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Good Karma Broadcasting, LLC

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Released: September 7, 2012

Federal Communications Commission

DA 12-1459

Before the

Federal Communications Commission

Washington, DC 20554

In the Matter of
)
)

GOOD KARMA BROADCASTING, LLC

)
File No. EB-09-IH-0756
)
FRN: 0015043227
Licensee of Station WKNR(AM), Cleveland, Ohio )
NAL/Account No.: 201132080018
)
Facility ID No. 28509

FORFEITURE ORDER

Adopted: September 7, 2012

Released: September 7, 2012

By the Chief, Investigations and Hearings Division, Enforcement Bureau:

I.

INTRODUCTION

1.
In this Forfeiture Order (Forfeiture Order), we assess a monetary forfeiture in the amount
of four thousand dollars ($4,000) against Good Karma Broadcasting, LLC (Good Karma or Licensee),
licensee of Station WKNR(AM), Cleveland, Ohio (Station), for willfully and repeatedly violating Section
73.1216 of the Commission’s rules by broadcasting information about a contest without fully and
accurately disclosing all of its material terms.1

II.

BACKGROUND

2.
As discussed in detail in the Notice of Apparent Liability for Forfeiture (NAL) issued in
this case,2 the Enforcement Bureau (Bureau) received a complaint alleging that, from approximately
November 2007 until September 2009, the Station conducted a “bogus” contest called “Who Said That?”
(Contest) during the “Really Big Show,” which, during the time period at issue, aired weekdays from
10:00 a.m. to noon.3 In particular, the complainant alleged that the Station “dropped talking about prizes”
during the course of the Contest.4 On June 19, 2009 and August 26, 2009, the Bureau sent letters of
inquiry (LOIs) to the Licensee regarding the contests.5 In response to those LOIs, Good Karma admitted


1 47 C.F.R. § 73.1216.
2 See Good Karma Broadcasting, LLC, Notice of Apparent Liability for Forfeiture, 25 FCC Rcd 17087 (Enf. Bur.
2010) (NAL).
3 See Complaint, Form 2000E Complaint No. 09-C00093667-1 (Feb. 13, 2009) (on file in EB-09-IH-0756) at 1-2
(Complaint).
4 Id. at 2.
5 See Letter from Rebecca A. Hirselj, Assistant Chief, Investigations and Hearings Division, Enforcement Bureau,
Federal Communications Commission, to Good Karma Broadcasting, LLC (June 19, 2009) (on file in EB-09-IH-
0756); Letter from Rebecca A. Hirselj, Assistant Chief, Investigations and Hearings Division, Enforcement Bureau,
Federal Communications Commission, to Good Karma Broadcasting, LLC (Aug. 26, 2009) (on file in EB-09-IH-
0756).

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DA 12-1459

that on a regular basis during early 2007 through the summer of 2008, and then sporadically thereafter
until September 4, 2009, the Station aired a “bit,” or program feature, called “Who Said That?” during
“The Really Big Show with Tony Rizzo.”6 Good Karma stated that, during broadcasts of the Contest, the
Station aired a voice recording of an unnamed individual in the sports world and listeners called in or sent
an e-mail to the Station to try to correctly identify the speaker.7 The Station would award prizes to
listeners who correctly identified the speaker.8 Once a listener called in and successfully identified the
speaker, the Station would select a new audio clip for listeners to identify and the Contest continued with
the new clip.9
3.
This practice continued regularly until the Station aired the last clip in the fall of 2007.
Good Karma noted that no one correctly identified the speaker of the clip for more than twenty months.10
The Licensee explained that from the fall of 2007 until the summer of 2008, the Station aired a prize
announcement during each weekday, two-hour program and notified listeners that additional prizes would
be added each week.11 The Licensee admitted, however, that the Station did not announce the entire list
of accumulated prizes, and was instead “identify[ing] the new prize and emphasiz[ing] material prizes in
the package.”12 The Licensee admitted that for over a year during the course of the Contest (from the
summer of 2008 until September 4, 2009), the Station stopped announcing prizes, unless a listener called
in and tried to guess the identity of the voice in the last clip.13 According to Good Karma, by September
2009, some originally-identified prizes were no longer available.14 Although the Station did not announce
any change in the prizes, Good Karma claimed that if a listener had correctly identified the speaker in the
last clip, the Station would have offered a similar package of prizes to what was originally announced.15
In view of the record evidence, the NAL proposed a forfeiture in the amount of four thousand dollars
($4,000) against Good Karma.16
4.
In its response to the NAL, Good Karma disputes that it committed a violation of our
contest rule.17 Good Karma asserts that “Who Said That?” is more properly characterized as a program


