Federal Communications Commission DA 08-1379
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Conn’s, Inc.
Beaumont, TX
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File No. EB-07-RK-008
Acct. No. 0832460006
FRN #0016772667
ORDER
Adopted:  June 10, 2008 Released:  June 13, 2008
By the Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (“Bureau”) and Conn’s Inc. (“Conn’s”).  The Consent Decree terminates an 
investigation by the Bureau against Conn’s for possible violations of Section 15.117(k) of the 
Commission’s Rules regarding the labeling of television receiving equipment that contains an analog 
broadcast television tuner but does not contain a digital broadcast television tuner. 
2. The Bureau and Conn’s have negotiated the terms of the Consent Decree that resolve this 
matter.  A copy of the Consent Decree is attached hereto and incorporated by reference.  
3. 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 
investigation.
4. In the absence of material new evidence relating to this matter, we conclude that our 
investigation raises no substantial or material questions of fact as to whether Conn’s possesses the basic 
qualifications, including those related to character, to hold or obtain any Commission license or 
authorization.    
5. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Communications Act 
of 1934, as amended,1 and Sections 0.111 and 0.311 of the Commission’s Rules,2 the Consent Decree 
attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
7. IT IS FURTHER ORDERED that Conn’s, Inc. shall make its voluntary contribution to 
the United States Treasury, as specified in the Consent Decree, by mailing a check or similar instrument 
payable to the order of the Federal Communications Commission, 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 
  
1 47 U.S.C. § 154(i).
2 47 C.F.R. §§ 0.111, 0.311.
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63101.  Payment by wire transfer may be made to ABA Number 021030004, receiving bank 
TREAS/NYC, 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).  Conn’s shall also send electronic notification on the date said payment is made to 
SCR-Response@fcc.gov.
8. IT IS FURTHER ORDERED that Conn’s, Inc. will file reports with the Commission 
ninety days after the Effective Date and on July 9, 2009.  Each report shall include a compliance 
certificate from an officer, as an agent of Conn’s, stating that the officer has personal knowledge that 
Conn’s has established operating procedures intended to ensure compliance with this Consent Decree, 
together with an accompanying statement explaining the basis for the officer’s compliance certification.  
All reports shall be submitted to Kathryn S. Berthot, Chief, Spectrum Enforcement Division, Enforcement 
Bureau, Federal Communications Commission, 445 12th Street, S.W., Washington, D.C. 20554 and by e-
mail at Kathy.Berthot@fcc.gov.
9. 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 Conn’s counsel, Scott Feira, Arnold 
& Porter, LLP, 555 12th St. NW, Washington, DC 20004-1206. 
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief, Enforcement Bureau
Federal Communications Commission DA 08-1379
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Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Conn’s, Inc.
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)
)
)
)
)
File No. EB-07-RK-008
Acct. No. 0832460006
FRN #0016772667
CONSENT DECREE
The Enforcement Bureau (“Bureau”) and Conn’s, Inc. (“Conn’s”), by their respective authorized 
representatives, hereby enter into this Consent Decree for the purpose of terminating the Bureau’s 
Investigation into Conn’s compliance with the Federal Communications Commission’s regulations in 47 
C.F.R. § 15.117(k) regarding the labeling of television receiving equipment that contains an analog 
broadcast television tuner but does not contain a digital broadcast television tuner. 
I.         DEFINITIONS
1. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended, 47 U.S.C. §§ 151
et seq.
(b) “Adopting Order” means an order of the Bureau adopting this Consent Decree.
(c) “Analog-only television receiving equipment” means television receiving 
equipment that contains an analog broadcast television tuner but does not 
contain a digital broadcast television (“DTV”) tuner.
(d) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(e) “Commission” or “FCC” means the Federal Communications Commission.
(f) “Conn’s” means Conn’s, Inc. and its wholly owned subsidiaries.
(g) “Effective Date” means the date on which the Bureau releases the Adopting 
Order.
(h) “Investigation” means the investigation initiated by the Bureau regarding 
Conn’s compliance through the Effective Date with Section 15.117(k) of the 
Commission’s Rules regarding the labeling of analog-only television receiving 
equipment.
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(i) “Parties” means Conn’s and the Bureau.
(j) “Rules” means the Commission’s regulations set forth in Title 47 of the Code 
of Federal Regulations.
