Federal Communications Commission DA 08-845
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
SANYO TV International Corporation d/b/a
SANYO Manufacturing Company
and
SANYO Fisher Company, a division of 
SANYO North America Corporation
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File No. EB-07-SE-254
Acct. No. 200832100030
FRN No. 0001726231
ORDER
Adopted: April 9, 2008 Released: April 11, 2008
By the Chief, Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (“Bureau”) and SANYO TV International Corporation d/b/a/ SANYO 
Manufacturing Company (“SMC”) and SANYO Fisher Company (“SFC”), a division of SANYO North 
America Corporation (collectively, “SANYO”).  The Consent Decree terminates an investigation by the 
Bureau against SANYO for possible violations of section 330(c) of the Communications Act of 1934, as 
amended (the “Act”),1 and section 15.120(d)(2) of the Commission’s rules ("Rules"),2 regarding the 
manufacture in the United States and interstate shipment, after March 15, 2006, of digital television 
receivers that do not comply with the V-Chip technology requirements because they lack the ability to 
adapt to new rating systems.  
2. The Bureau and SANYO 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.
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 SANYO 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 Act3 and sections 
0.111 and 0.311 of the Rules,4 the Consent Decree attached to this Order IS ADOPTED.
  
1 47 U.S.C. § 330(c).
2 47 C.F.R. § 15.120(d)(2).
3 47 U.S.C. § 154(i).
4 47 C.F.R. §§ 0.111, 0.311.
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6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
7. IT IS FURTHER ORDERED that all third-party complaints against SANYO before the 
Bureau related to the above-captioned-investigation as of the date of this Consent Decree ARE 
DISMISSED.
8. IT IS FURTHER ORDERED that SANYO shall make its voluntary contribution to the 
United States Treasury, as specified in the Consent Decree, by credit card through the Commission’s 
Revenue and Receivables Operations Group at (202) 418-1995, or 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 
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 Account number 
in block number 23A (call sign/other ID), and enter the letters “FORF” in block number 24A (payment 
type code).  
9. IT IS FURTHER ORDERED that SANYO will file reports with the Commission 
ninety days after the Effective Date, twelve months after the Effective Date, and twenty four months after 
the Effective Date.  Each report shall include a compliance certificate from an officer, as an agent of 
SANYO, stating that the officer has personal knowledge that SANYO 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 
the Chief, Spectrum Enforcement Division, Enforcement Bureau, Federal Communications Commission, 
445 12th Street, S.W., Washington, D.C. 20554.
10. 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 Alan G. Fishel, Esq. and Jeffrey E. 
Rummel, Esq., Arent Fox LLP, 1050 Connecticut Avenue, NW, Washington, DC 20036-5339. 
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief, Enforcement Bureau
Federal Communications Commission DA 08-845
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
SANYO TV International Corporation d/b/a
SANYO Manufacturing Company
and
SANYO Fisher Company, a division of 
SANYO North America Corporation
)
)
)
)
)
)
)
)
)
)
)
File No. EB-07-SE-254
Acct. No. 200832100030
FRN No. 0001726231
CONSENT DECREE
The Enforcement Bureau (“Bureau”) and SANYO TV International Corporation d/b/a/ SANYO 
Manufacturing Company (“SMC”) and SANYO Fisher Company (“SFC”), a division of SANYO North 
America Corporation (collectively, “SANYO”), by their authorized representatives, hereby enter into this 
Consent Decree for the purpose of terminating the Bureau’s investigation into whether SANYO  violated 
Section 330(c) of the Communications Act of 1934, as amended (“Act”),1 and Section 15.120(d)(2) of the 
Commission’s Rules (“Rules”),2 regarding the manufacture in the United States and interstate shipment, 
after March 15, 2006, of digital television receivers that do not comply with the V-Chip technology 
requirements because they lack the ability to adapt to new rating systems.
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) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(c) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.  
(d) “Complaints” means third-party complaints that may have been received by, or are 
in the possession of, the Commission or Bureau alleging violations of the V-Chip 
technology requirements.
(e) “Compliance Plan” means the program described in this Consent Decree at 
paragraph 8.
  
1 47 U.S.C. § 303(c). 
2 47 C.F.R. § 15.120(d)(2).
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(f) “Digital Television Receivers” or “DTV Receivers” means (i) digital television 
broadcast receivers with display screens in the 4:3 aspect ratio measuring 13 inches 
or larger diagonally, (ii) digital television broadcast receivers with display screens in 
the 16:9 aspect ratio measuring 7.8 inches or larger vertically, and (iii) devices with 
digital television broadcast tuners sold without an accompanying display device, 
such as DVR recorders.
(g) “Effective Date” means the date on which the Bureau releases the Adopting Order.