6 See Letter from Nancy A. Ory, Lerman Senter PLLC, Counsel for Good Karma Broadcasting, LLC, to Marlene H.
Dortch, Secretary, Federal Communications Commission, at 2 (July 20, 2009) (on file in EB-09-IH-0756) (First LOI
Response); Letter from Nancy A. Ory, Lerman Senter PLLC, Counsel for Good Karma Broadcasting, LLC, to
Marlene H. Dortch, Secretary, Federal Communications Commission, at 2 (Sept. 11, 2009) (on file in EB-09-IH-
0756) (Second LOI Response).
7 See First LOI Response at 2.
8 See id. at 2–3.
9 See id. at 3.
10 See id.
11 See Second LOI Response at 2–3.
12 Id. at 2.
13 See id. at 4–5.
14 See id. at 3.
15 See id.
16 See NAL, 25 FCC Rcd at 17092, para. 12.
17 See Response to Notice of Apparent Liability for Forfeiture of Good Karma Broadcasting, LLC (Jan. 7, 2011) (on
file in EB-09-IH-0756) (NAL Response).
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DA 12-1459

feature or “bit” rather than a traditional radio contest and therefore is not subject to our contest rule.18
Good Karma further contends that, even assuming that its programming constitutes a contest, it was
“generally and substantially conducted in material compliance” with Section 73.1216 and therefore the
Bureau should rescind the forfeiture.19 In support of its argument, Good Karma submits that: (1) the
Station was, at most, required to broadcast a “reasonable number” of prize list announcements
“periodically,” which Good Karma asserts that it did;20 and (2) Good Karma complied with the spirit of
Section 73.1216 with respect to prize disclosure.21 Good Karma also asserts that the NAL improperly
cites Clear Channel Broadcasting Licenses, Inc. (Clear Channel NAL).22 Moreover, Good Karma
suggests that, to the extent the Bureau rejects Good Karma’s argument that its actions at most constitute
technical violations of Section 73.1216, no action beyond an admonition is appropriate.23 We reject these
arguments as discussed below.

III.

DISCUSSION

5.
The proposed forfeiture amount in this case was assessed in accordance with Section
503(b) of the Communications Act of 1934, as amended (Act),24 Section 1.80 of the Commission’s
rules,25 and the Commission’s forfeiture guidelines set forth in its Forfeiture Policy Statement.26 In
assessing forfeitures, Section 503(b) 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 other matters as justice may require.27 As
discussed further below, we have examined Good Karma’s response to the NAL pursuant to the
aforementioned statutory factors, our rules, and the Forfeiture Policy Statement, and we find no basis for
cancellation or reduction of the forfeiture. We therefore affirm the forfeiture in the amount of four
thousand dollars ($4,000).
6.
Section 73.1216 provides: “A licensee that broadcasts or advertises information about a
contest it conducts shall fully and accurately disclose the material terms of the contest, and shall conduct


18 Id. at 2.
19 Id. at 2, 3.
20 Id. at 4, 7.
21 See id. at 4–6.
22 See id. at 3 n.3 (citing Clear Channel Broadcasting Licenses, Inc., Notice of Apparent Liability for Forfeiture, 15
FCC Rcd 2734, 2735 (Enf. Bur. 2000) (Clear Channel NAL)).
23 See NAL Response at 7–8 (citing Entercom Buffalo License, LLC, Order, 17 FCC Rcd 11997, 11998 (Enf. Bur.
2002) (stating, as quoted for support in the NAL Response, that “the First Amendment is a critical constitutional
limitation that demands we proceed cautiously and with appropriate restraint”); Action for Children’s Television v.
FCC
, 852 F.2d 1332, 1344 (D.C. Cir. 1988)).
24 47 U.S.C. § 503(b).
25 47 C.F.R. § 1.80.
26 The Commission’s Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the
Forfeiture Guidelines
, Report and Order, 12 FCC Rcd 17087 (1997), recons. denied, 15 FCC Rcd 303 (1999)
(Forfeiture Policy Statement).
27 47 U.S.C. § 503(b)(2)(E).
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DA 12-1459