II. BACKGROUND
2. To ensure that consumers do not inadvertently buy analog-only television receiving 
equipment without understanding that such devices will not be capable of receiving over-the-air television 
reception of digital signals after analog broadcasting ends unless connected to a digital-to-analog 
converter or a digital subscription service, the Commission adopted rules requiring anyone that sells, 
offers for sale, or rents television receiving equipment that does not contain a DTV tuner to display a 
Consumer Alert at the point of sale.1 This requirement also applies to the sale or rent of analog-only 
television receiving equipment via direct mail, catalog, or electronic means (e.g., the Internet).  These 
requirements are contained in Section 15.117(k) of the Rules, which became effective on May 25, 2007.2
3. Section 15.117(k)(3) of the Rules requires that the Consumer Alert contain the following 
language:
The Consumer Alert must be in a size of type large enough to be clear, conspicuous and readily legible, 
consistent with the dimensions of the equipment and the label.  The alert either must be printed on a 
transparent material and affixed to the screen, in a manner that is removable by the consumer and does 
not obscure the picture when displayed for sale, or displayed separately immediately adjacent to each 
television receiver offered for sale and clearly associated with the analog-only model to which it pertains.  
In the case of other analog-only video devices that do not include a display (e.g., VCRs, DVD players), 
the Consumer Alert must be in a prominent location on the device, such as on the top or front, or 
displayed separately immediately adjacent to and clearly associated with the analog-only model to which 
it pertains. To the extent that any persons display or offer for sale or rent via direct mail, catalog, or 
electronic means analog-only television receiving equipment, they must prominently display the 
  
1 Second Periodic Review of the Commission’s Rules and Policies Affecting the Conversion To 
Digital Television, Second Report and Order, 22 FCC Rcd 8776 (2007) (“Second DTV Periodic 
Report and Order”).
2 Second Periodic Review in the Commission’s Rules and Policies Affecting the Conversion to 
Digital Television, 72 Fed. Reg. 28894-01 (May 23, 2007).
CONSUMER ALERT
This television receiver has only an analog broadcast tuner and will require a converter box after 
February 17, 2009, to receive over-the-air broadcasts with an antenna because of the Nation’s 
transition to digital broadcasting.  Analog-only TVs should continue to work as before with cable 
and satellite TV services, gaming consoles, VCRs, DVD players, and similar products.  For more 
information, call the Federal Communications Commission at 1-888-225-5322 (TTY: 1-888-835-
5322) or visit the Commission’s digital television website at: www.dtv.gov.
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Consumer Alert as part of all advertisements or descriptions of such television receiving equipment, in 
clear and conspicuous print, and in close proximity to any images or descriptions of such equipment.  
4. After the rule became effective, the Bureau began inspecting stores throughout the country, 
as well as popular retailer websites, and observed many models of analog-only television receiving 
equipment on display without the required Consumer Alert labels.  Beginning on or about May 29, 2007, the 
Bureau conducted inspections at multiple Conn’s stores.  Based on those inspections, and relying on 
publicly available information, the Bureau issued Citations to Conn’s for alleged violations of Section 
15.117(k) at its stores.  After affording Conn’s a reasonable opportunity to respond to the first Citation, 
agents and investigators from the Enforcement Bureau inspected Conn’s stores in various states and 
observed, in stores, what appeared to them to be television receiving equipment with analog-only tuners on 
display apparently without the required Consumer Alert labels.
III. TERMS OF AGREEMENT
5. Adopting Order.  The Parties agree that the provisions of this Consent Decree shall be 
subject to final approval by the Bureau by incorporation of such provisions by reference in the Adopting 
Order without change, addition, modification, or deletion.
6. Jurisdiction. Conn’s 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.
7. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the date on which the Bureau releases the Adopting Order.  Upon release, the Adopting Order 
and this Consent Decree shall have the same force and effect as any other Order of the Bureau.  Any 
violation of the Adopting Order or of the terms of this Consent Decree shall constitute a separate violation 
of a Bureau order, entitling the Bureau to exercise any rights and remedies attendant to the enforcement of 
a Commission Order.
