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Released: October 14, 2011

Federal Communications Commission

DA 11-1536

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
File No.: EB-11-IH-0734
)

VERMONT TELEPHONE COMPANY, INC.

)
NAL/Acct. No.: 201232080004
)
Participant in Auction No. 86
)
FRN: 0005209374

NOTICE OF APPARENT LIABILITY FOR FORFEITURE

Adopted: October 14, 2011

Released: October 14, 2011

By the Chief, Enforcement Bureau:

I.

INTRODUCTION

1.
In this Notice of Apparent Liability for Forfeiture ("NAL"), we find that Vermont
Telephone Company, Inc. ("VTel"), apparently violated sections 1.17 and 1.65 of the Commission's rules
("Rules")1 by willfully and repeatedly failing to submit accurate revenue information to the Commission
and by failing to maintain the continuing accuracy of its application in connection with its participation in
Auction No. 86.2 Based on our review of the facts and circumstances surrounding this matter, and for the
reasons discussed below, we find that VTel is apparently liable for a forfeiture in the total amount of
$34,000.3

II.

BACKGROUND

2.
In Auction No. 86, a bidder whose attributable average annual gross revenues for the
preceding three years exceeded $15 million, but did not exceed $40 million, was designated as a "small
business" and entitled to receive a 15 percent discount on its winning bid(s).4 Pursuant to section 1.2110
of the Rules, an applicant claiming status as a small business entity in Auction No. 86 was required to
disclose, for each of the three years preceding the auction, the gross revenues of each of the following
entities: (1) the applicant, (2) its affiliates, (3) its controlling interests, (4) the affiliates of its controlling


1 47 C.F.R. 1.17, 1.65.
2 The spectrum associated with licenses auctioned in Auction No. 86 was previously allocated and made available
under the Multipoint Distribution Services ("MDS") and Multichannel Multipoint Distribution Service ("MMDS"),
the predecessor services to Broadband Radio Service ("BRS"). The licenses offered in Auction No. 86 consisted of
the available spectrum in 78 BRS service areas. BRS service areas are BTAs or additional service areas similar to
BTAs adopted by the Commission. See Auction of Broadband Service (BRS) Licenses Scheduled for October 27,
2009, AU Docket No. 09-56 Notice and Filing Requirement, Minimum Up Front Payment, and Other Procedure for
Auction 86, Public Notice, 24 FCC Rcd 8277 (WTB 2009) (Auction No. 86 June 26, 2009 Public Notice).
3 We note that VTel has now fully disclosed all information required under our rules; as a result, this Notice of
Apparent Liability addresses VTel's initial failures to timely submit complete and accurate information.
4 See 47 C.F.R. 1.2110(f)(2)(iii), 27.1218; Auction No. 86 June 26, 2009 Public Notice, 24 FCC Rcd at 8296.

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DA 11-1536

interests, and (5) the entities with which it has an attributable material relationship.5 Successful small
business auction participants were required to provide the required detailed financial information after the
auction closed.
3.
VTel is a family-owned telephone company that began serving rural Vermont in 1890.6
According to its website, VTel is "one of the largest owners of FCC wireless licenses in Vermont, New
Hampshire, and Upstate New York."7 On August 17, 2009, VTel filed an application on FCC Form 175
(commonly referred to as a pre-auction "short-form" application) to participate in Auction No. 86.8
Therein, VTel claimed status as a small business entity and sought a 15 percent bidding credit on any
licenses for which it was the high bidder.9 Auction No. 86 was held from October 27, 2009 to October
30, 2009. VTel was a successful bidder for three BRS licenses.10
4.
On November 20, 2009, VTel filed its post-auction "long-form" application on FCC
Form 601.11 In VTel's Ownership Report, J. Michel Guite was identified as an officer, director, and an
owner of VTel.12 The Ownership Report also identified Walter Hewlett as one of VTel's controlling
interest holders based on his status as an individual major shareholder of the company and his role as
Trustee of the Guite Family Trust, another major shareholder in VTel.13 In its long-form application, as
initially filed, VTel represented that Walter Hewlett had no gross revenues for each of the three years
preceding the auction (2006, 2007, and 2008). Thereafter, staff from the Wireless Telecommunications
Bureau ("WTB"), the bureau responsible for processing VTel's auction-related filings, contacted VTel
and inquired further about its ownership structure. In response, VTel twice amended its long-form
application on February 18 and April 23, 2010 each time affirmatively representing Walter Hewlett's
gross revenues as zero.14
5.
While processing VTel's application materials, WTB staff asked VTel whether Walter
Hewlett was related in any way to the Hewletts of the Hewlett-Packard Corporation family. VTel's
counsel at the time confirmed that Mr. Hewlett was so related. Given that the Hewlett-Packard


