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Greater Boston Radio, Inc. Fined for Contest Violation

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Released: February 28, 2013

Federal Communications Commission

DA 13-310

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
)

File No.: EB-08-IH-5305

Greater Boston Radio, Inc.

)
NAL/Account No.: 200932080039
)
FRN: 0005069802
Licensee of Station WMJX(FM)
)
Facility ID No.: 25052
Boston, Massachusetts
)

FORFEITURE ORDER

Adopted: February 28, 2013

Released: February 28, 2013

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

I.

INTRODUCTION

1.
In this Forfeiture Order, we assess a monetary forfeiture in the amount of four thousand
dollars ($4,000) against Greater Boston Radio, Inc. (Licensee), licensee of Station WMJX(FM), Boston,
Massachusetts (Station), for its willful and repeated violation of Section 73.1216 of the Commission’s
rules concerning licensee-conducted contests.1 As discussed below, the Licensee violated the contest rule
by broadcasting information about a contest without fully and accurately disclosing all material terms
thereof and by failing to conduct the contest substantially as announced or advertised.

II.

BACKGROUND

2.
The Commission received a complaint in May 2008 (Complaint) alleging that the Station
failed to conduct a contest in accordance with the contest’s advertised terms and the Commission’s
rules.2 The complainant alleged that contest promotions broadcast by the Station stated that the contest
winner would receive the winner’s choice of one of three new cars.3 The complainant was a preliminary
winner who received an initial cash prize, along with an automobile ignition key.4 Only after qualifying
for a chance to win the grand prize did the Complainant learn that the prize to be awarded was not the
winner’s choice of three available cars but, instead, a two-year lease of the selected car. The complainant


1 47 C.F.R. § 73.1216.
2 Complaint to Federal Communication Commission, IC No. 08-C00018081-1 (May 2, 2008) (on file in EB-08-IH-
5305) (Complaint).
3 Id. at 3.
4 Id.

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also learned at that time that the winner had to qualify for credit with the car dealer supplying the leased
car as a (previously unannounced) condition of the Station awarding the grand prize.5
3.
After receiving the Complaint, the Enforcement Bureau (Bureau) sent a letter of inquiry
(LOI) to the Licensee, directing the Licensee to provide information about the contest.6 The Licensee
responded to the LOI in March 2009 (LOI Response).7 In its LOI Response, the Licensee identified the
contest as the “Cool, Hot or Green” contest (Contest) and explained the primary elements of the
contest—that listeners were to call into the Station at designated times in order to win a gas card worth
one hundred six dollars ($106) (representing the Station’s position on the FM dial – 106.7MHz), and a
chance to win the grand prize.8 The Station broadcast contest promotions stating that the grand prize was
the winner’s choice of three different cars.9
4.
The Licensee acknowledged that “while the Contest, as described on air, made plain that
the grand prize winner would be able to choose from three different cars, only the complete rules of the
Contest, made available via the Station’s website . . . spelled out that what was being awarded was a two-
year lease of the car chosen, and not title to a car, and that the winner would have to be qualified for
credit by Prime Motor Group,”10 the Contest co-sponsor.11 Moreover, the Licensee admitted that “the
Station’s on-air announcements did not directly refer listeners to the Station’s website for complete
contest rules.”12 Nevertheless, the Licensee asserted that its violation of the Commission’s rules was
similar to that of the licensee in Kevin Cooney (Cooney), and that the violation in this case therefore
warranted no greater sanction than an admonishment of the Licensee.13
5.
On April 8, 2009, having fully considered these arguments, we issued a Notice of
Apparent Liability for Forfeiture (NAL) in the amount of four thousand dollars ($4,000) to the Licensee.
We found that it broadcast information about the Contest without fully and accurately disclosing all


