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Federal Communications Commission DA 18-482
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Digital Outdoor, LLC d/b/a Lightking Outdoor
)
)
)
)
)
File No.:  EB-SED-17-00024680
Acct. No.:  201832100014
FRN:  0027515089
ORDER
Adopted:  May 18, 2018 Released:  May 18, 2018
By the Deputy Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission has 
entered into a Consent Decree to resolve its investigation into whether Digital Outdoor, LLC d/b/a 
Lightking Outdoor (Lightking) marketed LED signs used in digital billboards and other commercial and 
industrial applications, without the required labeling and user manual disclosures in violation of the 
Commission’s rules.  These rules ensure that radio-frequency devices are properly labeled, and that the 
user manual for the devices inform consumers that such devices have been tested for compliance under 
the Commission’s technical rules because those devices could easily cause interference if they do not 
conform to the Commission’s rules.  To settle this matter, Lightking admits that it marketed LED signs 
without the required labeling and user manual disclosures, will implement a compliance plan, and will 
pay a $15,000 civil penalty. 
2. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
referenced investigation regarding Ligktking’s compliance with the labeling and user manual disclosure 
rules in effect at the time of the violation, Section 302(b) of the Communications Act of 1934, as 
amended (Act)
1
, and Sections 2.803, 15.19, 15.21, and 15.105 of the Commission’s rules.
2
3. In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of Lightking’s basic qualifications to hold or obtain any Commission license or 
authorization.
3
4. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act,
4
 and the 
authority delegated by Sections 0.111 and 0.311 of the Commission’s rules,
5
 the attached Consent Decree 
IS ADOPTED and its terms incorporated by reference.
5. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED.
1
 47 U.S.C. § 302a(b).
2
 47 CFR §§ 2.803, 15.19, 15.21, 15.105 (2017).  Some of the rules in effect at the time the violations occurred were 
subsequently amended.  The new rules became effective on November 2, 2017.  See Amendment of Parts 0, 1, 2, 15, 
and 18 of the Commission’s Rules regarding Authorization of Radiofrequency Equipment, Report and Order, 32 
FCC Rcd 8746 (July 2017).
3
 See 47 CFR § 1.93(b).
4
 47 U.S.C. § 154(i).
5
 47 CFR §§ 0.111, 0.311.
Federal Communications Commission DA 18-482
2
6. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Timur Colak, Managing Member 
and President, Digital Outdoor, LLC d/b/a Lightking Outdoor, 1551 NW 93
rd
 Avenue, Doral, Florida 
33172, and to Edward A. Maldonado, Esq., Maldonado Law Group, 2850 Douglas Road, Suite 303, Coral 
Gables, FL 33134.
FEDERAL COMMUNICATIONS COMMISSION
Christopher L. Killion
Deputy Chief
Enforcement Bureau
Federal Communications Commission DA 18-482
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Digital Outdoor, LLC d/b/a Lightking Outdoor
)
)
)
)
)
File No.:  EB-SED-17-00024680
Acct. No.:  201832100014
FRN:  0027515089
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Digital 
Outdoor, LLC d/b/a Lightking Outdoor (Lightking), by their authorized representatives, hereby enter into 
this Consent Decree for the purpose of terminating the Enforcement Bureau’s investigation into whether 
Lightking violated Section 302(b) of the Communications Act of 1934, as amended (Act),
1
 and Sections 
2.803, 15.19, 15.21, and 15.105 of the Commission’s rules.
2
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended.
3
(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(d) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.
(e) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Lightking is 
subject by virtue of its business activities, including but not limited to the 
Equipment Marketing Rules.
(f) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 13.
(g) “Covered Employees” means all employees and agents of Lightking who perform, 
or supervise, oversee, or manage the performance of, duties that relate to 
Lightking’s responsibilities under the Communications Laws, including the 
Equipment Marketing Rules.
(h) “Effective Date” means the date by which both the Bureau and Lightking have 
signed the Consent Decree.