5 47 C.F.R. 1.2110(b)(1)(i), 1.2110(b)(3)(iv)(B). See also Order on Reconsideration of the Third Report and
Order
, Fifth Report and Order, and Fourth Further Notice of Proposed Rule Making, FCC 00-274, 15 FCC Rcd
15,293, 15323-27 (2000) (modified by Erratum, DA 00-2475, 15 FCC Rcd 24,501).
6 See http://www.vermontel.com/about.
7 Id.
8 See Form 175, File No. 0003937211 (filed Aug. 17, 2009).
9 Id.
10 See http://wireless.fcc.gov/services/index.htm?job=service_home&id=ebs_brs ("BRS formerly known as the
Multipoint Distribution Service (MDS)/Multichannel Multipoint Distribution Service (MMDS), is a commercial
service. In the past, it was generally used for the transmission of data and video programming to subscribers using
high-powered systems, also known as wireless cable. However, over the years, the uses have evolved to include
digital two-way systems capable of providing high-speed, high-capacity broadband service, including two-way
Internet service via cellularized communication systems. Such services provide consumers integrated access to
voice, high-speed data, video-on-demand, and interactive delivery services from a wireless device.").
11 See Form 601, File No. 0004040603 (filed Nov. 20, 2009).
12 See Form 602, File No. 0003937211 (filed Mar. 31, 2009).
13 See id. VTel submitted an additional Ownership Report after the close of Auction No. 86. See Form 602, File
No. 0004129864 (filed Feb. 18, 2010).
14 See Amended Form 601, File No. 0004040603 (filed Feb. 18, 2010); Amended Form 601, File No. 0004040603
(filed Apr. 23, 2010).
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Federal Communications Commission

DA 11-1536

Corporation is a large, multi-national company with considerable revenues, WTB staff requested that
VTel verify the extent of Mr. Hewlett's revenues during the relevant three-year period. On August 9,
2010, VTel filed a third amendment to its long-form application, disclosing for the first time to the
Commission that Mr. Hewlett's had substantial gross revenues for each of the three relevant years.15
6.
The disclosure of Mr. Hewlett's revenues during the relevant three-year period did not
adversely affect VTel's entitlement to a small business bidding credit.16 Accordingly, on May 19, 2011,
WTB granted VTel's long-form application, as amended. 17 WTB then referred the matter of VTel's
conduct in Auction No. 86 to the Enforcement Bureau ("EB") for investigation. On May 26, 2011, EB
commenced an investigation by sending a letter of inquiry ("LOI") to VTel requesting information and
documents about Mr. Hewlett's gross revenues.18 VTel filed its response on June 27, 2011.19

III.

DISCUSSION

7.
Under section 503(b)(1) of the Act, any person who is determined by the Commission to
have willfully or repeatedly failed to comply with any provision of the Act or any rule, regulation, or
order issued by the Commission shall be liable to the United States for a forfeiture penalty.20 Section
312(f)(1) of the Act defines willful as "the conscious and deliberate commission or omission of [any] act,
irrespective of any intent to violate" the law.21 The legislative history to section 312(f)(1) of the Act
clarifies that this definition of willful applies to both sections 312 and 503(b) of the Act22 and the
Commission has so interpreted the term in the section 503(b) context.23 The Commission may also assess
a forfeiture for violations that are merely repeated, and not willful.24 "Repeated" means that the act was
committed or omitted more than once, or lasts more than one day.25 To impose such a forfeiture penalty,