5 Id.
6 Letter from Rebecca Hirselj, Assistant Chief, Investigations and Hearings Division, FCC Enforcement Bureau, to
Greater Boston Radio, Inc. (Feb. 11, 2009) (on file in EB-08-IH-5305) (LOI).
7 Letter from David S. Keir, Esq., Lerman Senter PLLC, to Judy Lancaster, Attorney Advisor, Investigations and
Hearings Division, FCC Enforcement Bureau (Mar. 20, 2009) (on file in EB-08-IH-5305) (LOI Response).
8 Id. at 2.
9 Id. at 2–3.
10 Id. at 3.
11 Id.
12 Id. at 2. The Station’s announcements consistently described the grand prize in the “Cool, Hot or Green” contest
as “A Cool Mercedes Benz…A Hot Audi TT Convertible…or a [Green] Toyota Prius Hybrid . . . from Prime Auto
Group . . . No fine print gimmicks . . . on line at Driveprime.com!” Id. at Exh. 2.
13 Id. at 6–7 (citing Kevin Cooney, Letter of Admonition, 5 FCC Rcd 7105 (Mass Med. Bur. 1990) (Cooney)).
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material terms thereof and failed to conduct the contest substantially as announced or advertised, in
violation of Section 73.1216 of the Commission’s rules.14
6.
On May 7, 2009, the Licensee filed a response to the NAL (NAL Response).15 In the
NAL Response, the Licensee does not dispute that its conduct of the Contest violated Section 73.1216,
but nevertheless requests that the proposed forfeiture be cancelled or reduced to, at most, an
admonishment.16 As justification for this request, the Licensee continues to primarily rely upon the
decision in Cooney17 and to argue that “[b]ecause [that case] is substantially similar to this case, under
the principles of Melody Music . . . the most severe sanction appropriate here is an admonition.”18 As
noted above, in the NAL the Bureau specifically considered and rejected the Licensee’s comparison of
this case to Cooney,19 and we continue to do so here.

III.

DISCUSSION

7.
Section 73.1216, the Commission’s rule concerning licensee-conducted contests,
provides that: “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 the contest substantially
as announced or advertised. No contest description shall be false, misleading or deceptive with respect to
any material term.”20 Material terms under the rule “include those factors which define the operation of
the contest and which affect participation therein[,]”21 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
. . . .”22 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 an announcement promoting a contest is
broadcast, “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.”23 Finally, disclosure of material terms must
be made by announcements broadcast on the station; non-broadcast disclosures of material terms can be


14 Greater Boston Radio, Inc., Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 4103, 4106, para. 9 (Enf.
Bur. 2009) (NAL).
15 Letter and Response to Notice of Apparent Liability for Forfeiture from Sally A. Buckman and David S. Kier,
Attorneys, Lerman Senter PLLC, to Hillary S. DeNigro, Chief, Investigations and Hearings Division, FCC
Enforcement Bureau (May 7, 2009) (on file in EB-08-IH-5305) (NAL Response).
16 See id at 1, 8.
17 See id. at 3–6 (citing Cooney, 5 FCC Rcd 7105).
18 Id. at 5 (citing Melody Music, Inc. v FCC, 345 F.2d 730 (D.C. Cir. 1965) (Melody Music)).
19 NAL, 24 FCC Rcd at 4106–07, paras. 10–11.
20 47 C.F.R. § 73.1216.
21 Id., Note 1(b).
22 Id.
23 Id., Note 2.
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made to supplement, but not substitute for, broadcast announcements.24 The Licensee admits the
violation at issue here, and thus, the only issue that remains in contention is the issuance of a forfeiture,
as we assessed, versus an admonishment, as the Licensee advocates.25
8.
The proposed forfeiture amount in this case was assessed in accordance with Section
503(b) of the Communications Act of 1934, as amended (the Act),26 Section 1.80 of the Commission’s
rules,27 and the Commission’s forfeiture guidelines set forth in its Forfeiture Policy Statement.28 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.29 As
discussed further below, we have examined the Licensee’s response to the NAL pursuant to the
aforementioned statutory factors, our rules, and the Forfeiture Policy Statement, and in light of the
conduct, our precedent, and the Licensee’s compliance history, we continue to find the base forfeiture
amount to be appropriate in this case.