the contest substantially as announced or advertised. No contest description shall be false, misleading, or
deceptive with respect to any material term.”28 Material terms under the rule “include those factors which
define the operation of the contest and which affect participation therein,”29 and generally include, among
other things, instructions on “how to enter or participate; eligibility restrictions; . . . whether prizes can be
won; when prizes can be won; . . . the extent, nature and value of prizes; [and] time and means of
selection of winners; . . . .”30 Although a licensee has discretion in determining the time and manner of
disclosing a contest’s material terms, and need not enumerate the terms each time it airs an announcement
promoting a contest, “the obligation to disclose the material terms arises at the time the audience is first
told how to enter or participate [in the contest] and continues thereafter.”31 Finally, disclosure of material
terms must be by announcements broadcast on the station; non-broadcast disclosures of material terms
can be made to supplement, but not substitute for, broadcast announcements. 32

A.

Good Karma Conducted a Contest.

7.
We find that the actions at issue here constitute a contest under the Commission’s contest
rule and therefore are subject to Section 73.1216. Good Karma asserts that “Who Said That?” is more
properly characterized as a program feature or “bit” rather than a traditional contest, thereby exempting it
from the requirements of Section 73.1216 of the Commission’s rules.33 We disagree. Section 73.1216,
Note 1(a), defines a contest as “a scheme in which a prize is offered or awarded, based upon chance,
diligence, knowledge or skill, to members of the public.”34 As we explained in the NAL, because the
Station offered or awarded various prizes to members of the public, its listeners, based upon the listeners’
knowledge of sports trivia, the material at issue clearly satisfies this definition.35 Accordingly, Section
73.1216 applies here.

B.

Good Karma’s Contest Violated Section 73.1216.

8.
We uphold our earlier finding that Good Karma’s Contest violated Section 73.1216.
Good Karma argues that even if “Who Said That?” was a contest, the Contest was “generally and
substantially conducted in material compliance” with Section 73.1216 for two overarching reasons.36


28 47 C.F.R. § 73.1216.
29 Id., Note 1(b).
30 Id. (emphasis added).
31 Id., Note 2.
32 See id. (“material terms should be disclosed periodically by announcements broadcast on the station conducting
the contest”). Posting contest rules on a station’s website does not satisfy Section 73.1216’s requirement that a
licensee broadcast the material terms of a contest it conducts. See, e.g., AK Media Group, Notice of Apparent
Liability for Forfeiture, 15 FCC Rcd 7541, 7543 (Enf. Bur. 2000) (forfeiture paid); Service Broadcasting Group,
LLC
, Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 8494, 8498–99 (Enf. Bur. 2009) (forfeiture paid).
33 See NAL Response at 2.
34 47 C.F.R. § 73.1216, Note 1(a).
35 Good Karma has acknowledged certain elements of the contest rule requirements, namely that it awarded prizes
based on listeners’ knowledge of who was speaking in the audio recording, and that these listeners were members of
the public. See First LOI Response at 2, 3; see also NAL, 25 FCC Rcd at 17090.
36 NAL Response at 2. Good Karma also argues that, at the time of its NAL Response, the Third Circuit Court of
Appeals was exploring the issue of scienter with respect to the willfulness factor in FCC forfeiture cases. See NAL
(Continued on next page....)
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First, Good Karma asserts that the Station was, at most, required to broadcast a “reasonable number” of
prize list announcements “periodically,” which Good Karma asserts that it did.37 Second, Good Karma
asserts that it complied with the spirit of Section 73.1216 with respect to prize disclosure.38 We address
each of these assertions in turn below.
1.

Good Karma Failed to Announce the Contest’s Material Terms with
Sufficient Frequency.