1
 47 U.S.C. § 302a(b).
2
 47 CFR §§ 2.803, 15.19, 15.21, 15.105.  Some of the rules in effect at the time the violations occurred were 
subsequently amended and became effective on November 2, 2017.  See Amendment of Parts 0, 1, 2, 15, and 18 of 
the Commission’s Rules regarding Authorization of Radiofrequency Equipment, Report and Order, 32 FCC Rcd 
8746 (July 2017) (Equipment Authorization Order).  This settlement resolves the rule violations listed in para. 1 of 
this Consent Decree and sets forth obligations for compliance with the current rules.
3
 47 U.S.C. § 151 et seq.
Federal Communications Commission DA 18-482
2
(i) “Equipment Marketing Rules” means Section 302(b) of the Act;
4
 Sections 2.803, 
2.1077, 15.19, 15.21, 15.105 of the Commission’s rules;
5
 and other provisions of the 
Act, the Rules, and Commission orders related to the marketing of radio frequency 
devices.
(j) “Investigation” means the investigation commenced by the Bureau’s July 17, 2017 
Letter of Inquiry regarding whether Lightking violated the Equipment Marketing 
Rules.
6
(k) “Lightking” or “Company” means “Digital Outdoor, LLC d/b/a Lightking Outdoor” 
and its affiliates, subsidiaries, predecessors-in-interest, and successors-in-interest.
(l) “Operating Procedures” means the standard internal operating procedures and 
compliance policies established by Lightking to implement the Compliance Plan.
(m) “Parties” means Lightking and the Bureau, each of which is a “Party.”
(n) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
II. BACKGROUND
3. Section 302 of the Act authorizes the Commission to promulgate reasonable regulations 
to minimize harmful interference by equipment that emits radio frequency energy.
7
  Specifically, 
Section 302(b) of the Act provides that “[n]o person shall manufacture, import, sell, offer for sale, or ship 
devices or home electronic equipment and systems, or use devices, which fail to comply with regulations 
promulgated pursuant to this section.”
8
  The purpose of Section 302 of the Act is to ensure that radio 
transmitters and other electronic devices meet certain standards to control interference before they reach 
the market.
4. The Commission carries out its responsibilities under Section 302 of the Act in two ways.  
First, the Commission establishes technical requirements for transmitters and other equipment to 
minimize their potential for causing interference to authorized radio services.  Second, the Commission 
administers an equipment authorization program to ensure that equipment reaching the market in the 
United States complies with the technical and administrative requirements set forth in the Rules.  The 
equipment authorization program requires, among other things, that radio frequency devices must be 
tested for compliance with the applicable technical requirements prior to marketing.
9
  In that regard, 
Section 2.803(b) of the Rules prohibits the marketing of radio frequency devices unless the device has 
first been properly authorized, identified, and labeled in accordance with the Rules, with limited 
exceptions.
10
4
 Id. § 302a(b).
5
 47 CFR §§ 2.803, 2.1077, 15.19 (2018); id. §§ 2.803, 15.19, 15.21, 15.105 (2017).
6
 See Letter from Aspasia A. Paroutsas, Chief, Spectrum Enforcement Division, FCC Enforcement Bureau, to Timur 
Colak, Managing Member and President, Digital Outdoor, LLC d/b/a Lightking Outdoor (July 17, 2017); Letter 
from Aspasia A. Paroutsas, Chief, Spectrum Enforcement Division, FCC Enforcement Bureau, to Timur Colak, 
Managing Member and President, Digital Outdoor, LLC d/b/a Lightking Outdoor (July 21, 2017) (LOI) (both on file 
in EB-SED-17-00024680).
7
 47 U.S.C. § 302a.
8
 Id. § 302a(b).
9
 The term “marketing” is defined in the Rules and includes the “sale or lease, or offering for sale or lease, including 
advertising for sale or lease, or importation, shipment, or distribution for the purpose of selling or leasing or offering 
for sale or lease.”  47 CFR § 2.803(a).
10
 See id. §§ 2.803(b), (c).