A.

Precedent Supports a Forfeiture in This Case.

1.

The Bureau’s Forfeiture Assessment Accords With Recent Precedent.

9.
The Bureau’s decision in this case is consistent with recent decisions concerning Section
73.1216,30 especially the Bureau decision in ABC, Inc.31 In ABC, two movie passes to the premier


24 See id. (“material terms should be disclosed periodically by announcements broadcast on the station conducting
the contest”) (emphasis added). 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., Service Broadcasting
Group, LLC
, Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 8494, 8497, para. 10 (Enf. Bur. 2009)
(assessed $4,000 forfeiture for inaccurate description of contest prize) (forfeiture paid) (Service Broadcasting); AK
Media Group
, Notice of Apparent Liability for Forfeiture, 15 FCC Rcd 7541, 7543, para. 7 (Enf. Bur. 2000)
(forfeiture paid).
25 See NAL Response at 1, 8.
26 47 U.S.C. § 503(b).
27 47 C.F.R. § 1.80.
28 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, para. 53 (1997), recons. denied, 15 FCC Rcd 303,
para. 1 (1999).
29 47 U.S.C. § 503(b)(2)(E).
30 See, e.g., Citicasters Co., Notice of Apparent Liability for Forfeiture, 15 FCC Rcd 16612, 16613–14, paras. 6, 8
(Enf. Bur. 2000) ($4,000 forfeiture imposed for the licensee’s failure to fully and accurately disclose contest term
that the prize was one million Turkish lira, not $1,000,000) (forfeiture paid); Clear Channel Broadcasting
Licenses, Inc.
, Notice of Apparent Liability for Forfeiture, 15 FCC Rcd 2734, 2735–36, paras. 6, 9 (Enf. Bur.
2000) ($4,000 forfeiture imposed for the licensee’s failure to fully and accurately disclose contest term that the
prize was 10,000 Italian lira, not $10,000) (forfeiture paid); Service Broadcasting, 24 FCC Rcd at 8497, para. 10
($4,000 forfeiture proposed for licensee’s failure to fully and accurately disclose that prize was access to a concert
rather than access to a VIP section “up close and personal” with performing artist Nelly).
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showing of the film “Spiderman” were awarded as a contest prize.32 The station never broadcast the fact
that the award of the tickets did not guarantee admission to the theater, but it did notify the contest
winner by telephone of that restriction when it awarded him the prize and when it later gave him the
tickets.33 When the winner was unable to attend the “Spiderman” premier due to large crowds, the
station offered him tickets to another movie that night, gave him promotional items, and purchased
tickets for him to see “Spiderman” at a later date.34 However, the Bureau found that the failure of the
station to broadcast that the prize movie tickets did not guarantee admission to the theater was a failure to
broadcast a material term, and despite the station’s efforts to correct its failure, imposed a four-thousand-
dollar ($4,000) forfeiture for ABC’s violation of the Commission’s contest rule.35 We find that the
Licensee’s failure to broadcast the fact that the grand prize was a car lease and only if the winner
qualified for it
– rather than title to the car, as listeners were lead to believe, is more serious than the
violation found in ABC.
2.

Cooney

Does Not Control the Outcome in This Case.

10.
The Licensee continues to contend that Cooney, a Mass Media Bureau letter in which no
forfeiture was imposed, controls the outcome of this case.36 In the NAL, we considered and rejected this
argument.37 In its NAL Response, the Licensee merely restates the arguments that we previously rejected
in the NAL.38 Despite the Licensee’s persistence, we continue to find that Cooney does not control the
outcome in this matter.
11.
In Cooney, the complainant misunderstood the contest term “enter as often as you like.”39
According to the licensee in that case, the term contemplated participation in various segments of the
contest at issue, but actually prohibited duplicate entries (like the complainant’s) from the same listener
for the same music segment. The Mass Media Bureau determined that this exclusion, which could have
been reasonably misunderstood, was a material term of the contest that should have been announced by
the Station. It then determined that the overall circumstances of the case, which included consideration
of the Station’s offer to compensate the complainant and to take steps to assure accuracy in its contests,
warranted an admonition.40 The circumstances in the instant case, however, warrant a forfeiture. Here,
(Continued from previous page)