15 See Amended Form 601, File No. 0004040603 (filed Aug. 9, 2010). VTel subsequently amended its long form
two more times and further refined Mr. Hewlett's gross revenues for 2007 and 2008.
16 Once Mr. Hewlett's gross revenues were included, VTel's total average gross revenues were $28,369,000,
$28,925,000 and $29,260,000 for 2006, 2007, and 2008, respectively. See Amended Form 601, File No.
0004040603 (filed Mar. 30, 2011). Thus, VTel's average revenues for the reported years were $28,851,333.33,
which was still under the $40,000,000 maximum to be eligible for the small business bidding credit.
17 See Wireless Telecommunications Bureau Grants Broadband Radio Service Licenses, Report No. AUC-86
(Auction 86), Public Notice, 26 FCC Rcd 6990 (WTB 2011).
18 See Letter from Gary Schonman, Special Counsel, Investigations & Hearings Division, Enforcement Bureau,
FCC, to Dr. J. Michael Guite, Chairman, Vermont Telephone Company, Inc., dated May 26, 2011 ("LOI").
19 See Letter from Bennett L. Ross, Esq., Wiley Rein, Counsel for Vermont Telephone Company, to Pam Slipakoff,
Attorney Advisor, Investigations & Hearings Division, Enforcement Bureau, FCC, dated June 27, 2011 ("LOI
Response").
20 47 U.S.C. 503(b)(1)(B); 47 C.F.R. 1.80(a)(1); see also 47 U.S.C. 503(b)(1)(D) (forfeitures for violation of
14 U.S.C. 1464).
21 47 U.S.C. 312(f)(1).
22 H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).
23 See, e.g., Application for Review of Southern California Broadcasting Co., Memorandum Opinion and Order, 6
FCC Rcd 4387, 4388 (1991) ("Southern California Broadcasting Co.").
24 See, e.g., Callais Cablevision, Inc., Grand Isle, Louisiana, Notice of Apparent Liability for Monetary Forfeiture,
16 FCC Rcd 1359, 1362, 10 (2001) ("Callais Cablevision") (issuing a Notice of Apparent Liability for, inter alia,
a cable television operator's repeated signal leakage).
25 Southern California Broadcasting Co., 6 FCC Rcd at 4388, 5; Callais Cablevision, Inc., 16 FCC Rcd at 1362,
9.
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DA 11-1536

the Commission must first issue a notice of apparent liability and the person against whom the notice has
been issued must have an opportunity to show, in writing, why no such forfeiture penalty should be
imposed.26 The Commission will then issue a forfeiture if it finds, based on the evidence, that the person
has violated the Act, a Rule, or a Commission Order.27
8.
Section 1.17 of the Rules states that no person may provide, in any written statement of
fact, "material factual information that is incorrect or omit material information that is necessary to
prevent any material factual statement that is made from being incorrect or misleading without a
reasonable basis for believing that any such material factual statement is correct and not misleading."28 In
2003, the Commission expanded the scope of section 1.17 of the Rules to include written statements that
are made without a reasonable basis for believing the statement is correct and not misleading.29 At that
time, the Commission explained that this requirement was intended to more clearly articulate the
obligations of persons dealing with the Commission, ensure that they exercise due diligence in preparing
written submissions, and enhance the effectiveness of the Commission's enforcement efforts.30 Thus,
even in the absence of an intent to deceive, a false statement provided without a reasonable basis for
believing that the statement is correct and not misleading constitutes an actionable violation of section
1.17 of the Rules.31
9.
In its LOI Response, VTel maintains that it had a reasonable basis for believing that Mr.
Hewlett had no reportable gross revenues during the relevant three year period because it relied on advice
of counsel.32 Specifically, VTel contends that it was advised by counsel that the FCC "was seeking
information regarding relationships with other entities that may be guiding or directly or indirectly
controlling VTel to determine if VTel was actually representing larger entities e.g., AT&T, Comcast, a
private equity or other investment fund, or a telecommunications manufacturer in seeking a bidding
credit in Auction No. 86."33 VTel also argues that no unjust enrichment occurred because Mr. Hewlett's
revenues, even after they were disclosed, had no adverse impact on VTel's entitlement to a small business
bidding credit.34 These arguments lack merit. First, the Commission's designated entity rules require
applicants to disclose revenues from all sources, without qualification, during the relevant time frame.35
There are no qualitative exceptions of the kind on which VTel claims to have relied. Second, WTB
issued a pre- and post-auction Public Notice for Auction No. 86 setting forth the information that


