1 

NOT FOR PUBLICATION 

United States District Court 

for the District of New Jersey 

WARREN HAVENS; SKYBRIDGE 

SPECTRUM FOUNDATION; TELESAURUS 

VPC, LLC; AMTS CONSORTIUM, LLC; 

INTELLIGENT TRANSPORTATION & 

MONITORING, LLC; TELESAURUS GB, LLC, 

 Plaintiffs, Civil No.: 11-993 (KSH) (CLW) 

 v. 

MOBEX NETWORK SERVICES, LLC; 

MOBEX COMMUNICATIONS, INC.; PAGING 

SYSTEMS, INC.; TOUCH TEL 

CORPORATION; MARITIME 

COMMUNICATIONS/LAND MOBILE, LLC, 

 Defendants. 

OPINION 

Katharine S. Hayden, U.S.D.J. 

Pending before the Court is a motion filed by defendants Paging Systems, Inc. and Touch 

Tel Corporation to enforce a settlement agreement. [D.E. 203.] The motion will be granted. 

The Court writes primarily for the parties, who are familiar with the facts of this case, 

which is set for a bench trial beginning on May 20. On April 8, 2013, the moving defendants 

entered into an agreement with the plaintiffs—through individual plaintiff Warren Havens, who 

is the president of the various entity plaintiffs—with the aim of resolving the disputes among the 

parties, which included this lawsuit and proceedings before the Federal Communications 

Commission (“FCC”). The Confidential Settlement Agreement (“CSA”), which is docketed in 

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redacted form at D.E. 203-3,1

 required the moving defendants to cede certain Automated Marine 

Telecommunications Service (AMTS) interests to the plaintiffs. (CSA ¶ 2–3.) Doing so would 

involve a number of transactions subject to FCC approval. For example, pursuant to the CSA, 

Paging Systems, Inc., would “submit to the FCC for permanent and complete cancellations . . . 

all of the . . . AMTS site-based licenses that exist in FCC licensing records in the fifty United 

States,” subject to limited exceptions. (CSA ¶ 5.) Following the completion of the various 

assignments, the parties “that are the assignees . . . w[ould] each promptly file with the FCC 

notices of consummation.” (CSA ¶ 4a.) And, subject to the successful realization of these 

transfers and cancellations: 

 The parties agreed to jointly file a stipulation of dismissal with prejudice of the 

remaining 15 U.S.C. § 1 claim by the plaintiffs against the moving defendants in 

this action (CSA ¶ 6(a)); 

 The plaintiffs agreed to dismiss with prejudice “all of their actions . . . that are 

pending before the FCC that challenge the FCC licenses . . . of and pending 

licensing actions of [the moving defendants], or the qualifications of [the moving 

defendants] to hold FCC licenses” (CSA ¶ 6(b)(1)); 

 The moving defendants agreed to dismiss with prejudice “all of their actions . . . 

that are pending before the FCC that challenge the FCC licenses . . . of and any 

pending licensing actions of any Plaintiff, or the qualifications of any Plaintiff to 

hold FCC licenses” (CSA ¶ 6(b)(2)); and 

 

1

 The moving defendants have also provided an unredacted version of the CSA and its enclosures for in camera

analysis. 

The named plaintiffs in this case are Havens, Skybridge Spectrum Foundation, Telesaurus VPC, AMTS Consortium, 

Intelligent Transportation & Monitoring, and Telesaurus GB. As detailed in the second amended complaint [D.E. 

1], Telesaurus VPC is now known as Verde Systems and AMTS Consortium is now known as Environmentel. The 

CSA bound the individual and entity plaintiffs in this suit as well as two non-party entities, Enrivonmentel-2 and 

V2G, who are not the subject of this opinion and order. 

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 The moving defendants agreed to use their “best efforts” to comply with certain 

outstanding discovery requests (CSA (unredacted) ¶ 12). 

With some exceptions, the parties also settled on the release of further claims or actions arising 

out of or pertaining to either this case or the ongoing FCC proceedings, to take effect upon the 

closing of the license assignments and other consummations. (CSA ¶¶ 7–8, 10.) 