31 See ABC, Inc., Notice of Apparent Liability for Forfeiture, 18 FCC Rcd 25647, 25650, paras. 9–10 (Enf. Bur.
2003) (forfeiture paid) (ABC).
32 See id. at 25647, para. 2.
33 See id. at 25648, para. 4.
34 See id.
35 See id. at 25650–51, paras. 9–10.
36 See LOI Response at 6–7; NAL Response at 3–6.
37 See NAL, 24 FCC Rcd at 4106–07, paras. 10–11.
38 See NAL Response at 3–6; NAL, 24 FCC Rcd at 4106–07, paras. 10–11.
39 See Cooney, 5 FCC Rcd 7105.
40 See id.
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the Station never aired a complete description of each material term in its over 300 Contest promotions,41
essentially broadcast a false announcement of the grand prize rather than a vague one, failed to broadcast
anything clarifying what it would award, and instead awarded something different than what it
announced.42 In contrast, in Cooney, the Station did announce material terms, except one term was open
to various interpretations, which the Mass Media Bureau determined should have been better defined.43
As discussed in the NAL and below, we find that the violation in the instant case is more serious than the
violation in Cooney, and the degree of departure in this case from the contest rule warrants a stronger
sanction than an admonishment. Accordingly, we continue to reject the Licensee’s comparisons to
Cooney.44
3.

Melody Music

Does Not Compel a Different Result.

12.
Notwithstanding the foregoing, the Licensee argues that, under the principles of Melody
Music, Inc. v. FCC (Melody Music), it should receive, at most, an admonishment for its conduct.45 We
reject this argument. The Licensee’s reliance on Melody Music is misplaced. First, Melody Music
addresses the particular burdens that the Commission must meet in justifying its licensing decisions, not


41 See LOI Response at 3–4; NAL, 24 FCC Rcd at 4106, para. 9.
42 See NAL, 24 FCC Rcd at 4106, para. 9. The Station’s promotional advertisement for the Contest states “Your
choice of a Mercedes Benz Z300W, an Audi TT 2.0 front wheel drive roadster, or a Toyota Prius hybrid, from
Prime Motor Group with no fine print gimmicks.” LOI Response at Exh. 1 (emphasis added). Yet, the
unannounced winner qualifications requirement and the misleading prize description appear to be just the types of
gimmicks that the announcement renounces.
43 Cooney, 5 FCC Rcd at 7105.
44 In addition, to the extent the Licensee’s NAL Response suggests that it took remedial measures that warrant a
reduction in the sanction, we reject such a contention. The NAL Response states that “it is not contending . . . that
corrective action excuses or nullifies a violation of [Commission] rules” while simultaneously noting that “the
necessary remediation in the instant case involves enhanced future vigilance with respect to compliance with the
FCC’s contest rule.” NAL Response at 3, 6. It is well settled that subsequent remedial actions do not excuse or
nullify a licensee’s violation of a Commission rule. See, e.g., Colby-Sawyer College, Forfeiture Order, 26 FCC
Rcd 9302, 9303, para.7 (Media Bur. 2011) (“Corrective action taken to come into compliance with the Rules is
expected, and does not mitigate, much less negate, any prior forfeitures or violations”) (forfeiture paid). We may
consider pre-investigative remedial measures when we determine the sanction to be imposed for a rule violation.
See, e.g., Guy Gannett Publishing Co., Memorandum Opinion and Order, 5 FCC Rcd 7688, 7890, para. 12 (Mass
Media Bur. 1990) (“the Commission generally considers prompt and effective remedial action by a licensee as
mitigative in determining the appropriate sanction level in an enforcement proceeding.”). We do not consider that
point applicable here, however, because any purportedly mitigating measures that the Licensee took occurred after
our investigation commenced. See LOI Response at 2, 6, Exh. 8 (noting the Licensee’s “addressing with Station
personnel the omission of some material terms from the Station’s announcement” and distributing a March 19,
2009, advisory notice regarding “Required Announcements Concerning Station-Sponsored Contests” to
programming and promotions personnel nearly one year after the Contest).
45 See NAL Response at 5.
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its enforcement actions; while some enforcement actions include decisions on whether to grant
applications, this case does not.46 Moreover, as cases following Melody Music have noted, the
requirements of Melody Music do not limit the Commission to previously assessed sanctions where there
are factual distinctions that warrant different treatment, and the Commission has adequately explained
such distinctions.47 Finally, the Commission has broad discretion to consider a variety of factors in
determining an appropriate forfeiture amount, if warranted, when faced with a violation of its rules.48
We note that egregiousness is one of the factors under Section 1.80 of the rules that must be considered
when determining the degree of a sanction.49 With respect to these last two points, we find that we have
properly exercised our discretion and adequately explained that the Licensee’s factual situation was
different from cited precedent due to the egregiousness of the violation.