Federal Communications Commission DA 18-482
3
5. Lightking is a privately-held limited liability company that advertises, imports, and sells 
LED display signs.  On July 17, 2017, after reviewing a complaint, the Bureau’s Spectrum Enforcement 
Division issued a Letter of Inquiry (LOI) to Lightking, directing it to submit a sworn written response to a 
series of questions relating to its marketing of LED signs in the United States.
11
  The Investigation 
revealed that Lightking violated the Equipment Marketing Rules by marketing LED signs without the 
required equipment labeling and user manual disclosures.
12
  After receiving the LOI, Lightking brought 
its LED signs into compliance with the Commission’s Equipment Marketing Rules and began marketing 
the equipment with the proper labels and user manual disclosures.  The Company achieved compliance 
with the relevant Equipment Marketing Rules in March 2018 for the LED signs at issue.
13 
6. The Bureau and Lightking negotiated the following terms and conditions of settlement 
and hereby enter into this Consent Decree as provided herein.
III. TERMS OF AGREEMENT
7. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.
8. Jurisdiction.  Lightking agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
9. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.  
10. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation.  In consideration for the termination of the Investigation, Lightking agrees to 
the terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the absence of 
new material evidence, it will not use the facts developed in the Investigation through the Effective Date, 
or the existence of this Consent Decree, to institute, on its own motion, any new proceeding, formal or 
informal, or take any action on its own motion against Lightking concerning the matters that were the 
subject of the Investigation.  The Bureau also agrees that, in the absence of new material evidence, it will 
not use the facts developed in the Investigation through the Effective Date, or the existence of this 
Consent Decree, to institute on its own motion any proceeding, formal or informal, or to set for hearing 
the question of Lightking’s basic qualifications to be a Commission licensee or hold Commission licenses 
or authorizations.
14
11
 See supra note 6.
12
 See Letter and attachments from Timur Colak, Managing Member and President, Digital Outdoor, LLC d/b/a 
Lightking Outdoor, to Aspasia Paroutsas, Chief, Spectrum Enforcement Division, FCC Enforcement Bureau (Aug. 
15, 2017) (LOI Response); Letter from Edward Maldonado, Counsel to Lightking, to Aspasia Paroutsas, Chief, 
Spectrum Enforcement Division, FCC Enforcement Bureau, (Aug. 17, 2017) (Supplemental LOI Response); Letter 
and attachments from Timur Colak, Managing Member and President, Digital Outdoor, LLC d/b/a Lightking 
Outdoor to Kathy Harvey, Spectrum Enforcement Division, FCC Enforcement Bureau (Mar. 16, 2018) (Second 
Supplemental LOI Response); E-mail and attachment from Edward Maldonado, Counsel to Lightking, to Kathy 
Harvey, Spectrum Enforcement Division, FCC Enforcement Bureau (Mar. 27, 2018, 16:35 ET) (Third Supplemental 
LOI Response); E-mail and attachment from Edward Maldonado, Counsel to Lightking, to Kathy Harvey, Spectrum 
Enforcement Division, FCC Enforcement Bureau (Apr. 13, 2018, 12:28 ET) (Fourth Supplemental LOI Response); 
E-mail and attachment from Edward Maldonado, Counsel to Lightking, to Kathy Harvey, Spectrum Enforcement 
Division, FCC Enforcement Bureau (Apr. 13, 2018, 12:28 ET) (Fifth Supplemental LOI Response) (all on file in 
EB-SED-17-00024680). 
13
 47 CFR §§ 2.803, 15.19, 15.21, 15.105.
14
 See 47 CFR 1.93(b).
Federal Communications Commission DA 18-482
4
11. Admission of Liability.  Lightking admits for the purpose of this Consent Decree and for 
Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 10 herein, 
that its actions described in paragraph 5, herein, violated the Equipment Marketing Rules in effect during 
the Investigation.
12. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, 
Lightking shall designate a senior corporate manager with the requisite corporate and organizational 
authority to serve as a Compliance Officer and to discharge the duties set forth below.  The person 
designated as the Compliance Officer shall be responsible for developing, implementing, and 
administering the Compliance Plan and ensuring that Lightking complies with the terms and conditions of 
the Compliance Plan and this Consent Decree.   In addition to the general knowledge of the 
Communications Laws necessary to discharge his or her duties under this Consent Decree, the 
Compliance Officer shall have specific knowledge of the Equipment Marketing Rules prior to assuming 
his/her duties.
13. Compliance Plan.  For purposes of settling the matters set forth herein, Lightking agrees 
that it shall, within sixty (60) calendar days after the Effective Date, develop and implement a 
Compliance Plan designed to ensure future compliance with the Communications Laws and with the 
terms and conditions of this Consent Decree.  With respect to the Equipment Marketing Rules, Lightking 
will implement, at a minimum, the following procedures:
(a) Operating Procedures.  Within thirty (30) calendar days after the Effective Date, 
Lightking shall establish Operating Procedures that all Covered Employees must 
follow to help ensure Lightking’s compliance with the Equipment Marketing Rules.  
Lightking’s Operating Procedures shall include internal procedures and policies 
specifically designed to ensure that all radio frequency devices to be marketed by 
Lightking are properly authorized and compliant with the applicable technical and 
administrative standards and requirements prior to the initiation of marketing.
15
  
Lightking shall also develop a Compliance Checklist that describes the steps that a 
Covered Employee must follow to ensure compliance with the Equipment 
Marketing Rules.
(b) Compliance Manual.  Within sixty (60) calendar days after the Effective Date, the 
Compliance Officer shall develop and distribute a Compliance Manual to all 
Covered Employees.  The Compliance Manual shall explain the Equipment 
Marketing Rules and set forth the Operating Procedures that Covered Employees 
shall follow to help ensure Lightking’s compliance with the Equipment Marketing 
Rules.  Lightking shall periodically review and revise the Compliance Manual as 
necessary to ensure that the information set forth therein remains current and 
accurate.  Lightking shall distribute any revisions to the Compliance Manual 
promptly to all Covered Employees.
(c) Compliance Training Program.  Lightking shall establish and implement a 
Compliance Training Program in compliance with the Equipment Marketing Rules 
and the Operating Procedures.  As part of the Compliance Training Program, 
Covered Employees shall be advised of Lightking’s obligation to report any 
noncompliance with the Equipment Marketing Rules under paragraph 14 of this 
Consent Decree and shall be instructed on how to disclose noncompliance to the 
Compliance Officer.  All Covered Employees shall be trained pursuant to the 
Compliance Training Program within sixty (60) calendar days after the Effective 
Date, except that any person who becomes a Covered Employee at any time after the 
initial Compliance Training Program shall be trained within thirty (30) calendar 
15
 See supra note 9 and accompanying text.
Federal Communications Commission DA 18-482
5
days after the date such person becomes a Covered Employee.  Lightking shall 
repeat compliance training on an annual basis, and shall periodically review and 
revise the Compliance Training Program as necessary to ensure that it remains 
current and complete and to enhance its effectiveness.
14. Reporting Noncompliance.  Lightking shall report any noncompliance with the 
Equipment Marketing Rules and with the terms and conditions of this Consent Decree within fifteen (15) 
calendar days after discovery of such noncompliance.  Such reports shall include a detailed explanation 
of:  (i) each instance of noncompliance; (ii) the steps that Lightking has taken or will take to remedy such 
noncompliance; (iii) the schedule on which such remedial actions will be taken; and (iv) the steps that 
Lightking has taken or will take to prevent the recurrence of any such noncompliance.  All reports of 
noncompliance shall be submitted to Chief, Spectrum Enforcement Division, Enforcement Bureau, 
Federal Communications Commission, 445 12th Street, SW, Rm. 3-C366, Washington, DC 20554, with a 
copy submitted electronically to Kathy Harvey at Kathy.Harvey@fcc.gov.
