Federal Communications Commission DA 09-1025
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Panhandle Telecommunication Systems, Inc. 
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File No. EB-08-SE-004
Acct. No. 200932100055
FRN No. 0001704246
ORDER
Adopted: May 11, 2009 Released: May 13, 2009
By the Chief, Spectrum Enforcement Division, Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (“Bureau”) and Panhandle Telecommunication Systems, Inc. 
(“PTSI”).  The Consent Decree terminates an investigation by the Bureau against PTSI for possible 
violation of former Section 20.19(d)(2) of the Commission’s Rules (“Rules”)1 regarding the inductive 
coupling standards for hearing aid compatibility.  
2. The Bureau and PTSI 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, which terminates 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 PTSI 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,2 and sections 0.111 and 0.311 of the Rules,3 the Consent Decree attached to this 
Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
  
1 47 C.F.R. § 20.19(d)(2) (2007).  In February 2008, as part of a comprehensive reconsideration of the effectiveness 
of the hearing aid compatibility rules, the Commission made several changes to these rules.  See Amendment of the 
Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets, First Report and Order, 23 FCC Rcd 
3406 (2008) (“Hearing Aid Compatibility First Report and Order”), Order on Reconsideration and Erratum, 23 FCC 
Rcd 7249 (2008).  
2 47 U.S.C. §§ 154(i). 
3 47 C.F.R. §§ 0.111, 0.311.
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7. 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 Ron Strecker, Chief Executive 
Officer, Panhandle Telecommunication Systems, Inc., 2224 N Highway 64, Guymon, Oklahoma 73942 
and to its counsel, Kenneth C. Johnson, Bennet & Bennet, PLLC, 4350 East West Highway, Bethesda, 
Maryland 20814. 
FEDERAL COMMUNICATIONS COMMISSION
Kathryn S. Berthot
Chief, Spectrum Enforcement Division
Enforcement Bureau
Federal Communications Commission DA 09-1025
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Panhandle Telecommunication Systems, Inc. 
)
)
)
)
)
File No. EB-08-SE-004
Acct. No. 200932100055
FRN No. 0001704246
CONSENT DECREE
The Enforcement Bureau (“Bureau”) and Panhandle Telecommunication Systems, Inc. 
(“PTSI”), by their authorized representatives, hereby enter into this Consent Decree for the purpose of 
terminating the Bureau’s investigation into whether PTSI violated former Section 20.19(d)(2) of the 
Commission’s Rules1 regarding the inductive coupling hearing aid compatibility requirements.
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 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) “Compliance Plan” means the program described in this Consent Decree at paragraph 
9.
(f)“Effective Date” means the date the Bureau releases the Adopting Order.
(g) “Investigation” means any investigation initiated by the Bureau regarding whether 
PTSI violated the inductive coupling hearing aid compatibility requirements of 
former Section 20.19(d)(2) of the Rules.
(h) “Parties” means PTSI and the Bureau.
(i)“PTSI” means Panhandle Telecommunication Systems, Inc., and its predecessors-in-
interest and successors-in-interest.
  