B.

The Gravity of the Violation Warrants a Forfeiture.

13.
We note that the serious nature of the violation here justifies the forfeiture that we
proposed. In the NAL Response, the Licensee asserts that the violation was “relatively minor” in
nature50 and that “no [C]ontest participant suffered any damages in reliance on his or her
misunderstanding of the rules.”51 These contentions echo the arguments that the Licensee put forward in
its LOI Response.52 As we did in the NAL, we continue to reject this position.53
14.
As described above, the violation in this case was fundamental and serious. The
Licensee failed to accurately describe both the prize and the conditions required to win that prize.54
Omitting or obscuring such a fundamental Contest term as the Contest prize undermines the essence of
the contest rule, which is designed to ensure that listeners are accurately informed of the material terms


46 See Broadcast Consultant’s Corp., Memorandum Opinion and Order, 58 FCC 2d 1290, 1292, para. 6 (1976).
47 See, e.g., Continental Broadcasting, Inc., v. Federal Communications Commission, 439 F.2d 580, 582–83 (D.C.
Cir. 1971) (finding that “the choice of remedies and sanctions is a matter wherein the Commission has broad
discretion” and considering Melody Music not to be on point where close parallels do not exist) (internal quotation
marks, citations, and subsequent history omitted); White Mountain Broadcasting Co., Inc., v. Federal
Communications Commission
, 598 F.2d 274, 278–79 (D.C. Cir. 1978) (upholding Melody Music in a licensing
proceeding but finding that differences between conduct of licensee at issue versus conduct of licensees facing
milder enforcement sanctions were “so ‘obvious’ as to remove the need for explanation”) (internal citations and
subsequent history omitted).
48 See Entercom Wichita License, LLC, Forfeiture Order, 24 FCC Rcd 1270, 1273, para. 8 (Enf. Bur. 2009)
(forfeiture paid) (Entercom Wichita).
49 47 C.F.R. § 1.80.
50 NAL Response at 3.
51 Id. at 6.
52 See LOI Response at 6.
53 See NAL, 24 FCC Rcd 4103, 4106, paras. 10–11.
54 See supra note 42 and accompanying text.
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of the contest. Moreover, in focusing on the listeners’ “misunderstanding of the rules,” the Licensee
appears to misunderstand its obligations. The burden is not on the listener to surmise the nature of the
prize—it is on the Licensee to announce it.55 Indeed, we find the so-called “misunderstandings” of
Station listeners and Contest contestants to be both reasonable and warranted because the Station’s
promotions were fundamentally misleading. In claiming that no harm resulted from such misleading
behavior, the Licensee ignores its basic obligation to prevent the broadcast of false, misleading or
deceptive contest announcements.56 Such a claim also ignores the likelihood that Contest participants,
such as the complainant, may have relied on the announced grand prize, rather than the actual grand
prize, to enter the contest in the first instance and discounts the possibility of damages from such
reliance. Furthermore, the Licensee admits that some of the qualifying contestants complained about the
Station’s misleading advertisements,57 which indicates that they were indeed harmed by the Licensee’s
conduct. Accordingly, we find these contentions unpersuasive, as we have when addressing similar
arguments from other licensees.58
15.
As a result of our review of the Licensee’s response to the NAL, and in view of the
statutory factors and the Forfeiture Policy Statement, we affirm the NAL and issue a forfeiture in the
amount of four thousand dollars ($4,000).59

IV.