26 47 U.S.C. 503(b); 47 C.F.R. 1.80(f).
27 See, e.g., SBC Communications, Inc., Apparent Liability for Forfeiture, Forfeiture Order, 17 FCC Rcd 7589, 7591,
4 (2002) (forfeiture paid).
28 47 C.F.R. 1.17(a)(2).
29 See Amendment of Section 1.17 of the Commission's Rules Concerning Truthful Statements to the Commission,
Report and Order, 18 FCC Rcd 4016, 4021 (2003), recon. denied, Memorandum Opinion and Order, 19 FCC Rcd
5790, further recon. denied, Memorandum Opinion and Order, 20 FCC Rcd 1250 (2004) ("Amendment of Section
1.17
").
30 Id.
31 See id. at 4017 (stating that the revision to Section 1.17 of the Rules is intended to "prohibit incorrect statements
of omissions that are the results of negligence, as well as an intent to deceive").
32 See LOI Response at 2.
33 Id.
34 See Id. at 1.
35 47 C.F.R. 1.2110(b).
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Federal Communications Commission

DA 11-1536

applicants were required to disclose in support of a claim of designated entity status.36 Thus, VTel had
additional advance and ample notice, beyond the Commission's rules, of the auction-related reporting
requirements. Finally, VTel provided revenue information for Four Winds Farms, Inc. (Four Winds) in
its initial long-form application.37 Four Winds' average gross revenues for the reported three year time
period was $5,900.38 In addition, it appears that Four Winds does not appear to have a relationship with
the other entities identified on the VTel long-form application that may be guiding, or directly or
indirectly controlling VTel. Therefore, it appears that VTel did not consistently apply the advice it says it
received from its counsel. By having provided information about Four Winds, VTel essentially
undermines its argument about the advice it received from counsel and its understanding of what our rules
required.
10.
As the Commission has stated, parties must "use due diligence in providing information
that is correct and not misleading to the Commission, including taking appropriate affirmative steps to
determine the truthfulness of what is being submitted.39 A failure to exercise such reasonable diligence
would mean that the party did not have a reasonable basis for believing in the truthfulness of the
information."40 In this case, rather than failing to mention Mr. Hewlett at all, VTel repeatedly included
Mr. Hewlett and listed his revenues as zero, even after several inquiries by WTB staff. The statements
provided by VTel were false, and VTel had no reasonable basis for believing that the statements were
correct and not misleading. We conclude, therefore, that VTel made these statements in apparent willful
and repeated violation of section 1.17(a)(1) of the Commission's Rules.41
11.
In addition, section 1.65 of the Rules provides that "[e]ach applicant is responsible for the
continuing accuracy and completeness of information furnished in a pending application or in
Commission proceedings involving a pending application."42 Section 1.65 also requires that applicants
amend their applications within 30 days, unless good cause is shown, of any substantial change in
information provided to the Commission.43
12.
In the instant case, VTel failed to maintain the continuing accuracy of its pending long-
form application, in apparent willful and repeated violation of section 1.65. VTel initially filed its long-
form application in November 2009. In its long-form application, VTel affirmatively represented to the
Commission that Mr. Hewlett had no gross revenues for each of the three relevant years.44 In addition,
VTel subsequently filed two amendments to its long-form application in which it provided identical gross
revenue information for Mr. Hewlett that was later revealed to be inaccurate.45 In fact, it was not until the