9.
In its NAL Response, Good Karma correctly notes that the Commission’s rules required
the Station to broadcast a “reasonable number” of announcements “periodically.”39 Based on the record,
however, we found in the NAL that Good Karma failed to meet this requirement with respect to the list of
prizes offered in the Contest because we concluded that the frequency of announcements in this case was
insufficient to meet the announcement requirement.40 As explained in the NAL, the record reflects that
the frequency of the announcements decreased over the course of the Contest, to the point that the
Licensee did not announce the Contest terms unless prompted by a listener to do so.41 As described in the
NAL, the Licensee admitted that for over a year during the Contest, the Station stopped announcing prizes
unless a listener called in and tried to guess the identity of the voice in the last clip.42 Good Karma does
not dispute these facts, and given that admission, we conclude that the material terms, including the prizes
offered, were not “periodically” broadcast throughout the course of the Contest.
2.

Good Karma Failed to Fully and Accurately Announce the Contest Prizes.

10.
We also uphold our earlier finding that Good Karma failed to comply with Section
73.1216’s requirements concerning prize disclosure. In particular, we noted that Good Karma failed to
announce on-air the list of accumulated prizes and failed to announce the fact that the announced prizes
were subject to substitution.43 After reviewing Good Karma’s NAL Response, we reject Good Karma’s
claims that: (a) Section 73.1216 does not require it to broadcast a list of accumulated prizes; and (b)
Section 73.1216 does not require it to broadcast the fact that prizes of equal value might be substituted for
certain previously announced prizes.44


(...Continued from previous page)
Response at 2 n.2. To the extent the Third Circuit has since resolved the case in question and specifically declined
to adopt findings related to the issue of scienter, that issue now appears moot. See CBS Corp. v. FCC, 663 F.3d 122
(3d Cir. 2011), petition for rehearing en banc denied, No. 06–3575 (3d Cir. Jan. 18, 2012), petition for cert. denied,
No. 11–1240, 2012 WL 2470244 (U.S. Jun. 29, 2012).
37 NAL Response at 4, 7.
38 See id. at 4–6.
39 See id. at 4 (citing 47 C.F.R. § 73.1216, Note 2).
40 See NAL, 25 FCC Rcd at 17090-91, para. 9.
41 See id.
42 See id. (citing Second LOI Response at 4–5).
43 See id. (citing Second LOI Response at 2–3).
44 See NAL Response at 4–5.
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11.
As noted above, Section 73.1216 requires that licensees conducting contests “shall fully
and accurately disclose the material terms of the contest.”45 Note 1(b) of Section 73.1216 clearly states
that “the extent, nature and value of prizes” is a material term.46 Nothing in Section 73.1216 indicates
that prizes of low value are excluded from this requirement. Thus, we reject Good Karma’s assertion that
it is within the licensee’s discretion to determine that certain prizes are “not as worthy of discussion.”47
Good Karma correctly notes that nothing prohibits a station from awarding more prizes than announced.48
Listeners, however, may not know if the station actually awarded fewer than previously announced prizes
unless the station periodically announces complete prize lists. Moreover, without such periodic
announcements, listeners cannot know whether previously announced prizes remain part of the total
package of prizes. Failing to periodically announce the full extent of the prizes, as Good Karma did in
this case, violates Section 73.1216.49
12.
We also reject Good Karma’s assertion that Section 73.1216 did not require it to
broadcast an announcement that prizes of equal value might be substituted for certain previously
announced prizes when Good Karma, in fact, made such substitutions and, by its own admission,
anticipated that it might do so.50 As discussed above, it is beyond dispute that “the extent, nature and
value of prizes” is a material term that must be disclosed.51 By announcing one prize and awarding
another without any broadcast notice that such a substitution might occur, Good Karma failed to
adequately announce the nature of the prize and failed to conduct the contest as announced.
13.
Good Karma further asserts that the general contest rules posted on the Station’s website
state that, “Stations reserve the right to substitute a prize of equal or greater value for all contests and
giveaways.”52 The Station acknowledges, however, that a comparable disclosure was never broadcast on
the Station.53 As noted above, online disclosure of contest terms does not substitute for broadcast
announcements of such terms.54
14.
Good Karma claims that the substitutable nature of the Contest’s prizes was self-evident
to listeners, including to the complainant.55 In particular, Good Karma explains that some prizes
announced during “Who Said That?” (such as tickets to sporting events set on precise dates) had