ORDERING CLAUSES

16.
Accordingly,

IT IS ORDERED

that, pursuant to Section 503(b) of the Act,60 and
Sections 0.111, 0.311 and 1.80(f)(4) of the Commission's rules,61 Greater Boston Radio, Inc.

IS LIABLE



55 See, e.g., WMJX, Inc., Decision, 85 FCC 2d 251, 269–277, paras. 31–41 (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).
56 See id.
57 See LOI Response at 6.
58 See Service Broadcasting, 24 FCC Rcd at 8497, para. 10; NM Licensing LLC, Notice of Apparent Liability for
Forfeiture, 21 FCC Rcd 7916, 7919–20, para. 9 (Enf. Bur. 2006) (forfeiture paid) (“that it offered compensation to
the participants that were unable to participate due to the alteration in schedule, does not mitigate [the licensee’s]
liability . . . . [A] showing of harm is not necessary to establish a violation [of § 73.1216 of the Commission’s
rules]”); Clear Channel Broadcasting Licenses, Inc., Notice of Apparent Liability for Forfeiture, 21 FCC Rcd 6808,
6810, para. 5 (Enf. Bur. 2006) (holding that with regard to what constitutes a false, misleading or deceptive
announcement, it is enough “if the net impression of the announcement has a tendency to mislead the public”)
(internal quotation marks and citations omitted) (forfeiture paid); Clear Channel Broadcasting Licenses, Inc., Notice
of Apparent Liability for Forfeiture, 21 FCC Rcd 4072, 4074, para. 9 (Enf. Bur. 2006) (“Although Clear Channel
later conducted a second drawing, such remedial action does not absolve it from liability and the proposed forfeiture
penalty”) (forfeiture paid).
59 We caution licensees that future violations of comparable severity may incur higher penalties.
60 See 47 U.S.C. § 503(b).
61 See 47 C.F.R. §§ 0.111, 0.311, 1.80(f)(4).
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FOR A MONETARY FORFEITURE

in the amount of four thousand dollars ($4,000) for willful
violation of Section 73.1216 of the Commission’s rules.62
17.
Payment of the forfeiture shall be made in the manner provided for in Section 1.80 of the
Rules by close of business on or before ten days after the date of the entry of this Order.63 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.64 Greater Boston Radio,
Inc. shall send electronic notification of payment to Judy Lancaster at Judy.Lancaster@fcc.gov, Anjali K.
Singh at Anjali.Singh@fcc.gov, and Jeffrey J. Gee at Jeffrey.Gee@fcc.gov on the date said payment is
made.
18.
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.65 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:
·
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.
·
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.
·
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.
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.
19.
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.,


62 See 47 C.F.R. § 73.1216.
63 47 C.F.R. § 1.80.
64 47 U.S.C. § 504(a).
65 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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Room 1-A625, Washington, D.C. 20554.66 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.
20.

IT IS FURTHER ORDERED

that a copy of this Forfeiture Order shall be sent by First
Class Mail and Certified Mail Return Receipt Requested to Greater Boston Radio, Inc., 35 Braintree Hill
Office Park, Suite 300, Braintree, Massachusetts 02184-8703, and to its counsel, Sally A. Buckman and
David S. Keir, Lerman Senter PLLC, 2000 K Street, NW, Suite 600, Washington, D.C. 20006-1809.
FEDERAL COMMUNICATIONS COMMISSION
Theresa Z. Cavanaugh
Chief, Investigations and Hearings Division
Enforcement Bureau


66 See 47 C.F.R. § 1.1914.
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