36 See Auction No. 86 June 26, 2009 Public Notice, 25 FCC Rcd 8277, 8297-99, 8323-24; Auction of Broadband
Radio Service Licenses Closes Winning Bidder Announced for Auction 86, Public Notice, 24 FCC Rcd 13572,
Attachment E (WTB 2009)
37 See Form 601, File No. 0004040603 (filed Nov. 20, 2009).
38 See id.
39 See Cricket Communications, Inc., Order and Notice of Apparent Liability for Forfeiture, 26 FCC Rcd 989, 991
(Enf. Bur 2011) ("Cricket Communications")
40 Amendment of Section 1.17, 18 FCC Rcd at 4021; Cricket Communications, Inc., 26 FCC Rcd at 991.
41 47 C.F.R. 1.17(a)(1); See, e.g Cricket Communications, Inc., 26 FCC Rcd at 992.
42 47 C.F.R. 1.65(a).
43 See 47 C.F.R. 1.65.
44 See Form 601, File No. 0004040603 (filed Nov. 20, 2009).
45See Amended Form 601, File No. 0004040603 (filed Feb. 18, 2010); Amended Form 601, File No. 0004040603
(filed Apr. 23, 2010).
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Commission staff questioned the veracity of the information because of Mr. Hewlett's familial relations
that VTel finally disclosed the extent of Mr. Hewlett's gross revenues, almost a full year after the filing its
long-form application. VTel was, at all relevant times, required under section 1.65 to maintain the
accuracy of the information it provided to the Commission about the extent of Mr. Hewlett's revenues,
and EB's investigation reveals that on no fewer than three separate and distinct occasions, VTel failed to
do so in its long-form application.46 VTel's derelictions in this matter are significant because the
Commission relied on the information provided by VTel to assess the merits of the company's claimed
entitlement to a bidding credit.47 The fact that VTel remained qualified to receive the bidding credit after
subsequently attributing Mr. Hewlett's revenues to VTel is of no consequence to EB's determination here
that VTel apparently willfully and repeatedly violated section 1.65 of the Rules. Indeed, the relevant
issue is that Mr. Hewlett's revenues could have prevented VTel from obtaining a bidding credit, which in
turn, could have impacted the Auction No. 86 results. Thus, the Commission was unable to determine
both the actual amount owed by VTel, and whether VTel was still entitled to the small business bidding
credit, until after Mr. Hewlett's full income was disclosed.
13.
In determining the amount of a forfeiture penalty, section 503(b)(2)(E) of the Act48 and
section 1.80(a)(4) of the Rules direct the Commission to take into account "the nature, circumstances,
extent, and gravity of the violation . . . and the degree of culpability, any history of prior offenses, ability
to pay, and such other matters as justice may require."49 Consistent with Commission precedent, we find
that a base forfeiture in the amount of $25,000 is appropriate for VTel's violation of section 1.17 of the
Rules.50 In addition, the Commission's Forfeiture Policy Statement and implementing Rules prescribe a
base forfeiture of $3,000 for each failure to file required forms or information.51 Accordingly, we find
that the base forfeiture of $3,000 is appropriate for each one of the three Form 601s that VTel submitted
listing Mr. Hewlett's gross revenues as zero. Therefore, we conclude that a proposed base forfeiture of
$9,000 against VTel is warranted for VTel's repeated failure to file required forms or information. Thus,
based on the facts and circumstances presented, we conclude that a proposed forfeiture of $34,000 against
VTel is warranted.


46 See Form 601, File No. 0004040603 (filed Nov. 20, 2009); Amended Form 601; Amended Form 601, File No.
0004040603 (filed Feb. 18, 2010); and Amended Form 601, File No. 0004040603 (filed Apr. 23, 2010).
47 The Commission's small business bidding credits are designed to enhance access to telecommunications services
by encouraging broad participation in the provision of spectrum-based services and ensuring that spectrum-based
services are available to a wide range of consumers. See Implementation of Section 309(j) of the Communications
Act - Competitive Bidding, Second Report and Order, PP Docket No. 93-253, 9 FCC Rcd 2348, 2350 Para. 6
(1993). They also implement Congress' directive to "promot[e] economic opportunity and competition and ensur[e]
that new and innovative technologies are readily available to the American people by avoiding excessive
concentration of licenses and by disseminating licenses among a wide variety of applicants, including small
businesses..." See 47 U.S.C. Sec. 309(j)(3)(B).
48 47 U.S.C. 503(b)(2)(E).
49 47 C.F.R. 1.80(a)(4).
50 See, e.g Cricket Communications, Inc., 26 FCC Rcd at 993-94 (proposing a $20,000 forfeiture for Cricket's
failure to file the correct construction date for station WQJE535. The proposed forfeiture reflects a downward
adjustment from $25,000 as a result of Cricket's voluntary disclosures to Commission staff); Cardinal Broadband
LLC,
Notice of Apparent Liability for Forfeiture, 23 FCC Rcd 12233 (Enf. Bur. 2008) (proposing a $25,000
forfeiture against an interconnected VoIP provider and common carrier for its violation of 1.17(a)(2) of the
Commission's Rules).
51 See 47 C.F.R. 1.80; Forfeiture Policy Statement, 12 FCC Rcd 17087, 17113 (1997).
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DA 11-1536

IV.

