NOTICE ************************************************************************* NOTICE ************************************************************************* This document was originally prepared in Word Perfect. If the original document contained-- * Footnotes * Boldface & Italics --this information is missing in this version The document format (spacing, margins, tabs, etc.) is changed too. If you need the complete document, download the Word Perfect version. For information about downloading documents (FTP) see file pnmc5021. File pnmc5021 (.txt & .wp) is in directory \pub\Public_Notices\Miscellaneous. ************************************************************************* Before the Federal Communications Commission Washington, D.C. 20554 In re Applications of ) ) DCR PCS, INC. ) File No. 00182WL96 et al. ) Applications for Broadband PCS ) C Block Licenses ) ORDER Adopted: November 1, 1996 Released: November 4, 1996 By the Chief, Wireless Telecommunications Bureau I. INTRODUCTION 1. By this Order, we resolve the Petition to Deny filed June 21, 1996 ("Petition"), by National Telecom PCS, Inc. ("NatTel") regarding the applications of DCR PCS, Inc. ("DCR") for various C block broadband Personal Communications Services (PCS) licenses. We conclude that NatTel has failed to demonstrate that granting DCR's applications would be inconsistent with the public interest. Accordingly, we deny the Petition and grant DCR's applications. II. BACKGROUND 2. On May 6, 1996, the Commission concluded its auction of 493 licenses to provide broadband PCS on the C block in the 2 GHz band. During the course of the auction, NatTel withdrew two high bids and, at the conclusion of the auction, was the high bidder for the American Samoa (B-492) C block PCS license. NatTel failed to make the required deposit to meet its required bid withdrawal and down payment. NatTel was deemed to be in default on its payment obligation for the American Samoa license and was made subject to the default payment specified in the Commission's Rules. 3. DCR was the winning bidder for forty-three C block PCS licenses. DCR has represented to the Commission that it qualifies as a small, minority and woman-owned business under the Commission's PCS designated entity rules. DCR is a wholly-owned corporate subsidiary of Pocket Communications, Inc. ("PCI"). The following parties currently hold direct interests of 5% or more in DCR through their interest in PCI. The chart below refers to the percentage of foreign ownership attributed to DCR by use of a multiplier taking into account each shareholder's voting share in PCI and the level of foreign ownership of each shareholder. % of Voting Stock % of Foreign Ownership Name in Applicant in Applicant Daniel C. Riker 16.13% 0% Janis Riker 19.79% 0% Teleconsult, Inc. 31.69% 1.20% MTI BVI, Inc. 20.45% 20.45% Westinghouse Electric Corp. 6.14% 0.80% 4. Given these various interests, DCR reports that foreigners comprise 22.45% of its parent's ownership. DCR contends that this level is within the twenty-five percent foreign ownership limit set forth in Section 310(b)(4) of the Communications Act of 1934, as amended ("the Act"), 47 U.S.C. 310(b)(4). 5. DCR and PCI share the following identical control group: Name % of Equity Daniel C. Riker 13.92% Janis Riker 17.08% Teleconsult, Inc. 27.73% According to DCR, this control group has control over all major management decisions of DCR and PCI, including the employment of senior executives. 6. On September 25, 1996, DCR filed an amendment to its FCC Form 600 exhibits. The amendment was filed to report that DCR's parent corporation, PCI, had issued an additional 120,000 stock options to certain of its employees and had issued additional equity to other investors so that the fully diluted equity calculations contained in its original application would remain substantially the same. DCR reported that PCI had elected to terminate its Service Contract with Westinghouse Electric Corporation ("Westinghouse") and that, in November 1996, it would be repurchasing Westinghouse's stock. DCR also reported that, in the future, PCI may be issuing additional options to other parties in consideration for short-term borrowing and vendor financing, and that the exercise of such options will be subject to compliance with all FCC requirements, including foreign ownership limitations. In addition, DCR reported that PCI's board of directors had approved in principle a recapitalization plan designed to ensure compliance with the Commission's voting control and equity structure requirements following the consummation of a planned public offering of stock. DCR stated in its amendment that the recapitalization would not be implemented until the consummation of PCI's initial public offering and following the grant of DCR's applications. DCR reports in its amendment that none of these changes would affect DCR's qualifications as a prospective licensee. In particular, DCR contends that it would still qualify as a small business in which the control group holds 58.73 percent of its fully diluted equity, exceeding the 50.1 percent required by the Commission's Rules. 