8. 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 its Investigation.  In consideration for the termination of said Investigation, Conn’s agrees to the 
terms, conditions, and procedures contained herein.  The Bureau further agrees that in the absence of new 
material evidence, the Bureau will not use the facts developed in this Investigation through the Effective 
Date of the Consent Decree, or the existence of this Consent Decree, to institute, on its own motion or in 
response to third-party objection, any new proceeding, formal or informal, or take any action on its own 
motion against Conn’s concerning the matters that were the subject of the Investigation.  The Bureau also 
agrees that it will not use the facts developed in this Investigation through the Effective Date of this 
Consent Decree, or the existence of this Consent Decree, to institute on its own motion or in response to 
third-party objection any proceeding, formal or informal, or take any action on its own motion against 
Conn’s with respect to Conn’s basic qualifications, including its character qualifications, to hold 
Commission authorizations.
9. Compliance Plan. For purposes of settling the matters set forth herein, Conn’s agrees to 
develop, within thirty (30) calendar days from the Effective Date, an internal Compliance Plan related to 
future compliance with this Consent Decree.  The Plan will include, at a minimum, the following 
components:
Federal Communications Commission DA 08-1379
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Training obligations.  The Compliance Plan will, at a minimum, provide that all store 
employees responsible for the sale of television receiving equipment (i.e., those sales personnel 
who regularly work in the consumer electronics section of affected stores) and all those 
responsible for managing such personnel shall receive training on the DTV transition.  Training 
will include, at a minimum, information about:  
A. the need for a digital television receiver or a digital-to-analog converter box to receive 
over-the-air broadcasts with an antenna due to the transition to digital broadcasting;
B. the February 17, 2009 end date for the DTV transition; 
C. the FCC’s DTV transition website (www.dtv.gov); and 
D. compliance with 16 CFR Part 238 (“Guides Against Bait Advertising”).
10. Consumer Education.  Conn’s agrees that it will take the following actions to educate 
consumers about the upcoming transition for over-the-air broadcasting from analog programming to 
digital programming schedule for completion by February 17, 2009.  The requirements of this paragraph 
will end on February 17, 2009.
A. Within thirty (30) days of the Effective Date, Conn’s will include references to the FCC’s 
DTV transition website (www.dtv.gov) on the Conn’s web site’s general welcome screen 
and television welcome screen.
B. Within thirty (30) days of the Effective Date, Conn’s will provide prominent in-store 
signage in the consumer electronics section in each of its stores in addition to Section 
15.117(k) notices to further educate consumers about the DTV transition.  Such signage 
shall include the offering of an informational tipsheet on the DTV transition, developed 
by the Commission.  Conn’s will print and stock in its electronics department copies of 
the tipsheet within thirty (30) days of the Effective Date or receipt of an electronic copy 
of the document from the Bureau, whichever is later.  In the event that the Commission or 
its designee notifies Conn’s that the DTV tip sheet has been updated, Conn’s will begin 
using the revised tip sheet within thirty (30) days of its being made available to retailers.
C. In fifty (50) percent of all print advertising featuring televisions between the Effective 
Date and February 17, 2009, Conn’s will include a reference to the February 17, 2009 
DTV transition end date and refer to the FCC’s DTV transition website (www.dtv.gov).  
D. Within thirty (30) days of the Effective Date, Conn’s will display a video announcement 
on the DTV transition and the Coupon-Eligible Converter Box Program (the “CECB 
Program”) on a continuous loop in each Conn’s store.
11. Termination of Sales of Analog-Only Televisions. Conn’s has not placed any orders 
for analog only televisions after February 2007.  Conn’s stock of unsold devices with analog-only 
receivers as of the Effective Date is less than 1,110 units.  Conn’s shall terminate all domestic retail sales 
of these devices no later than December 31, 2008.  Beginning August 29, 2008, and on the last business 
day of each successive month, Conn’s shall notify Diane Law-Hsu, Regional Counsel, South Central 
Region, Enforcement Bureau, Federal Communications Commission, at SCR-Response@fcc.gov whether 
Conn’s continues to sell analog-only televisions.  Beginning September 1, 2008, and continuing on the 
first business day of each successive month, Conn’s shall make a voluntary contribution to the United 
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States Treasury in the amount of $1,500 until Conn’s no longer sells devices with analog-only receivers.  
Payment shall be made as described in Paragraph 15.  Conn’s audit staff will confirm compliance with 
this paragraph.