 While it set out the basic agreement among the parties, the CSA also included several 

attachments—entitled Appendix 1 and Attachments 1, 2, and 3—that contained additional details 

about the specific conveyances required to complete the transactions. Appendix 1, the 

Assignments Agreement (“AA”), established at length the contractual details and procedures 

required to effect the transfers and cancellations discussed in the CSA, setting out the terms and 

conditions of the assignment of geographic AMTS licenses. (See CSA ¶ 4.) By its terms, the 

AA applied to paragraphs 2 and 3 of the CSA, as well as “all other parts of the [CSA] . . . that 

pertain directly to actions required or permitted to be performed and executed before and by the 

FCC of the license assignments under said paragraphs.” (AA 9.) One provision, under the 

subheading “Special Covenants and Assignments Agreements,” emphasized that the assignment 

actions contemplated were to be “subject to the prior consent and approval of the FCC.” (AA ¶ 

6.1(a).) Attachment 1 defined the various license cancellations and reciprocal license/partition 

assignments referred to in the CSA, Attachment 2 defined the partition area of assignments 

discussed in the CSA and set out a reciprocal channel-sharing agreement, and Attachment 3 

expanded on the number of pending FCC proceedings. 

The relevant parties executed the CSA in April 2013. Thereafter, the moving defendants 

informed the Court that while there was a global confidential settlement agreement, its 

consummation—and the signing parties’ ability stipulate to dismissal under Fed. R. Civ. P. 41—

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was conditioned upon prior FCC approval of pending licensing actions. (Apr. 12, 2013 Letter 1 

[D.E. 164].) The signatories sought a stay from the Court “pending FCC approval of the terms 

of the CSA . . . so that the parties’ settlement can be fully completed and all parties remain in 

appropriate equipoise in the interim.” (Apr. 12, 2013 Letter 2.) The Court denied the stay 

request via order of April 19, 2013. [D.E. 167.] 

 In the present motion, the moving defendants represent that while they have upheld their 

end of the bargain, the plaintiffs have not. Specifically, the plaintiffs allegedly refuse to allow 

the last steps contemplated by the CSA to take place: final closing of the FCC-approved license 

agreements and the with-prejudice dismissal of the remaining antitrust claim. (See Moving Br. 

1–2 [D.E. 203-1].) According to the moving defendants, at the plaintiffs’ insistence, the 

settlement process was made contingent on the various FCC actions being “final,” defined as 

when “all challenges to the given FCC action by a third-party or sua sponte by the FCC, if any, 

had been dismissed, and the time for appealing from the given FCC action, either by third-parties 

or sua sponte by the FCC, had expired.” (Friedman Cert. ¶ 5 [D.E. 203-2]; see also CSA ¶ 5 

(defining “final” as “not subject to and beyond the time allowed in FCC law for” third-party 

challenge for sua sponte action by the FCC); AA (unredacted) ¶ 7.1(c).) “All necessary FCC 

consents,” the moving defendants write, “for the parties’ geographic ATMS license assignments 

became final for purposes of the [CSA] on or about October 17, 2013,” at the end of the relevant 

regulatory periods for seeking review. (Friedman Cert. ¶ 32 & n.3 (citing 47 C.F.R. §§ 1.104, 

1.117).) With regard to site-based ATMS licenses, the moving defendants further contend that 

they have performed beyond what was required by the CSA, unilaterally cancelling certain sitebased AMTS licenses earlier than was required; those cancellations and others became final in 

September 2013 and January 2014. (Friedman Cert. ¶¶ 33–36.) 

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 The moving defendants identify two issues the plaintiffs have raised in refusing to bring 

the settlement to a close. First, the plaintiffs inquired about the continued “availability of 

Maritime/Mobex-related documents under ¶ 12 of the [CSA]”; second, they disputed “the 

finality of the dismissals/withdrawals of the parties’ proceedings before the FCC under ¶ 5 of the 

[CSA].” (Friedman Cert. ¶ 48.) Attached to the moving defendants’ motion are several exhibits, 

including: 

 An email chain reflecting plaintiff Havens’s desire to ensure that the FCC 

decision was “non-defective” (Ex. 172

 [D.E. 203-6]); 

 A January 21, 2014 email from plaintiff Havens, in which he maintained that the 

moving defendants had not completed “all required actions under the [CSA],” 

thereby preventing the closing from taking place (Ex. 20 [D.E. 203-6]); and 

 A February 7, 2014 email to plaintiff Havens in which an attorney for the moving 

defendants wrote that 1) there were “no additional documents” to be provided 

under the discovery portions of the CSA and that 2) the FCC decisions were final 

(Ex. 21 [D.E. 203-6]). 

