  the  CellCom  10  prior  to  certification.  This  is  illustrated  by  Vitecs  statement  in  its  direct  response  to  the  first  LOI  that  the  advertising  in  Broadcast  Engineering  .  .  .  did  take  place  as  you  note 
 during  April  2005,  the  object  being  to  market  this  product  prior  to  launch  (emphasis  added). 
 11.  Vitec  also  argues  that  the  one  year  statute  of  limitations  contained  in  Section  503(  b)(  6)(  B)  of  the  Act  23  bars  imposing  a  forfeiture  on  the  basis  of  Vitecs  Broadcast  Engineering 
 advertisement.  Specifically,  Vitec  claims  that  the  statute  of  limitations  date  passed  before  the  issuance  of  the  NAL  because  the  Broadcast  Engineering  issue  in  which  Vitecs  advertisement  appeared,  April  2005, 
 was  distributed  to  subscribers  during  March  2005,  which  is  more  than  one  year  before  the  April  14,  2006,  issuance  of  the  NAL.  24  We  reject  this  argument.  The  April  issue  of  Broadcast  Engineering  was  current 
 until  the  end  of  that  month  and,  therefore,  Vitecs  violation  continued  through  the  end  of  April  2005,  which  is  within  the  one  year  statute  of  limitations  period. 


 12.  We,  accordingly,  find  that  Vitec  willfully  25  and  repeatedly  26  violated  Section  302(  b)  of  the  Act  and  Section  2.803(  a)(  2)  of  the  Rules  by  marketing  its  digital  wireless  intercom  system  in  the  April 
 2005  issue  of  Broadcast  Engineering  prior  to  certification. 


 20  NAL  response,  Exhibit  B. 
 21  Id.  at  pp.  6-  7,  Exhibit  A. 
 22  Id.  at  pp.  6-  7. 
 23  47  U.  S.  C.    503(  b)(  6)(  B),  which  provides  that  No  forfeiture  penalty  shall  be  determined  or  imposed  against  any 
 person  under  this  subsection  if  such  person  does  not  hold  a  broadcast  station  license  issued  under  subchapter  III  of  this  chapter  and  if  the  violation  charged  occurred  more  than  1  year  prior  to  the  date  of  issuance  of  the  required  notice 


 or  notice  of  apparent  liability. 
 24  NAL  response  at  p.  6. 


 25  Section  312(  f)(  1)  of  the  Act,  47  U.  S.  C.    312(  f)(  1),  which  applies  to  violations  for  which  forfeitures  are  assessed 
 under  Section  503(  b)  of  the  Act,  provides  that  [  t]  he  term  willful,      means  the  conscious  and  deliberate  commission  or  omission  of  such  act,  irrespective  of  any  intent  to  violate  any  provision  of  this  Act  or  any  rule  or 


 regulation  of  the  Commission  authorized  by  this  Act  .  See  Southern  California  Broadcasting  Co.,  6  FCC  Rcd  4387  (1991). 


 26  Section  312(  f)(  2)  of  the  Act  provides  that  [  t]  he  term  repeated,      means  the  commission  or  omission  of  such 
 act  more  than  once  or,  if  such  commission  or  omission  is  continuous,  for  more  than  one  day.  47  U.  S.  C.   
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 13.  Vitec  also  argues  that,  if  there  is  basis  for  a  monetary  forfeiture,  the  amount  proposed  by  the  NAL  is  excessive.  27  First,  Vitec  contends  that  the  calculation  of  the  proposed  base  forfeiture  amount  -- 
 $14,000  --  is  erroneous.  The  base  forfeiture  amount  for  the  marketing  of  unauthorized  equipment  is  $7,000.  28  We  proposed  a  $14,000  forfeiture  because  the  CellCom  system  included  two  types  of 
 uncertified  transmitters  --  base  station  and  mobile  --  whose  marketing  constituted  separate  offenses.  Vitec  argues  that  the  base  forfeiture  amount  should  be  $7,000  because  CellCom  10  is  a  single  device.  We 
 reject  that  argument.  The  base  and  mobile  transmitters  constituting  the  CellCom  10  are  covered  by  separate  equipment  authorizations  29  and  must,  therefore,  be  considered  distinct  devices. 