12. Participation in the NTIA Digital-to-Analog Converter Box Coupon Program.  
Conn’s has agreed to participate in the CECB Program developed by the U.S. Department of Commerce’s 
National Telecommunications and Information Administration by offering digital-to-analog converters 
through its stores that sell televisions.  Conn’s will participate in the program as follows:
A. Conn’s has ordered converter boxes for its stores; 
B. unless delays on the part of suppliers or shippers make such action infeasible, Conn’s will 
place, by July 1, 2008, the converter boxes in all of its stores in which televisions are 
sold; 
C. Conn’s retains the discretion to determine the number of boxes to be delivered to 
individual stores, based on anticipated customer demand; 
D. if a particular store does not have converter boxes in stock, Conn’s will order a converter 
box for shipment directly to the customer’s home; and
E. Conn’s will continue to sell converter boxes until such time as, based on its reasonable 
judgment, reimbursement payments to Conn’s are no longer likely to be forthcoming.
13. Compliance Reports.  Conn’s will file compliance reports with the Commission ninety 
(90) days after the Effective Date and on July 9, 2009.  Each compliance report shall include a 
compliance certificate from an officer, as an agent of Conn’s, stating that the officer has personal 
knowledge that Conn’s has established operating procedures intended to ensure compliance with this 
Consent Decree, together with an accompanying statement explaining the basis for the officer’s 
compliance certification.  All compliance reports shall be submitted to Kathryn S. Berthot, Chief, 
Spectrum Enforcement Division, Enforcement Bureau, Federal Communications Commission, 445 12th 
Street, S.W., Washington, D.C. 20554 and by e-mail at Kathy.Berthot@fcc.gov.  
14. Termination Date.  Unless stated otherwise, the requirements of this Consent Decree 
will expire July 9, 2009.
15. Voluntary Contribution. Conn’s agrees that it will make a voluntary contribution to the 
United States Treasury in the amount of seventy thousand dollars ($70,000).  The payment will be made 
within thirty calendar days after the Effective Date of the Adopting Order.  The payment must be made by 
check or similar instrument, payable to the order of the Federal Communications Commission.  The 
payment must include the NAL/Account Number and FRN Number referenced in the caption to the 
Adopting Order.  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 
TREAS/NYC, 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 
Federal Communications Commission DA 08-1379
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(payment type code).  Conn’s shall also send electronic notification on the date said payment is made to 
Diane Law-Hsu, Regional Counsel, South Central Region, at SCR-Response@fcc.gov.
16. Waivers.  Conn’s 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, provided the Bureau issues the Adopting Order adopting the Consent 
Decree without change, addition, modification, or deletion.  Conn’s 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 Adopting 
Order, neither Conn’s nor the Commission shall contest the validity of the Consent Decree or the 
Adopting Order, and Conn’s shall waive any statutory right to a trial de novo.  Conn’s hereby agrees to 
waive any claims it may otherwise have under the Equal Access to Justice Act, 5 U.S.C. § 504 and 47 
C.F.R. § 1.1501 et seq., relating to the matters addressed in this Consent Decree.
17. Severability. The Parties agree that if any of the provisions of the Adopting Order or the 
Consent Decree shall be invalid or unenforceable, such invalidity or unenforceability shall not invalidate 
or render unenforceable the entire Adopting Order or Consent Decree, but rather the entire Adopting 
Order or Consent Decree shall be construed as if not containing the particular invalid or unenforceable 
provision or provisions, and the rights and obligations of the Parties shall be construed and enforced 
accordingly.  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.
18. 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 Conn’s does not expressly 
consent) that provision will be superseded by such Commission rule or Order.
19. Successors and Assigns. Conn’s agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees.  
20. Final Settlement. The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties.  The Parties further agree that this Consent Decree does 
not constitute either an adjudication on the merits or a factual or legal finding or determination regarding 
any compliance or noncompliance with the requirements of the Act or the Commission’s Rules and 
Orders.  The Parties agree that this Consent Decree is for settlement purposes only and that by agreeing to
this Consent Decree, Conn’s does not admit or deny noncompliance, violation or liability for violating the 
Act in connection with the matters that are the subject of this Consent Decree.
21. Modifications. This Consent Decree cannot be modified without the advance written 
consent of both Parties.
22. 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.
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23. Authorized Representative.  Each party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.
25. Counterparts. This Consent Decree may be signed in any number of counterparts 
(including by facsimile), each of which, when executed and delivered, shall be an original, and all of 
which counterparts together shall constitute one and the same fully executed instrument.
________________________________
Kris Anne Monteith
Chief, Enforcement Bureau
Federal Communications Commission
________________________________
Date
________________________________
Timothy L. Frank
President
Conn’s, Inc.
________________________________
Date