The moving defendants seek an order from this Court compelling the plaintiffs to speedily 

execute and deliver “the required closing documents memorializing the assignment transactions 

to the [moving defendants] and [to] promptly notify the FCC that the assignments have been 

completed,” as well as to enter into the agreed-upon stipulation dismissing this case against the 

moving defendants. (Friedman Cert. ¶ 65.) They further ask the Court to contemplate a future 

involuntary dismissal pursuant to Fed. R. Civ. P. 41(b) should the plaintiffs fail to comply with 

the order. 

 

2

 All exhibit numbers in this opinion refer to attachments to the original Friedman Certification unless otherwise 

specified. 

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 Proceeding pro se and writing only for himself,3

 plaintiff Havens opposes the pending 

motion, claiming that the moving defendants have not candidly explained the FCC situation and 

arguing further that this Court lacks jurisdiction to enforce the CSA. With regard to the FCC 

proceedings, Havens asserts, among other things, that the various assignments were not 

completed before the FCC “due to . . . violations of FCC law,” and that the moving defendants 

misrepresented the status of the assignments to the FCC; the FCC decisions are therefore 

incorrect and “should be reversed.” (Opp’n Br. 3–5 [D.E. 226].) He also maintains that the 

moving defendants have not issued valid Notice communications under the CSA and AA. 

(Opp’n Br. 5; see also AA ¶ 11.2.) With regard to jurisdiction, he points out that while the CSA 

grants this Court “continuing jurisdiction to take all action necessary to effect and enforce” the 

agreement (CSA ¶ 18), the AA contains an altogether different—and arguably stronger—forumand choice-of-law selection clause, under the caption “Governing Law; Venue”: 

This Assignments Agreement shall be governed, construed, and enforced in 

accordance with the laws of the State of California, without regard to the choice 

of law provisions thereof. Each of the Parties consents to the exclusive 

jurisdiction of the federal and state courts of the State of California, as well as to 

the jurisdiction of all courts to which an appeal may be taken from such courts, 

for the purpose of any suit, action or other proceeding arising out of, or in 

connection with, this Assignments Agreement. 

(AA ¶ 11.5.) Under Havens’s reading of the CSA and AA, the only courts with jurisdiction to 

resolve this dispute are those located in California, although he also appears to suggest that the 

only body with jurisdiction to rule is the FCC. (See Opp’n Br. 3, 5; see also Opp’n Br. 6 (“The 

Motion should be dismissed or denied for lack of jurisdiction.”).) 

 In their reply, the moving defendants attempt to distinguish the AA’s forum-selection 

clause by emphasizing that the AA, which was not separately executed by the parties, did not 

 

3

 The Court addressed Havens’s inability to represent the entity plaintiffs in its May 1 order. [D.E. 228.] His pro se

submission has been liberally construed. See Liggon-Redding v. Estate of Sugarman, 659 F.3d 258, 265 (3d Cir. 

2011) (“Pro se filings . . . must be liberally construed.”). 

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create independent obligations thereunder. (Reply Br. 3–4 [D.E. 238].) In any event, they argue, 

none of the enforcement steps requested arises out of the AA. Instead, each derives from 

obligations established by the CSA, meaning that the CSA’s language controls. The defendants 

also challenge Havens’s standing to contest jurisdiction, and assert that he has abandoned his 

discovery-based objection by failing to oppose their arguments. (Reply Br. 7–10.) Finally, they 

ask the Court to compel the plaintiffs to withdraw a new conditional petition for reconsideration 

filed in an FCC matter, which “breached the covenant not to pursue further legal actions” 

contained in the CSA (Reply Br. 10–11). 

 Reaching the jurisdictional argument first: the Court notes that paragraph 19 of the 

unredacted CSA appears by itself to solve the tension between the forum-selection clauses of the 

CSA and AA. Specifically, paragraph 19(ii) resolves term conflicts between the two documents 

in favor of those from the CSA. The parties do not address this language, despite having access 

to the unredacted CSA. 

Nevertheless, even without paragraph 19(ii), Havens’s jurisdictional argument is without 

merit. First, forum-selection clauses do not, strictly speaking, deprive a court of jurisdiction; in 

certain circumstances, such clauses can be disregarded. See Atl. Marine Constr. Co. v. U.S. Dist. 