7. In its Petition to Deny, NatTel raises a variety of arguments relating to four basic issues: (1) DCR's percentage of foreign ownership; (2) DCR's qualification as a minority or women-owned business; (3) the attribution of Westinghouse's equity interest in DCR's parent corporation; and (4) errors in DCR's short form application. 8. First, NatTel argues that DCR's foreign ownership exceeds the limitation set forth in Section 310(b)(4) of the Act. NatTel notes that PCI has a right to reacquire the shares of Teleconsult, Inc. ("Teleconsult"), which currently holds a 31.69 percent voting interest in PCI. NatTel argues that, if PCI reacquired Teleconsult's shares, those shares would necessarily become "treasury stock" and that such stock would be treated as retired and no longer counted when calculating PCI's ownership percentages. NatTel argues that this action would reduce the number of outstanding PCI shares and thus increase the percentage of PCI's foreign ownership above the 25 percent limit. NatTel argues that this "call option" must be treated "as called" for the purpose of calculating DCR's foreign ownership. 9. In a second foreign ownership claim, NatTel notes that Masa Telecom, Inc. ("Masa"), which owned 20.65% of the voting stock of PCI at the time DCR filed its application, is owned 94.9% by foreigners. NatTel alleges that Masa's foreign owners exert de facto control over Masa and that 100% of Masa's shares should be counted when calculating DCR's foreign ownership. In its First Supplement, NatTel also alleges that Masa must control Teleconsult, Inc. ("Teleconsult") since, according to NatTel, Masa has provided all of Teleconsult's investment in PCI. Other than generally referring to PCI's August 29, 1996, SEC Form S-1 filing, NatTel offers no specific support for this allegation. 10. Next, NatTel alleges that DCR is not a minority or woman-owned business and should not have been permitted to claim credit as such in the C block PCS auctions. NatTel first argues that Daniel C. Riker, a white male and one of three members of DCR's and PCI's control groups, has assumed de facto control over DCR. NatTel asserts that the acronym "DCR" is based upon Daniel C. Riker's initials and this demonstrates Mr. Riker's dominance over the company. NatTel refers to the fact that Mr. Riker sent a letter on behalf of PCI to other potential PCS licensees setting forth PCI's goals with respect to the Commission's interconnection proceeding. NatTel argues that this letter is evidence that Mr. Riker is controlling DCR's "goals and purposes." NatTel also notes that Mr. Riker is an officer and director of DCR, which, NatTel argues, is further evidence of Mr. Riker's de facto control over the corporation. Since Mr. Riker controls DCR, NatTel argues, DCR does not qualify as a minority or woman-owned business. 11. In addition, NatTel argues that DCR is not qualified as a minority or woman-owned business because Teleconsult has granted Janis Riker (another member of the DCR control group) an irrevocable proxy to vote 9 percent of Teleconsult's shares. NatTel argues that the only minority in DCR's control group is Teleconsult, but that, by virtue of the irrevocable proxy, Teleconsult has less than 100 percent of the voting power of DCR. NatTel contends that, in order to qualify as a minority or woman-owned business, DCR must have a control group that is composed 100 percent of minorities and woman. According to NatTel, because DCR's control group is not composed entirely of minorities and women, the certifications contained in its applications concerning its status as a minority and woman-owned business are misrepresentations. 12. NatTel also alleges that Westinghouse, which currently has a 5.37 percent fully- diluted equity interest in PCI, is an "attributable investor" in DCR and, as such, DCR did not qualify as a "small business" for the C block PCS auctions. Because Westinghouse had total assets of $16.7 billion in 1995 and gross revenues of $12 billion in 1992 and 1993, NatTel contends that Westinghouse's position as an "attributable investor" would have invalidated DCR's claim to be a small business and would have disqualified it from participation in the C block PCS auctions. 13. Moreover, NatTel argues that Westinghouse has de facto control over DCR. NatTel submits that control is evidenced by the fact that Westinghouse is a member of DCR's auction committee. NatTel argues that as a "passive investor" Westinghouse should not have a role in important corporate decisions. NatTel also notes that Westinghouse has veto power over a change of control of PCI and that this fact alone demonstrates that Westinghouse has both de facto and de jure control over DCR. NatTel additionally argues that Westinghouse's prior criminal convictions render DCR unqualified as a PCS licensee. 