ORDERING CLAUSES

14.
Accordingly,

IT IS ORDERED

that, pursuant to section 503(b) of the Communications
Act of 1934, as amended, 47 U.S.C. 503(b), and section 1.80 of the Commission's rules, 47 C.F.R.
1.80, that Vermont Telephone Company, Inc. is hereby

NOTIFIED

of its

APPARENT LIABILITY
FOR A FORFEITURE

in the amount of $34,000 for willfully and repeatedly violating sections 1.17 and
1.65 of the Commission's Rules.52
15.

IT IS FURTHER ORDERED THAT

, pursuant to section 1.80 of the Commission's
Rules,53 within thirty days of the release date of this Notice of Apparent Liability for Forfeiture, VTel

SHALL PAY

the full amount of the proposed forfeiture or

SHALL FILE

a written statement seeking
reduction or cancellation of the proposed forfeiture.
16.
Payment of the forfeiture must be made by check or similar instrument, payable to the
order of the Federal Communications Commission. The payment must include the NAL/Acct. No. and
FRN referenced above. Payment by check or money order may be mailed to Federal Communications
Commission, P.O. Box 979088, St. Louis, MO 63197-9000. Payment by overnight mail may be sent to
U.S. Bank Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
63101. Payment by wire transfer may be made to ABA Number 021030004, receiving bank Federal
Reserve Bank of New York, and account number 27000001. For payment by credit card, an FCC Form
159 (Remittance Advice) must be submitted. When completing the FCC Form 159, enter the
NAL/Account number in block number 23A (call sign/other ID), and enter the letters "FORF" in block
number 24A (payment type code). VTel will also send electronic notification within forty-eight (48)
hours of the date said payment is made to Terry.Cavanaugh@fcc.gov, Gary.Schonman@fcc.gov and
Pam.Slipakoff@fcc.gov.
17.
The written statement seeking reduction or cancellation of the proposed forfeitures, if
any, must include a detailed factual statement supported by appropriate documentation and affidavits
pursuant to sections 1.80(f)(3) and 1.16 of the Commission's rules.54 The written statement must be
mailed to Theresa Z. Cavanaugh, Acting Chief, Investigations and Hearings Division, Enforcement
Bureau, Federal Communications Commission, 445 12th Street, S.W., Room 4-C330, Washington, D.C.
20554 and must include the NAL/Acct. No. referenced above. The written statement should also be
emailed to Terry Cavanaugh at Terry.Cavanaugh@fcc.gov, Gary Schonman at Gary.Schonman@fcc.gov
and Pam Slipakoff at Pam.Slipakoff@fcc.gov.
18.
The Commission will not consider reducing or canceling a forfeiture in response to a
claim of inability to pay unless the petitioner submits: (1) federal tax returns for the most recent three-
year period; (2) financial statements prepared according to generally accepted accounting practices
(GAAP); or (3) some other reliable and objective documentation that accurately reflects the petitioner's
current financial status. Any claim of inability to pay must specifically identify the basis for the claim by
reference to the financial documentation submitted.
19.
Requests for payment of the full amount of this Notice of Apparent Liability for
Forfeiture under an installment plan should be sent to: Chief Financial Officer -- Financial Operations,


52 See 47 C.F.R. 1.17, 1.65(a).
53 See 47 C.F.R. 1.1914.
54 See 47 C.F.R. 1.80(f)(3), 1.16.
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DA 11-1536

Federal Communications Commission, 445 12th Street, S.W., Room 1-A625, Washington, D.C. 20554.55
For answers to questions regarding payment procedures, please contact the Financial Operations Group
Help Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov.
20.

IT IS FURTHER ORDERED

that a copy of this Notice of Apparent Liability for
Forfeiture shall be sent by certified mail, return receipt requested, to counsel for VTel: Bennett L. Ross,
Esq., Wiley Rein LLP., 1776 K Street, N.W., Washington, D.C. 20006.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau


55 See 47 C.F.R. 1.1914.
8

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