Ct., 134 S. Ct. 568, 582 (2013) (“Forum-selection clauses should control except in unusual 

cases.”); see also Botman Int’l, B.V. v. Int’l Produce Imports, Inc., 205 F. App’x 937, 941 (3d 

Cir. 2006) (nonprecedential) (“[T]he applicability of a forum selection or choice-of-law clause is 

not a jurisdictional issue and a party may waive its right to enforce it.”). In fact, when 

confronting multiple, inconsistent clauses, courts frequently must choose which, if any, are to be 

given effect. See, e.g., Asoma Corp. v. SK Shipping Co., 467 F.3d 817, 822 (2d Cir. 2006) (in 

circumstances with competing clauses, “the court must decide . . . which forum selection clause 

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governs”); Bennett v. Itochu Int’l, Inc., No. 09-CV-1819, 2009 WL 2569259, at *3 (E.D. Pa. 

Aug. 17, 2009) (“Given that potentially multiple forum selection clauses provide Pennsylvania as 

a proper venue and Plaintiffs are Pennsylvania citizens, Plaintiffs’ choice to litigate in the 

Eastern District of Pennsylvania is entitled to deference.”); Lee v. Le, No. 07-10683, 2008 WL 

686233, at *3 (E.D. Mich. Mar. 13, 2008) (declining to enforce any of multiple clauses when 

doing so would “be seriously inconvenient” to the ongoing litigation). The Court has never 

relinquished jurisdiction in this matter, as the parties do not dispute. 

Second, the arguably stronger, exclusive language of the AA clause cannot control 

because the parties plainly bargained for this Court to exercise continuing jurisdiction over the 

settlement process. See Feldman v. Google, Inc., 513 F. Supp. 2d 229, 245–46 (E.D. Pa. 2007) 

(discussing permissive and mandatory forum-selection language); see also Dawes v. Publish Am. 

LLLP, No. 13-3269, 2014 WL 1389007, at *1 (3d Cir. Apr. 10, 2014) (nonprecedential per 

curiam) (same). In fact, were the Court to have entered an order conditionally dismissing the 

case at the time the parties reached agreement, language in the order retaining jurisdiction would 

be of equivalent force to any exclusive clause separately contained in the settlement documents. 

See Flanagan v. Arnaiz, 143 F.3d 540, 545 (9th Cir. 1998) (“[I]t would make no sense for the 

district court to retain jurisdiction to interpret and apply its own judgment to the future conduct 

contemplated by the judgment, yet have a state court construing what the federal court meant in 

the judgment.”). 

 Third, settlement agreements are contracts. In re Cendant Corp. PRIDES Litig., 233 F.3d 

188, 193 (3d Cir. 2000); Thompson v. City of Atl. City, 190 N.J. 359, 379 (N.J. 2007). It is well 

established that contracts are to be read “in a way that allows all the language to be read together, 

reconciling conflicts in the language without rendering any of it nugatory if possible.” CTF 

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Hotel Holdings v. Marriott Int’l, 381 F.3d 131, 137 (3d Cir. 2004). Thus, a contract “should not 

be interpreted to render one of its terms meaningless,” Cumberland Cnty. Imp. Authority v. GSP 

Recycling Co., Inc., 358 N.J. Super. 484, 497 (App. Div. 2003), and its terms should be looked at 

“as a whole, in order to ascertain their meaning,” Town of Kearny v. Discount City of Old 

Bridge, Inc., 205 N.J. 386, 411 (N.J. 2011). The CSA and AA refer to each other and took effect 

simultaneously, suggesting that they should be understood as a whole when possible. Because 

this dispute arises out of the contractual obligations of the CSA and not the assignment protocol 

of the AA, the forum-selection clause of the former controls. 