(h) “Investigation” means the investigation commenced by the Bureau’s August 9, 2007 
Letter of Inquiry3 regarding whether SANYO violated section 330(c) of the Act, and 
section 15.120(d)(2) of the Rules, by shipping interstate digital television receivers 
that do not comply with the V-Chip technology requirements because they lack the 
ability to adapt to new rating systems.
(i) “SANYO” means SANYO TV International Corporation d/b/a SANYO 
Manufacturing Company, SANYO Fisher Company, a division of SANYO North 
America Corporation, and their predecessors-in-interest and successors-in-interest.
(j) “Order” or “Adopting Order” means an Order of the Bureau adopting the terms of 
this Consent Decree without change, addition, deletion, or modification.
(k) “Parties” means SANYO and the Bureau.
(l) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
II. BACKGROUND
2. Section 303(x) of the Act directs the Commission to prescribe rules that require television 
receivers with picture screens 13 inches or greater shipped in interstate commerce or manufactured in the 
United States to be equipped with a feature designed to enable viewers to block the display of all 
programs with a common rating.4 Section 330(c) of the Act provides that no person shall ship in 
interstate commerce or manufacture in the United States television receivers that do not comply with rules 
prescribed by the Commission pursuant to Section 303(x).5 The Commission adopted program blocking 
capability requirements for both analog and digital television (“DTV”) receivers in 1998.6 In 2004, the 
Commission adopted specific technical standards to implement V-Chip functionality for DTV receivers 
(“V-Chip technology requirements”).7 The DTV V-Chip technology requirements provide that, effective 
  
3 See Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division, Enforcement Bureau to Sanyo North 
America Corporation (August 9, 2007) (“August 9, 2007 LOI”)
4 47 U.S.C. § 303(x).
5 47 U.S.C. § 330(c).
6 In the Matter of Technical Requirements to Enable Blocking of Video Programming Based on Program Rating, 
Implementation of Sections 551(c), (d), and (e) of the Telecommunications Act of 1996, Report and Order, 13 FCC 
Rcd 11248 (1998).
7 In the Matter of Second Periodic Review of the Commission’s Rules and Policies Affecting the Conversion to 
Digital Television, Report and Order, 19 FCC Rcd 18279 (2004).  The V-Chip technology requirements also apply 
to devices sold without an accompanying display device.  Id. at 18348.
Federal Communications Commission DA 08-845
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March 15, 2006, digital television receivers with picture screens 13 inches or greater that are shipped in 
interstate commerce must be equipped with V-Chip technology to allow blocking of the display of 
programming based on its content and be able to respond to changes in the content advisory rating 
system.8
3. On August 9, 2007, the Bureau issued a letter of inquiry (LOI) to SANYO.9 The August 
9, 2007 LOI directed SANYO, among other things, to submit a sworn written response to a series of 
questions relating to its compliance with the DTV V-Chip technology requirements.  SANYO responded 
to the August 9, 2007 LOI on November 15, 2007,10 and submitted follow-up responses on December 13, 
2007, March 27, 2008, and April 3, 2008.11  
III. TERMS OF AGREEMENT
4. 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.
5. Jurisdiction. SANYO 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.
6. 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.
7. 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 and dismiss the Complaints. In consideration for the termination of said 
Investigation and dismissal of the Complaints, SANYO 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 
  
8 47 C.F.R. § 15.120(d)(2).
9 See August 9, 2007 LOI.
10 See Letter from Alan G. Fishel, Esq. and Jeffrey E. Rummel, Esq., Counsel for SANYO TV 
International Corporation d/b/a SANYO Manufacturing Corporation and SANYO Fisher Company, a 
division of SANYO North America Corporation, to Kathryn S. Berthot, Chief, Spectrum Enforcement 
Division, Enforcement Bureau (November 15, 2007).
11 See Letter from Alan G. Fishel, Esq. and Jeffrey E. Rummel, Esq., Counsel for SANYO TV 
International Corporation d/b/a SANYO Manufacturing Corporation and SANYO Fisher Company, a 
division of SANYO North America Corporation, to Kathryn S. Berthot, Chief, Spectrum Enforcement 
Division, Enforcement Bureau (December 13, 2007); Letter from Alan G. Fishel and Jeffrey E. Rummel, 
Counsel for SANYO TV International Corporation d/b/a SANYO Manufacturing Corporation and 
SANYO Fisher Company, a division of SANYO North America Corporation, to Marlene H. Dortch, 
Secretary, Federal Communications Commission (March 27, 2008); Letter from Alan G. Fishel and 
Jeffrey E. Rummel, Counsel for SANYO TV International Corporation d/b/a SANYO Manufacturing 
Corporation and SANYO Fisher Company, a division of SANYO North America Corporation, to Marlene 
H. Dortch, Secretary, Federal Communications Commission (April 3, 2008).
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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 SANYO 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 any proceeding, formal or informal, or take any action on its own motion against SANYO with 
respect to SANYO’s basic qualifications, including its character qualifications, to be a Commission 
licensee, authorized common carrier, or hold Commission authorizations.  