14. Finally, NatTel argues that DCR's short form application (FCC Form 175) was incomplete and defective and that it should have been returned by the Commission's staff. NatTel asserts that DCR filed its short form application electronically and the exhibit footnotes were not converted from WordPerfect to ASCII and were unreadable. NatTel argues that this error was material and rendered DCR's application unacceptable for filing. 15. In its Opposition, DCR argues that NatTel does not have standing to challenge DCR's various C block PCS applications, as NatTel has not shown that it is a "party in interest" as required by Section 309(d)(1) of the Act. With respect to NatTel's substantive arguments, DCR argues that it has complied with the foreign ownership limitations set forth in Section 310(b)(4) of the Act. DCR contends that the Commission should not treat its "call option" to reacquire Teleconsult's shares as fully exercised since, in the context of foreign ownership, the Commission has consistently not treated such options as exercised. 16. In its Response to First Supplement, DCR rejects NatTel's allegation that Masa controls Teleconsult. DCR states that NatTel has mistakenly read PCI's SEC Form S-1 filing to mean that Masa has provided the financing for Teleconsult to acquire its shares of PCI. DCR states that, while Masa loaned money to Teleconsult, the loan was issued approximately a year after Teleconsult had already acquired its stock in PCI, and the Masa loan agreement specifically bars Teleconsult from using the proceeds to make investments in other businesses, including PCI. 17. Further, DCR defends its status as a minority and woman-owned business. DCR contends that NatTel has misread the Commission's rules with respect to the level of minority and female ownership that is required to claim credit as a minority and/or woman-owned business in the C block PCS auctions. DCR also argues that Daniel C. Riker does not have control over DCR. 18. DCR additionally asserts that NatTel has misread the Commission's rules with respect to whether Westinghouse has an attributable interest in DCR. DCR argues that Westinghouse's 5.37 percent fully diluted interest is not attributable and, contrary to NatTel's claims, there is no evidence that Westinghouse has de facto control over DCR. DCR concludes that, since Westinghouse does not have an attributable interest in DCR, there is no reason to consider its prior criminal convictions. 19. Finally, DCR points out that the error contained in its short form (FCC Form 175) application was minor and immaterial and that the Commission permitted DCR an opportunity to amend its application, which it did prior to the C block auction. DCR explains that the footnotes to the exhibits included with its short form application were inadvertently not converted from WordPerfect to ASCII form. DCR contends that the Wireless Telecommunications Bureau did not err when it permitted DCR to amend its short form application to correct such a minor error. 20. In its Reply, NatTel argues that it is a party in interest with respect to DCR's applications because NatTel would not have had to bid an additional $51,000 in the American Samoa market had DCR been properly denied access to the C block PCS auctions. In its Petition to Deny, DCR also claims that it "lost out on opportunities to acquire markets due to DCR's mutually exclusive application." III. DISCUSSION A. Standing 21. As an initial matter, we find that NatTel has failed to demonstrate the requisite standing to make a blanket challenge to all of DCR's C block PCS applications. NatTel has not shown that it is a "party in interest" as required by Section 24.830(a)(3) of the Commission's rules and Section 309(d)(1) of the Act with respect to all of the markets for which DCR was the winning bidder. While NatTel argues that it lost out on opportunities to acquire PCS licenses due to DCR's mutually exclusive application, we find that NatTel's participation in the C block auction was severely limited by its upfront payment of only $50,000. 22. Under the Commission's rules, in order for a party to participate in an auction for a particular C block PCS market, it must submit an upfront payment that is equal to the sum of $0.015 multiplied by the population of market ("pop") and the amount of megahertz ("MHz") for which it intends to bid. Based on its $50,000 upfront payment, NatTel was only eligible to bid in markets with a cumulative population of 111,111 or less. Of the 43 markets for which DCR was the winning bidder, only four of these had populations of 111,111 or less -- Adrian, Michigan (population 91,476), Michigan City, Indiana (population 107,066), Pittsburgh, Kansas (population 90,934) and Northern Marianas Islands (population 43,000). NatTel bid on only one of those markets: Northern Marianas Islands. Because NatTel could have bid in only four of the markets for which DCR was the winning bidder, NatTel has, at best, demonstrated that it is a party in interest with respect to those four markets. 