 The plaintiffs objected to performing in part because of alleged deficiencies in the FCC’s 

decisions. According to the record on this motion, on December 6, 2013, the FCC granted the 

various requests to dismiss and withdraw the pleadings pending before it. (See Dec. 6, 2013 

Letter Order, Ex. 12 [D.E. 203-5].) In the communiqué—which was signed by Scot Stone, 

Deputy Chief of the Mobility Division; John Schauble, Deputy Chief of the Broadband Division; 

and Gary Michaels, Deputy Chief of the Auction and Spectrum Access Division—the agency 

characterized the requests as having been filed pursuant to 47 C.F.R. § 1.935(a), a regulation that 

establishes the procedures to be followed by a “party withdrawing or requesting dismissal of its 

application (or specific frequencies on the application), petition to deny, informal objection or 

other pleading or refraining from filing a pleading.”4

 Having “reviewed the requests and 

find[ing] that they raise[d] no substantial or material question of fact,” the FCC granted them and 

also dismissed in part as moot an additional formal request filed by the plaintiffs. (Dec. 6, 2013 

Letter Order 2–4.) In the final portion of its order, the agency made reference to another 

 

4

 This approach was in accordance with the CSA, which specified that the parties would act to withdraw the pending 

FCC actions in compliance with § 1.935. (See CFA 4 n.6.) 

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regulation, 47 C.F.R. § 0.331, which delegates to the Chief of the Wireless Telecommunications 

Bureau “authority to perform all functions of the Bureau.” 

 In a December 18 letter, David Hill, the attorney for one of the settling parties, wrote to 

Havens that the FCC letter “completes the FCC actions required by the [CSA],” which would 

then become “final” on January 15, 2014. “Thus,” he wrote, “we should confer to review closing 

procedures and set date for closing.” (Dec. 18, 2013 Email, Ex. 17 [D.E. 203-6].) Later in the 

email chain, however, Havens raised possible irregularities in the FCC decision, writing: 

As to the FCC Dec 6 letter, in review of it – 

- Rule 1.935 says that the requests are to the Commission. 

- The PSI and IT requests under this rule were addressed to the WB Chief. 

I followed with my side’s request using the same addressee. 

- The Dec 3 letter was by three persons in WB, none of which are the 

Chief, and cites 0.331 as authority,[] but I am not sure this rule allows 

anyone in WB (even the Chief) to act on a pleading before the full 

Commission. The parties exhibit listing pleadings to be dismissed includes 

Apps for Rev before full Commission on both sides. 

I have just considered this possible issue. 

We need to secure this as a non-defective decision. 

I would appreciate your views on this. 

(Dec. 22, 2013 Email, Ex. 17 [D.E. 203-6].) 

 The next pertinent exchange took place in January. Hill emailed Havens on January 16, 

2014, and represented that, from his client’s perspective, the “FCC action” was now “final” as 

contemplated by the CSA. Referencing paragraph 8.1(b) of the AA, he proposed a series of 

actions to be taken at the January 21, 2014 closing date. (Jan. 16, 2013 Email, Ex. 19 [D.E. 203-

6].) Hill sent another email on January 20, addressing the finality of the FCC action. (Jan. 20, 

2013 Email, Ex. 20 [D.E. 203-6].) A reply email from Havens contained additional comments 

about the moving defendants’ compliance with the CSA. (Jan. 21, 2014 Email, Ex. 20 [D.E. 

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203-6].) The plaintiffs were sent closing documents—“Assignment and Assumption” forms, 

executed by the relevant defendants—on February 14. (See Feb. 14, 2013 Email and 

Attachments, Ex. 23 [D.E. 203-6].) However, the plaintiffs did not execute the documents. 

Nevertheless, on February 18, 2014, the moving defendants “notified the FCC that the previously 

approved assignment of the partitioned portion of Plaintiffs’ Southern Pacific geographic AMTS 

licenses to the Paging System Defendants had been completed,” and on February 20, “the time 

for Plaintiffs, as assignees, to notify the FCC that the previously approved assignments of the 

Paging System Defendants’ Great Lakes and Hawaii geographic AMTS licenses to Plaintiffs 

have been consummated was extended 90 days.” (Friedman Cert. ¶¶ 59–60.) 

