• The FCC Puts The Arm On a Puerto Rico Landlord [telecom]

    From Bill Horne@21:1/5 to All on Sun Apr 2 00:37:06 2023
    NOTICE OF ILLEGAL
    PIRATE RADIO BROADCASTING
    Case Number: EB-FIELDSCR-22-00034240

    ...

    Under section 511(a) of the Act, persons or entities found to
    willfully and knowingly suffer (i.e., permit) a third party to engage
    in so-called “pirate radio” broadcasting on their property can face significant financial penalties.5 Accordingly, you are hereby notified
    and warned that the FCC may issue a fine of up to $2,316,034 if,
    following the response period set forth below, we determine that you
    have continued to permit any individual or entity to engage in pirate
    radio broadcasting from the property that you own or manage.

    https://docs.fcc.gov/public/attachments/DOC-392069A1.pdf

    **********************************************************************
    * Moderator's Note
    *
    * I had to read the amount shown above three times before I believed
    * it. This dunning notice is so clearly an example of bureaucratic
    * arrogance and overreach that I'm saddened to think it's even
    * possible: if I understand it, the FCC appears to be demanding that
    * the owner of a building take steps to stop a tenant, squatter, or
    * transient from using a ten-watt FM transmitter to "broadcast" to
    * local listeners - or face a fine that could range "up to" over
    * Two Million dollars.
    *
    * News flash, FCC: real estate agents have been putting more powerful
    * transmitters into vacant homes for years, with pre-recorded
    * anouncements about the selling points that the agents want visitors
    * to remember while listening from their cars. Why don't you go after
    * *them*, oh gov-a-mint minions?
    *
    * Is it so much trouble to obtain a search and seizure warrant that
    * our Federal employees feel that they are entitled to force
    * innocent third parties to do their jobs for them?
    *
    * Bill Horne **********************************************************************

    --
    (Please remove QRM for direct replies)

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  • From Garrett Wollman@21:1/5 to malQRMassimilation@gmail.com on Sun Apr 2 02:57:29 2023
    In article <20230402003706.GA1906300@telecomdigest.us>,
    Bill Horne <malQRMassimilation@gmail.com> wrote:

    * I had to read the amount shown above three times before I believed
    * it. This dunning notice is so clearly an example of bureaucratic
    * arrogance and overreach

    Nonsense.

    * possible: if I understand it, the FCC appears to be demanding that
    * the owner of a building take steps to stop a tenant, squatter, or
    * transient from using a ten-watt FM transmitter to "broadcast" to
    * local listeners

    The PIRATE Act[1] (Pub. L. 116-109, passed by Congress and signed by
    President Trump in 2020) authorizes penalties for unlicensed
    broadcasting of up to $20,000 per day, with an overall limit of
    $2,316,034,[2] and allows the FCC to fine the property owners where transmitters are located in addtion to the station operators. The
    legislation requires the FCC to conduct annual enforcement sweeps in
    the top 5 markets for pirate activity and make an annual report to
    Congress.

    The specific language is codified at 47 USC 511(a):

    Any person who willfully and knowingly does or causes or
    *suffers to be done* any pirate radio broadcasting shall be
    subject to a fine of not more than $2,000,000. (emphasis mine)

    The same language is used in the implementing regulations, 47 CFR
    1.80(b)(c). "Suffers to be done" allows for the FCC to go after
    anyone who tolerates pirate activity on their property, although it's
    implicit in the choice of verb that some knowledge on the part of the
    landlord must be demonstrated -- but the FCC could easily force the
    issue simply by serving the landlord with a Notice of Apparent
    Liability. If the landlord does not then take action to evict the
    pirate, the fines start racking up even if the FCC can't prove that
    they knew (or should have known) about their tenant's activity prior
    to receiving notice.

    The FCC's procedure used to be more forgiving, in addition to the
    fines having been lower: the Enforcement Bureau would previously have
    issued a Notice of Unlicensed Operation prior to proceeding to a
    Notice of Apparent Liability, but in the new legislation Congress
    required them to dispense with this extra step.

    -GAWollman

    [1] Not to be confused with intellectual property legislation of the
    same name passed in 2004.

    [2] The actual legislation as enacted says "2,000,000" but elsewhere
    in the U.S. Code, its is provided that all dollar amounts are to be
    adjusted for inflation unless the law explicitly specifies otherwise.
    --
    Garrett A. Wollman | "Act to avoid constraining the future; if you can, wollman@bimajority.org| act to remove constraint from the future. This is Opinions not shared by| a thing you can do, are able to do, to do together."
    my employers. | - Graydon Saunders, _A Succession of Bad Days_ (2015)

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