8. Compliance Plan. For purposes of settling the matters set forth herein, SANYO agrees 
to create within 30 days and maintain, a Compliance Plan related to future compliance with the Act, the 
Commission’s Rules, and the Commission’s Orders.  The Plan will include, at a minimum, the following 
components: 
(a) Compliance Officer. Sanyo will designate an employee of Sanyo to serve as the V-Chip 
Compliance Officer (the “VCO”).  The VCO will oversee Sanyo’s Compliance Program, 
ensuring compliance with the Commission’s DTV V-Chip technology requirements and 
ascertaining whether any developments may trigger additional compliance-related 
responsibilities under the Act or the Commission’s rule.  Sanyo personnel with questions 
regarding compliance on DTV V-Chip technology requirements will be directed to the VCO 
for assistance.  Where necessary, the VCO will consult with outside counsel for assistance.  
The VCO will report regularly to Sanyo’s senior management as necessary about the status of 
Sanyo’s V-Chip related compliance efforts.  The VCO also will promptly notify Sanyo’s 
senior management as necessary about any company-related developments which would or 
might affect Sanyo’s compliance with the Commission’s DTV V-Chip technology 
requirements.
(b) Compliance Manual. Sanyo, through the VCO, will develop a Compliance Manual for 
distribution on or before the date of the initial compliance training program described in 
Paragraph 8(c) below, to company engineers, managers, lawyers, and other parties 
responsible for the company’s compliance with the Commission’s V-chip requirements.   The 
Compliance Manual will include the matters covered in the Compliance Training Program, 
i.e., an overview of the Commission’s V-chip requirements, and issues relating to ensure 
compliance on a going-forward basis.  The Compliance Manual will be updated from time to 
time as needed.
(c) Training. The VCO, with assistance from outside counsel if necessary, will conduct an 
initial education program within 90-days of the Effective Date for company engineers, 
managers, lawyers and other pertinent employees.  This education program will include an 
overview of the Commission’s V-chip requirements and issues relating to ensure compliance 
on a going-forward basis. This education program will be updated and presented annually and 
additionally from time to time as needed to ensure that Sanyo remains informed of regulatory 
compliance requirements.
(d) Database. The VCO or its designee will assemble and maintain information about Sanyo’s 
DTV models subject to the Commission’s V-chip requirements.  The database will be 
accessible by all pertinent employees.
(e) Review Prior to Shipment or Marketing. Prior to the initial shipment of any new DTV 
receiver model,  Sanyo will first ensure that  such model’s design and specifications have 
been verified, through post-production testing, for compliance with the Commission’s V-chip 
requirements, and a report has been completed confirming same.  These reports and records 
from a sample for each such model will be kept on file.
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(f) Compliance Reports. SANYO will file compliance reports with the Commission ninety 
days after the Effective Date, twelve months after the Effective Date, and twenty four months 
after the Effective Date.  Each compliance report shall include a compliance certificate from 
the VCO, as an agent of SANYO, stating that the officer has personal knowledge that 
SANYO 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 the Chief, 
Spectrum Enforcement Division, Enforcement Bureau, Federal Communications 
Commission, 445 12th Street, S.W., Washington, D.C. 20554.  
(g) Termination Date.  Unless stated otherwise, the requirements of this Consent Decree will 
expire twenty-four months after the Effective Date.
9. Voluntary Contribution.  SANYO agrees that it will make a voluntary contribution to 
the United States Treasury in the amount of $375,000.  The payment will be made within thirty (30) 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 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 Account number in block number 23A (call sign/other ID), and enter the letters 
“FORF” in block number 24A (payment type code).
10. Waivers.  SANYO 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 Order adopting this Consent Decree, provided the Bureau issues an Order 
adopting the Consent Decree without change, addition, modification, or deletion.  SANYO 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 SANYO nor the Commission shall contest the validity of the 
Consent Decree or the Adopting Order, and SANYO shall waive any statutory right to a trial de novo.  
SANYO 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.
11. 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.
12. 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 SANYO does not expressly 
consent) that provision will be superseded by such Commission rule or Order.
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13. Successors and Assigns. SANYO agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.  
14. 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.  
15. Modifications. This Consent Decree cannot be modified without the advance written 
consent of both Parties.
16. 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.
17. Authorized Representative.  Each party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.
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18. 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 
________________________________
Date
________________________________
Joe Keeton
Vice President
SANYO TV International Corporation d/b/a/ 
SANYO Manufacturing Company  
________________________________
Date
________________________________
Paul W. D’Arcy
Executive Vice President
SANYO Fisher Company, a division of SANYO 
North America Corporation
________________________________
Date