 Despite the above, which sets forth at length the moving defendants’ attempts to bring 

this matter to a close, Havens argues5 that procedural irregularities and the moving defendants’ 

February FCC filings render the relevant assignments nonfinal. According to him, the 

assignment transaction did not close because neither Skybridge nor Verde has signed the 

assignment documents. But this is part of the relief the moving defendants seek: compelling the 

entity defendants to comply with their obligations under the CSA and AA. Havens does not 

explain how the February submissions amounted to a violation of the CSA or AA; nor, for that 

matter, does he address how the moving defendants’ letters, calls, and filings did not amount to 

proper “notices” under the agreements.6

 In the FCC Petition for Reconsideration incorporated 

 

5

 According to the record, in justifying his refusal to complete performance, Havens claimed that the moving 

defendants had not complied with certain discovery obligations contained in the settlement documents. In their 

motion, the moving defendants represent that they used their best efforts, as was required by the CSA (see CSA 

(unredacted) ¶ 12), to locate and provide responsive documents. As mentioned above, Havens has not responded to 

this argument in his opposition brief. The Court concludes that Havens has abandoned this issue. 

6

 Havens writes that the moving defendants “ha[ve] not issued to Plaintiffs[’] side[] Notices under the Settlement 

Agreement as to [their] actions and positions including those that are the basis of the Motion.” (Opp’n Br. 5.) If he 

is referring to the “Notices” section of the AA, contained at paragraph 11.2, that section does not govern 

submissions to either this Court or to the FCC. In any event, Havens does not contend that he has been without 

notice, nor does he clarify how any formal notice failures taking place after the plaintiffs refused to execute the 

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into Havens’s opposition papers,7

 he writes that he and the entity plaintiffs refused to sign the 

closing documents because of “matters of State and contract law” extending to alleged defects in 

the FCC’s December 6 decision. (Pet. For Reconsideration 3 [D.E. 226].) But any defect should 

have been addressed in the first instance with the FCC. Havens presents no compelling reason to 

think that the December 6 decision was in any way defective.8

 In sum, the CSA and AA describe a series of actions to be taken by both the moving 

defendants and plaintiffs. The plaintiffs refuse to take certain final steps; Havens, who argues 

only for himself, premises this resistance on alleged procedural defects in the FCC proceedings 

and actions taken by the moving defendants since the time he and the entity plaintiffs declined to 

move forward. The Court has reviewed the parties’ submissions and finds that the moving 

defendants have demonstrated to the Court’s satisfaction that they have performed under the 

terms of the agreement. After reviewing Havens’s objections, the Court finds them all to be 

unpersuasive. 

 In their reply, the moving defendants ask the Court to compel the plaintiffs to withdraw a 

conditional Petition for Reconsideration pending before the FCC, which Havens filed pro se on 

behalf of himself and two entity plaintiffs. (See Reply Br. 10–11.) They argue that this violates 

the releases and covenant not to sue contained in the agreements. (See, e.g., CSA ¶¶ 7–10.) 

Because they raised this issue for the first time in the reply brief, the Court declines to rule on it, 

 closing documents justifies or otherwise relieves the plaintiffs’ more general responsibility to adhere to the terms of 

the CSA and AA. 

7

 The moving defendants argue that the incorporated petition is improper under D.N.J. L. Civ. R. 7.1(d)(2). (See

Reply Br. 2.) Because the two submissions, when combined, are otherwise within the boundaries of D.N.J. L. Civ. 

R. 7.2, they will be considered together for the purposes of this decision as one omnibus opposition brief. 

8

 To the extent that Havens contends that the signatories to the December 6 order were without actual decisionmaking power as “deputy chiefs” rather than “chiefs,” numerous FCC decisions under § 1.935 are rendered by the 

deputy chiefs of various divisions under the delegated authority created by governing regulations. See, e.g., In re 

Club 42 CM Ltd. P'ship, 28 FCC Rcd. 8341, 8345–46 (FCC 2013); In re Smith Bagley, Inc., 24 FCC Rcd. 5332, 

5333 (FCC 2009). The routine nature of these decisions is a strong signal of their validity. 

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noting that the plaintiffs’ promises in the CSA appear more in the nature of a defense to be raised 

in the forum where he is attempting to litigate. See, e.g., Skilstaf, Inc. v. CVS Caremark Corp., 

669 F.3d 1005, 1017 n.10 (9th Cir. 2012) (briefly discussing releases and covenants not to sue). 

 In light of the foregoing, the Court GRANTS the moving defendants’ motion to enforce 

the settlement agreement and directs the plaintiffs to comply with their obligations under the 

settlement agreement within 15 days of the filing of this opinion and the accompanying order. 

 

 

Date: May 14, 2014 

 /s/ Katharine S. Hayden 

 Katharine S. Hayden, U.S.D.J. 

 

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