23. NatTel also argues that it has standing to challenge all of DCR's applications because it would have been able to win the auction for the American Samoa market with a lower winning bid had DCR not been allowed to participate in the C block auctions. We find that this alleged injury is based upon a hypothetical event that is too speculative to support the requisite finding of "a direct injury causally linked to the challenged action." Because it has not shown an injury in fact, NatTel lacks the requisite standing to file a blanket Petition to Deny all of DCR's C block PCS applications. Nevertheless, because we conclude that NatTel is a party-in- interest in four of DCR's markets, we will consider NatTel's substantive arguments to the extent they affect those markets. B. DCR's Level of Foreign Ownership 24. NatTel argues that DCR's percentage of foreign ownership is inconsistent with the foreign ownership limitations set forth in Section 310(b)(4) of the Act. We disagree. The fact that PCI holds a "call option" to reacquire the shares of Teleconsult does not support such a finding. While Section 24.709(b)(7) of the Commission's rules does provide that stock options will generally be treated as fully exercised for the purposes of determining eligibility as a small business, Commission precedent is clear that with respect to foreign ownership questions, an option held by a foreigner to buy stock in a licensee or the parent of a licensee is not cognizable until it is exercised. The Commission does not treat options as exercised in those cases where there is a redemption or savings clause contained in the applicant's corporate charter which would allow it to redeem foreign shares to ensure continued compliance with Section 310(b)(4) of the Act in the event such an option were exercised. Because PCI's corporate charter contains such a redemption provision, the existence of the call option is not an obstacle to a grant of DCR's applications. 25. Similarly, we find that the fact that 94.9 percent of the stock of Masa, a former stockholder of PCI, was owned by foreigners is irrelevant. Masa has sold its interest in PCI to MTI BVI, Inc., a foreign corporation and MTI's interest in PCI is fully accounted for within the 25 percent limit established by Section 310(b)(4). 26. We also find no support for NatTel's allegation that Teleconsult is a representative of foreigners and should be treated as 100 percent foreign owned. NatTel's erroneous allegation that Masa provided the financing for Teleconsult to acquire its share in PCI was apparently based upon a misreading of PCI's SEC Form S-1 filing. We find no other evidence that Masa controls Teleconsult. C. DCR's Status as a Minority and Woman-Owned-Business 27. As an initial matter, it should be noted that the issue of whether DCR is a minority and/or woman-owned business is no longer relevant, given the Commission's Sixth Report and Order, in which the Commission concluded that the C Block auction rules would be race and gender neutral. Nevertheless, because NatTel has alleged that DCR's minority and woman- owned business certifications were false and constituted misrepresentations, a full evaluation of its allegations is warranted. 28. NatTel's claim that Daniel C. Riker, a non-minority male, has assumed de facto control over DCR is unfounded. In Ellis Thompson Corporation, the Commission outlined the criteria (known as the Intermountain Microwave factors) for determining whether a transfer of control has occurred. Those criteria are: (1) Does the party have unfettered use of all facilities and equipment; (2) who controls daily operations; (3) who determines and carries out the policy decisions; (4) who is in charge of employment, supervision and dismissal of personnel; (5) who is in charge of the payment of financing obligations, including expenses arising out of operations; (6) who received monies and profits derived from the operation of the facilities? We find that none of the matters raised by NatTel, when examined under these six criteria, support a finding that Daniel Riker controls DCR. 29. Mr. Riker holds only 16.13 percent of the voting stock of PCI, DCR's parent company, and is one of three members of DCR's control group. According to DCR, this control group will have control over all of DCR's major management decisions. NatTel has not shown that Mr. Riker has the ability to override the authority of the other members of the control group in order to exercise sole control of the daily operations of DCR's PCS systems. Similarly, NatTel has not produced any evidence that Mr. Riker alone has determined and carried out DCR's policy decisions. The allegation that Mr. Riker sent correspondence to other potential PCS licensees on behalf of the corporation, by itself, does not demonstrate that Mr. Riker controls DCR's policy decisions. As one of PCI's officers and directors, Mr. Riker may be involved in PCI's corporate affairs, but NatTel has not shown how Mr. Riker will be able to use these positions to control DCR's day-to-day operations or policy making. NatTel has not produced any evidence to suggest that Mr. Riker will control access to DCR's facilities or that he will have control over key personnel decisions. DCR has stated that its control group will have control over the employment of senior executives. Furthermore, there is no evidence that Mr. Riker has controlled DCR's financing or that Mr. Riker will receive more than his pro rata share of monies derived from DCR's operations. In sum, NatTel has not shown that Riker has or will be able to individually dominate DCR's corporate affairs. 