15. Compliance Reports.  Lightking shall file compliance reports with the Commission 
ninety (90) calendar days after the Effective Date, twelve (12) months after the Effective Date, twenty-
four (24) months after the Effective Date, and thirty-six (36) months after the Effective Date.  
(a) Each Compliance Report shall include a detailed description of Lightking’s efforts 
during the relevant period to comply with the terms and conditions of this Consent 
Decree and the Equipment Marketing Rules.  In addition, each Compliance Report 
shall include a certification by the Compliance Officer, as an agent of and on behalf 
of Lightking, stating that the Compliance Officer has personal knowledge that 
Lightking:  (i) has established and implemented the Compliance Plan; (ii) has 
utilized the Operating Procedures since the implementation of the Compliance Plan; 
and (iii) is not aware of any instances of noncompliance with the terms and 
conditions of this Consent Decree, including the reporting obligations set forth in 
paragraph 14 of this Consent Decree.
(b) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and shall comply with Section 1.16 of the 
Rules and be subscribed to as true under penalty of perjury in substantially the form 
set forth therein.
16
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Lightking, shall provide the Commission 
with a detailed explanation of the reason(s) why and describe fully:  (i) each 
instance of noncompliance; (ii) the steps that Lightking has taken or will take to 
remedy such noncompliance, including the schedule on which proposed remedial 
actions will be taken; and (iii) the steps that Lightking has taken or will take to 
prevent the recurrence of any such noncompliance, including the schedule on which 
such preventive action will be taken.
(d) All Compliance Reports shall be submitted to Chief, Spectrum Enforcement 
Division, Enforcement Bureau, Federal Communications Commission, 445 12th 
Street, SW, Rm. 3-C366, Washington, DC 20554, with a copy submitted 
electronically to Kathy Harvey at Kathy.Harvey@fcc.gov and to Leslie Barnes at 
Leslie.Barnes@fcc.gov.
16. Termination Date.  Unless stated otherwise, the requirements set forth in paragraphs 12 
through 15 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
16
 47 CFR § 1.16.
Federal Communications Commission DA 18-482
6
17. Civil Penalty.  Lightking will pay a civil penalty to the United States Treasury in the 
amount of fifteen thousand dollars ($15,000) within thirty (30) calendar days of the Effective Date.  
Lightking shall send electronic notification of payment to Kathy Harvey at Kathy.Harvey@fcc.gov and to 
SED’s mailbox at EB-SED-Response@fcc.gov on the date said payment is made.  The payment must be 
made by check or similar instrument, wire transfer, or credit card, and must include the Account Number 
and FRN referenced above.  Regardless of the form of payment, a completed FCC Form 159 (Remittance 
Advice) must be submitted.
17
  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 that should be followed based on the form of payment selected:
? 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.
Questions regarding payment procedures should be addressed to the Financial Operations Group 
Help Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
18. Waivers.  As of the Effective Date, Lightking waives any and all rights it may have to 
seek administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest 
the validity of this Consent Decree and the Adopting Order.  Lightking shall retain the right to challenge 
Commission interpretation of the Consent Decree or any terms contained herein.  If either Party (or the 
United States on behalf of the Commission) brings a judicial action to enforce the terms of the Consent 
Decree or the Adopting Order, neither Lightking nor the Commission shall contest the validity of the 
Consent Decree or the Adopting Order, and Lightking shall waive any statutory right to a trial de novo.  
Lightking hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice 
Act
18
 relating to the matters addressed in this Consent Decree.
19. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
20. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding.
17
 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
18
 See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530.
Federal Communications Commission DA 18-482
7
21. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent Rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which Lightking does not expressly 
consent) that provision will be superseded by such Rule or Order.
22. Successors and Assigns.  Lightking agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.
23. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.  
24. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
25. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
26. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions.
27. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Christopher L. Killion
Deputy Chief
Enforcement Bureau
________________________________
Date
________________________________
Timur Colak
President 
Digital Outdoor, LLC d/b/a Lightking
Outdoor 
________________________________
Date