45 47 C.F.R. § 73.1216.
46 Id., Note 1(b).
47 NAL Response at 5. Even contests with comparatively low value prizes remain subject to Section 73.1216. See,
e.g., AMFM Broadcasting Licenses, LLC, Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 1529 (Enf. Bur.
2009) (forfeiture paid) (theater tickets); ABC, Inc., Notice of Apparent Liability for Forfeiture, 18 FCC Rcd 25647
(Enf. Bur. 2003) (forfeiture paid) (movie passes).
48 See NAL Response at 5 n.7.
49 See Complaint at 2 (noting that the Station has “dropped talking about prizes”).
50 See NAL Response at 5; First LOI Response at 3; Second LOI Response at 3.
51 47 C.F.R. § 73.1216, Note 1(b).
52 Second LOI Response at 3.
53 See id.
54 See supra note 32.
55 See NAL Response at 5–6.
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definitive “expiration dates” after which they would be of no value.56 Good Karma states that it intended
to award prizes—or their equivalent—that had already been announced.57 Listeners, however, could not
be expected to know the Licensee’s intentions without notice from the Licensee. The burden is not on the
listener to surmise the nature of the prizes, but rather on the licensee to announce it.58

C.

Imposition of a Forfeiture is the Appropriate Sanction for Good Karma’s Rule
Violation.

15.
We continue to assess a forfeiture in this case. Good Karma contends that the NAL’s
proposed forfeiture is overly harsh and no action beyond admonition is appropriate here.59 In urging a
more restrained approach for a Section 73.1216 violation, Good Karma argues that Section 73.1216
constitutes “government regulation of program content” and, therefore, the Commission should exercise
restrained agency enforcement” relating to that regulation, consistent with the Commission’s approach
to the regulation of program content.60 In support, Good Karma relies on two cases involving the
regulation of indecent speech, not the Commission’s contest rule.61 These cases provide no relevant
guidance about the contest case at issue, which has nothing to do with regulating indecency and the
sensitive First Amendment implications that such regulation entails. Indeed, the Commission has stated
that the contest rule, unlike matters involving indecency, is content neutral and “does not implicate the
First Amendment.”62
16.
Pursuant to the Commission’s Forfeiture Policy Statement and Section 1.80 of the
Commission’s rules, the base forfeiture for violations of the contest rules is four thousand dollars
($4,000).63 In assessing the monetary forfeiture amount, we must take into account the statutory factors
set forth in Section 503(b)(2)(E) of the Act, which include the nature, circumstances, extent, and gravity
of the violations, and with respect to the violator, the degree of culpability, any history of prior offenses,


56 Id.
57 See Second LOI Response at 3.
58 See, e.g., WMJX, Inc., Decision, 85 FCC 2d 251, 269 (1981) (subsequent history omitted) (WMJX, Inc.) (holding,
in part, that the licensee, as a public trustee, has an affirmative obligation to prevent the broadcast of false,
misleading or deceptive contest announcements).
59 See NAL Response at 2, 7. Good Karma also claims that the Clear Channel NAL was not pertinent to the facts at
issue in this case. See NAL Response at 3 n.3. However, the purpose for citing the Clear Channel NAL was to
demonstrate that the Bureau repeatedly has held that licensees are responsible for broadcasting accurate statements
as to the nature and value of contest prizes. In the Clear Channel NAL, the Bureau stated that licensees “will be held
accountable for any announcement which tends to mislead the public.” Clear Channel NAL, 15 FCC Rcd at 2735
(emphasis added) (citing WMJX, Inc., 85 FCC 2d at 272). Thus, citation to the Clear Channel NAL was appropriate.
60 NAL Response at 7 n.11.
61 See id. (citing Entercom Buffalo License, LLC, Order, 17 FCC Rcd 11997, 11998 (Enf. Bur. 2002) (stating, as
quoted for support in the NAL Response, that “the First Amendment is a critical constitutional limitation that
demands we proceed cautiously and with appropriate restraint”); Action for Children’s Television v. FCC, 852 F.2d
1332, 1344 (D.C. Cir. 1988) (subsequent history omitted)).
62 CBS Radio Inc. of Philadelphia, Memorandum Opinion and Order, 24 FCC Rcd 10993, 10996 (Enf. Bur. 2009)
(subsequent history omitted).
63 See supra note 26; 47 C.F.R. § 1.80.
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ability to pay, and other such matters as justice may require.64 Accordingly, as a result of our reviewing
Good Karma’s response to the NAL, we affirm the NAL and impose a forfeiture in the amount of four
thousand dollars ($4,000).