30. In addition, NatTel has misread Commission rules and decisions in an effort to show that DCR was not qualified as a minority and/or woman-owned business for competitive bidding purposes. Section 24.720(c) of the rules states that a business owned by members of minority groups and/or women is an entity: (1) in which the qualifying investor members of the applicant's control group are members of minority groups and/or women, and (2) that complies with the requirements of Sections 24.709(b)(3) and (b)(5) or Sections 24.709(b)(4) and (b)(6) of the rules. When the Commission revised its competitive bidding rules, it did so to permit applicants to claim credit as a minority and/or woman-owned business, as long as 30 percent of the applicant's total equity was held by principals of the control group who are minorities and/or women. In this case, at least 30 percent of DCR's total equity is so held. NatTel has not produced any evidence to rebut the Commission's presumption that control of DCR is vested other than in its shareholders as a whole. Because NatTel has not shown that DCR's minority and female ownership certifications were false, we find that there is no support for NatTel's allegation that DCR misrepresented its ownership structure to the Commission. D. Westinghouse's Interest in DCR 31. NatTel alleges that Westinghouse's 5.37 percent fully-diluted equity interest in DCR is "attributable" with respect to determining whether DCR is a "small business" and qualified to participate in the C block PCS auction. We do not agree. Westinghouse holds less than 25 percent of the fully-diluted equity of DCR. Section 24.709(b)(3) of the rules states that: the gross revenues and total assets of a person or entity that holds an interest in the applicant (or licensee), and its affiliates, shall not be considered so long as: . . . Such person or entity, together with its affiliates, holds only nonattributable equity equalling no more than 25 percent of the applicant's . . . total equity . . . such person or entity is not a member of the applicant's . . . control group; and . . . The applicant . . . has a control group that complies with the minimum equity requirements of paragraph (b)(5) of this section, and, if the applicant . . . is a corporation, owns at least 50.1% of the applicant's . . . voting interests.... Because Westinghouse holds less than 25 percent of the fully-diluted equity of DCR and DCR's control group complies with the minimum equity requirements of the rules, we find that Westinghouse's interest is not attributable for the purposes of determining whether DCR is a small business. 32. As for NatTel's allegation that Westinghouse has assumed de facto control of DCR, the matters raised by NatTel, when examined under the six criteria set forth in Ellis Thompson Corporation, do not support such a finding. The corporate provisions that NatTel cites as demonstrative of Westinghouse's control are rights typically granted to minority shareholders to provide a certain level of protection for their investment and do not provide Westinghouse with a means of assuming control of DCR. For example, the fact that Westinghouse is one of four members on DCR's auction committee is not dispositive proof that Westinghouse will be able to control DCR's policy making or daily operations. In previous cases, the Commission has found that membership on a corporate committee does not rise to the level of de facto control. Similarly, the fact that Westinghouse may be able to veto a change of control by DCR is of no consequence. The Commission has found such a provision to be an appropriate means of permitting a minority investor to protect its investment. Because Westinghouse does not exercise control over DCR, we find that there is no reason to consider its prior criminal convictions. E. DCR's Short Form Application 33. NatTel's next argument is that DCR's short form applications were defective and should have been returned without consideration. We find that DCR's short form application contained a minor error that was not material and that did not warrant its return. Contrary to NatTel's contentions, the Commission does not enforce a letter perfect standard with respect to PCS short form applications. We find that DCR's application contained a minor error similar to a typographical error, which applicants are permitted to correct under the Commission's rules. According to DCR's explanation, the footnotes to the exhibits included with DCR's short form application were mistakenly not translated from WordPerfect code to ASCII code. After being notified by the Commission of this error, DCR was permitted an opportunity to correct it, and it promptly did so prior to the beginning of the C block auction. To have returned DCR's short form application for such a minor, immaterial error would have been contrary to the Commission's rules and stated policy. 