 14.  In  addition,  Vitec  contends  that  the  Spectrum  Enforcement  Divisions  holding  in  Schumacher  Electronic  Corporation,  19  FCC  Rcd  6344  (Enf.  Bur.  2004),  consent  decree  issued,  19  FCC 
 Rcd.  8825  (Enf.  Bur.  2004),  requires  a  reduction  of  the  forfeiture  amount  in  this  case.  In  Schumacher,  the  Spectrum  Enforcement  Division  proposed  a  forfeiture  of  $7,000  for  willful  and  repeated  violation  of 
 Section  302(  b)  of  the  Act  and  Section  2.  803(  a)(  2)  of  the  Rules  where  Schumacher  had  displayed  three  unauthorized  battery  charger  models  at  a  trade  show  without  providing  the  disclaimer  specified  by 
 Section  2.803(  c)  of  the  Rules.  Schumacher  is  not  consistent  with  the  Commissions  decision  in  Samson  Technologies,  Inc.,  19  FCC  Rcd  4221  (2004),  consent  decree  issued,  19  FCC  Rcd  24542  (2004).  In  that 
 case,  the  Commission  determined  that  a  base  forfeiture  amount  of  $7,000  is  warranted  for  each  kind  of  unauthorized  device  that  is  marketed  (a  total  of  $35,000  for  five  devices).  Samson  has  been  followed  in 
 numerous  cases  30  and  we  will  follow  it  here.  Accordingly,  we  find  that  our  calculation  of  the  proposed  base  forfeiture  amount  --  $14,000  --  was  correct. 


 15.  Vitec  also  argues  that  none  of  the  upward  adjustment  criteria  31  set  forth  in  the  Forfeiture  Policy  Statement  and  47  C.  F.  R.    1.80(  b)(  4)  apply.  32  This  argument  has  no  merit  because  the  forfeiture 
 amount  proposed  by  the  NAL  does  not  include  an  upward  adjustment. 


 312(  f)(  2). 
 27  NAL  response  at  p.  11. 


 28  Forfeiture  Policy  Statement  and  47  C.  F.  R.    1.  80. 
 29  FCC  ID  S30-  CEL-  BP  and  FCC  ID  S30-  CEL-  TA. 
 30  E.  g.,  Pilot  Travel  Centers,  LLC,  19  FCC  Rcd  23113,  23117  (2004)  (proposing  $91,000  base  forfeiture  amount  for 
 13  devices),  consent  decree  issued,  21  FCC  Rcd  5308  (2006);  Behringer  USA,  Inc.,  21  FCC  Rcd.  1820,  1827  (2006)  (proposing  $350,  000  base  forfeiture  amount  for  50  devices),  response  pending;  San  Jose  Navigation,  Inc.,  21  FCC 