IV. ORDERING CLAUSES

17.

ACCORDINGLY, IT IS ORDERED

that, pursuant to Section 503(b) of the Act and
Section 1.80 of the Commission’s rules,65 and authority delegated by Sections 0.111 and 0.311 of the
Commission’s rules,66 Good Karma Broadcasting, LLC,

IS LIABLE FOR A MONETARY
FORFEITURE

in the amount of four thousand dollars ($4,000) for willfully and repeatedly violating
Section 73.1216 of the Commission’s rules.
18.
Payment of the forfeiture shall be made in the manner provided for in Section 1.80 of the
Commission’s rules by the close of business on or before September 21, 2012.67 If the forfeiture is not
paid within the period specified, the case may be referred to the U.S. Department of Justice for
enforcement of the forfeiture pursuant to Section 504(a) of the Act.68 Good Karma Broadcasting, LLC
shall send electronic notification of payment to Jeffrey Gee, Anjali Singh, and Melissa Marshall at
Jeffrey.Gee@fcc.gov, Anjali.Singh@fcc.gov, and Melissa.Marshall@fcc.gov on the date said payment is
made.
19.
The payment must be made by check or similar instrument, wire transfer, or credit card,
and must include the NAL/Account number and FRN referenced above. Regardless of the form of
payment, a completed FCC Form 159 (Remittance Advice) must be submitted.69 When completing the
FCC Form 159, enter the Account Number in block number 23A (call sign/other ID) and enter the letters
“FORF” in block number 24A (payment type code). Below are additional instructions you should follow
based on the form of payment you select:
Ÿ
Payment by check or money order must be made payable to the order of the Federal
Communications Commission. Such payments (along with the completed Form 159) must be
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank – Government Lockbox #979088, SL-MO-C2-
GL, 1005 Convention Plaza, St. Louis, MO 63101.
Ÿ
Payment by wire transfer must be made to ABA Number 021030004, receiving bank
TREAS/NYC, and Account Number 27000001. To complete the wire transfer and ensure
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank
at (314) 418-4232 on the same business day the wire transfer is initiated.
Ÿ
Payment by credit card must be made by providing the required credit card information on
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.


64 47 U.S.C. § 503(b)(2)(E).
65 47 U.S.C. § 503(b); 47 C.F.R. § 1.80.
66 47 C.F.R. §§ 0.111, 0.311.
67 47 C.F.R. § 1.80.
68 47 U.S.C. § 504(a).
69 An FCC Form 159 and detailed instructions for completing the form may be obtained at
http://www.fcc.gov/Forms/Form159/159.pdf.
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The completed Form 159 must then be mailed to Federal Communications Commission, P.O.
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank –
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
63101.
20.
Any request for full payment under an installment plan should be sent to: Chief Financial
Officer—Financial Operations, Federal Communications Commission, 445 12th Street, S.W., Room 1-
A625, Washington, D.C. 20554.70 If you have questions regarding payment procedures, please contact
the Financial Operations Group Help Desk by phone, 1-877-480-3201, or by e-mail,
ARINQUIRIES@fcc.gov.
21.

IT IS FURTHER ORDERED

that a copy of this Forfeiture Order shall be sent, by
Certified Mail/Return Receipt Requested, to Good Karma Broadcasting, LLC, 100 Stoddart Street, P.O.
Box 902, Beaver Dam, Wisconsin 53916, and to its counsel, Dennis P. Corbett, Esquire, Nancy A. Ory,
Esquire, and F. Scott Pippin, Esquire, Lerman Senter PLLC, 2000 K Street, N.W., Suite 600, Washington,
D.C. 20006.
FEDERAL COMMUNICATIONS COMMISSION
Theresa Z. Cavanaugh
Chief, Investigations and Hearings Division
Enforcement Bureau


70 See 47 C.F.R. § 1.1914.
9

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