34. Furthermore, we find that DCR's September 25, 1996, amendment to its application was minor and did not affect its qualifications as a prospective licensee. The fact that PCI has issued additional shares of stock does not affect DCR's qualifications because the overall equity percentages of PCI's stockholders have not changed substantially. Similarly, the fact that Masa sold its interest to MTI BVI, Inc., a foreign corporation with identical ownership, does not affect DCR's qualifications because MTI BVI, Inc., only has a 20.45 percent interest in DCR and DCR's foreign ownership is still within the 25 percent limit. IV. CONCLUSION 35. Having reviewed the applications, the amendments and the pleadings filed in this matter, we conclude that grant of the subject applications, as amended, will serve the public interest, convenience, and necessity, and that NatTel has not sufficiently alleged facts establishing that grant of the applications would be inconsistent with the public interest, convenience, and necessity. Therefore, we deny NatTel's Petition and grant DCR's applications. 36. The grant of DCR's applications is expressly conditioned on payment within five (5) business days of the release of this Order of the remaining portion of the 10 percent down payments due on each of the licenses. Payment of the remainder of the amount due on each license will be made in quarterly installments in accordance with Parts 1 and 24 of the Commission's rules. For each license granted, DCR PCS, Inc., will receive from the United States Department of Treasury an original note documenting its installment payment obligations and a security agreement commemorating the Commission's security interest in the license in the event of default. The notes and security agreements will include instructions on the completing, signing, and return of the documents to the Treasury Department. The grant of DCR's applications is expressly conditioned on timely execution and return of the notes and security agreements in accordance with these instructions. V. ORDERING CLAUSES 37. Accordingly, pursuant to our authority under Section 309(d)(2) of the Communications Act of 1934, as amended, 47 U.S.C. 309(d)(2), IT IS ORDERED that the Petition to Deny filed by National Telecom PCS, Inc., IS DENIED and that the applications of DCR PCS, Inc., for broadband PCS C block licenses listed in Appendix A attached hereto are GRANTED, subject to the conditions set forth above. 38. This action is taken pursuant to delegated authority as set forth in Section 0.331 of the Commission's rules, 47 C.F.R.  0.331. FEDERAL COMMUNICATIONS COMMISSION Michele C. Farquhar Chief, Wireless Telecommunications Bureau APPENDIX A Applications of DCR PCS, Inc., for broadband PCS C block licenses. Market Call Sign File Number Name B005 KNLF487 00182-CW-L-96 DCR PCS, INC. B033 KNLF488 00283-CW-L-96 DCR PCS, INC. B046 KNLF489 00286-CW-L-96 DCR PCS, INC. B067 KNLF490 00288-CW-L-96 DCR PCS, INC. B071 KNLF491 00290-CW-L-96 DCR PCS, INC. B078 KNLF492 00293-CW-L-96 DCR PCS, INC. B090 KNLF493 00296-CW-L-96 DCR PCS, INC. B101 KNLF494 00298-CW-L-96 DCR PCS, INC. B109 KNLF496 00302-CW-L-96 DCR PCS, INC. B112 KNLF495 00300-CW-L-96 DCR PCS, INC. B140 KNLF497 00304-CW-L-96 DCR PCS, INC. B145 KNLF498 00306-CW-L-96 DCR PCS, INC. B153 KNLF499 00308-CW-L-96 DCR PCS, INC. B169 KNLF500 00310-CW-L-96 DCR PCS, INC. B190 KNLF502 00314-CW-L-96 DCR PCS, INC. B192 KNLF503 00316-CW-L-96 DCR PCS, INC. B195 KNLF504 00318-CW-L-96 DCR PCS, INC. B209 KNLF505 00320-CW-L-96 DCR PCS, INC. B219 KNLF506 00322-CW-L-96 DCR PCS, INC. B223 KNLF507 00324-CW-L-96 DCR PCS, INC. B225 KNLF508 00326-CW-L-96 DCR PCS, INC. B243 KNLF509 00328-CW-L-96 DCR PCS, INC. B245 KNLF510 00330-CW-L-96 DCR PCS, INC. B255 KNLF511 00332-CW-L-96 DCR PCS, INC. B257 KNLF512 00334-CW-L-96 DCR PCS, INC. B260 KNLF513 00336-CW-L-96 DCR PCS, INC. B294 KNLF514 00338-CW-L-96 DCR PCS, INC. B308 KNLF515 00340-CW-L-96 DCR PCS, INC. B310 KNLF516 00342-CW-L-96 DCR PCS, INC. B320 KNLF517 00344-CW-L-96 DCR PCS, INC. B332 KNLF519 00348-CW-L-96 DCR PCS, INC. B349 KNLF520 00350-CW-L-96 DCR PCS, INC. B355 KNLF521 00352-CW-L-96 DCR PCS, INC. B380 KNLF522 00354-CW-L-96 DCR PCS, INC. B394 KNLF526 00362-CW-L-96 DCR PCS, INC. B403 KNLF523 00356-CW-L-96 DCR PCS, INC. B419 KNLF524 00358-CW-L-96 DCR PCS, INC. B426 KNLF525 00360-CW-L-96 DCR PCS, INC. B443 KNLF527 00383-CW-L-96 DCR PCS, INC. B444 KNLF528 00384-CW-L-96 DCR PCS, INC. B452 KNLF529 00387-CW-L-96 DCR PCS, INC. B490 KNLF501 00312-CW-L-96 DCR PCS, INC. B493 KNLF518 00346-CW-L-96 DCR PCS, INC.