 Rcd  2873,  2877  (2006)  (proposing  $28,  000  base  forfeiture  amount  for  four  devices),  response  pending;  Via  Technologies,  19  FCC  Rcd  19556  (Enf.  Bur.,  Spectrum  Enf.  Div.,  2004)  (proposing  $14,  000  base  forfeiture  amount 
 for  two  devices),  forfeiture  ordered,  19  FCC  Rcd  24341  (2004);  Ramsey  Electronics,  Inc.,  21  FCC  Rcd  458,  462  (Enf.  Bur.,  Spectrum  Enf.  Div.,  2006)  (proposing  $28,  000  base  forfeiture  amount  for  four  devices);  Gibson  Tech  Ed, 
 Inc.,  20  FCC  Rcd  14438,  14441  (Enf.  Bur.,  Spectrum  Enf.  Div.,  2005)  (proposing  $14,  000  base  forfeiture  amount  for  two  devices),  forfeiture  ordered,  21  FCC  Rcd  2915  (Enf.  Bur.,  Spectrum  Enf.  Div.,  2006),  recon.  den.,  21  FCC 
 Rcd  9642  (Enf.  Bur.  2006);  and  Bureau  DElectronique  Appliquee,  Inc.,  20  FCC  Rcd  3445,  3448  (Enf.  Bur.,  Spectrum  Enf.  Div.,  2005)  (proposing  $14,  000  base  forfeiture  amount  for  two  devices),  forfeiture  ordered,  20  FCC 
 Rcd  17893  (Enf.,  Bur.,  Spectrum  Enf.  Div.,  2005). 
 31  See  Forfeiture  Policy  Statement,  12  FCC  Rcd  at  17100;  47  C.  F.  R.    1.80(  b)(  4),  Note  to  paragraph  (b)(  4):  Section 
 II.  Adjustment  Criteria  for  Section  503  Forfeitures. 
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 16.  In  addition,  Vitec  argues  that  the  proposed  forfeiture  amount  should  be  reduced  on  the  basis  of  the  following  downward  adjustment  criteria  33  :  minor  violation,  good  faith  and  history  of  overall 
 compliance.  34  The  Commission  has  held  that  a  violation  of  a  provision  of  the  Communications  Act  cannot  be  classified  as  a  minor  violation.  35  Therefore,  we  do  not  find  that  Vitecs  violation  of  the 
 Communications  Act  was  minor.  Further,  Vitec  has  not  identified  any  specific  action  that  would  constitute  good  faith  --  nor  are  we  aware  of  any.  Accordingly,  we  do  not  find  that  Vitec  acted  in  good 
 faith.  We  do,  however,  find  that  Vitec  has  a  history  of  overall  compliance  which  warrants  reduction  of  the  forfeiture  amount  to  $11,  200. 


 17.  We  have  examined  Vitecs  response  to  the  NAL  pursuant  to  the  statutory  factors  set  forth  in  Paragraph  7  above,  and  in  conjunction  with  the  Policy  Statement  as  well.  As  a  result  of  our 
 review,  we  conclude  that  cancellation  of  the  forfeiture  is  not  warranted  but  that  the  forfeiture  amount  should  be  reduced  from  $14,000  to  $11,200. 


 IV.  ORDERING  CLAUSES 
 18.  Accordingly,  IT  IS  ORDERED  that,  pursuant  to  Section  503(  b)  of  the  Act,  and  Sections  0.111,  0.311  and  1.80(  f)(  4)  of  the  Rules,  36  Vitec  Group  Communications,  Ltd..,  IS  LIABLE  FOR  A 
 MONETARY  FORFEITURE  in  the  amount  of  eleven  thousand  two  hundred  dollars  ($  11,200)  for  willful  and  repeated  violation  of  Section  302(  b)  of  the  Act  and  Section  2.803(  a)(  1)  of  the  Rules. 


 19.  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,  445  12  th  Street,  S.  W.,  Room  1A625,  Washington, 
 D.  C.  20554.  37 


 32  NAL  response  at  p.  11. 
 33  See  Forfeiture  Policy  Statement,  12  FCC  Rcd  at  17100;  47  C.  F.  R.    1.80(  b)(  4),  Note  to  paragraph  (b)(  4):  Section 
 II.  Adjustment  Criteria  for  Section  503  Forfeitures. 
 34  NAL  response  at  p.  11. 


 35  Catherine  R.  Waddill,  13  FCC  Rcd  23861,  23866  (1998);  Paging  Network  of  Los  Angeles,  Inc.,  8  FCC  Rcd  1702, 
 1703  (1993). 
 36  47  C.  F.  R.    0.111,  0.311,  1.  80(  f)(  4). 


 37  See  47  C.  F.  R.    1.1914. 
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 Federal  Communications  Commission  DA  06-  2229 
 7 
 20.  IT  IS  FURTHER  ORDERED  that  a  copy  of  this  Notice  of  Apparent  Liability  for  Forfeiture  shall  be  sent  by  first  class  mail  and  certified  mail  return  receipt  requested  to  Vitec  Group 
 Communications  Limited,  4065  Hollis  Street,  Emeryville,  CA  94608,  and  to  its  attorney,  Christopher  D.  Imlay,  Esq.,  Booth,  Freret,  Imlay  &  Tepper,  P.  C.,  14356  Cape  May  Road,  Silver  Spring,  MD  20904- 
 6011. 
 FEDERAL  COMMUNICATIONS  COMMISSION 


 Kathryn  S.  Berthot  Chief,  Spectrum  Enforcement  Division 
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