1 47 C.F.R. § 20.19(d)(2) (2007). In February 2008, as part of a comprehensive reconsideration of the effectiveness 
of the hearing aid compatibility rules, the Commission made several changes to these rules.  See Amendment of the 
Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets, First Report and Order, 23 FCC Rcd 
3406 (2008) (“Hearing Aid Compatibility First Report and Order”), Order on Reconsideration and Erratum, 23 FCC 
Rcd 7249 (2008).  
Federal Communications Commission DA 09-1025 
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(j)“Rules” means the Commission’s regulations found in Title 47 of the Code of Federal 
Regulations.
II.  BACKGROUND
2. Pursuant to former Section 20.19(d)(2) of the Rules, carriers were required to offer at 
least two handset models for each air interface that meet the inductive coupling standards for hearing aid 
compatibility (i.e., achieve a rating of T3 or better) by September 18, 2006.  
3. On September 14, 2006, PTSI filed a Petition for Temporary and Limited Waiver of the 
requirements in Section 20.19(d)(2) of the Commission’s Rules.2 The PTSI Petition requested additional 
time to obtain the required handsets until January 1, 2007.  
4. On June 1, 2007, PTSI notified the Commission that as of January 29, 2007, it had been 
offering for sale two handset models rated T3 or better (the Motorola L7c and the Motorola K1m).3 On 
September 20, 2007, PTSI filed an Amendment to its Petition requesting extended relief from the 
deadline until January 29, 2007.4 On February 27, 2008, the Commission issued a Memorandum Opinion 
and Order that, inter alia, denied PTSI’s Petition as amended and referred PTSI’s apparent violation to 
the Bureau.5 On June 9, 2008, PTSI notified the Commission that it discovered that it had offered for sale 
one additional compatible model, the T3-rated version of the Motorola V3c, since October 23, 2006.6
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. PTSI 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, PTSI agrees to the 
  
2 See Panhandle Telecommunication Systems, Inc.  Petition for Temporary and Limited Waiver of Section 
20.19(d)(2) of the Commission’s Rules, WT Docket No. 01-309 (September 14, 2006).
3 Letter from Michael Bennet, Esq. and Kenneth Johnson, Esq., Bennet & Bennet, Counsel for Panhandle 
Telecommunication Systems, Inc. to Ms. Marlene Dortch, Secretary (June 1, 2007).  
4 See Panhandle Telecommunication Systems, Inc. Amendment to Petition for Temporary and Limited Waiver of 
Section 20.19(d)(2) of the Commission’s Rules, WT Docket No. 01-309 (September 20, 2007).  
5 See Section 68.4(a) of the Commission’s Rules Governing Hearing Aid-Compatible Telephones, Petitions for 
Waiver of Section 20.19 of the Commission’s Rules, Memorandum Opinion and Order, 23 FCC Rcd 3352, 3365 
(2008).
6 Letter from Kenneth Johnson, Esq., Bennet & Bennet, Counsel for Panhandle Telecommunication Systems, Inc., to 
Ms. Marlene Dortch, Secretary (June 9, 2008).
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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, any 
new proceeding, formal or informal, or take any action on its own motion against PTSI 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 PTSI with respect to PTSI’s basic qualifications, including its character 
qualifications, to be a Commission licensee or authorized common carrier.
9. Compliance Plan.  For purposes of settling the matters set forth herein, PTSI agrees to 
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. PTSI has designated its Chief Executive Officer as its hearing aid 
compatibility compliance officer.  The designated hearing aid compatibility compliance
officer will be familiar with the Commission’s hearing aid compatibility regulations and 
associated selling and labeling benchmarks.  The designated hearing aid compatibility 
compliance officer will also review the Commission’s hearing aid compatibility regulations 
on a monthly basis in order to stay abreast of pending benchmarks and any new hearing aid 
compatibility requirements. 
(b) Training. The designated hearing aid compatibility compliance officer will be responsible 
for ensuring that all PTSI retail staff receives training regarding the hearing aid compatibility 
capabilities of the handsets PTSI offers for sale.  Such training will be completed within 
ninety days of the Effective Date and any new employees will receive training within sixty 
days of their employment.
(c) Consumer Outreach. PTSI will advertise the availability of hearing aid-compatible 
handsets to ensure that all of its retail customers are aware that hearing aid-compatible 
handsets are available.  
(d) Compliance Reports. PTSI will file compliance reports with the Commission ninety (90) 
days after the Effective Date, twelve (12) months after the Effective Date, and twenty-four 
(24) months after the Effective Date.  Each compliance report shall include a compliance 
certificate from an officer, as an agent of PTSI, stating that the officer has personal 
knowledge that PTSI 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.  All 
compliance reports shall also be submitted electronically to Nissa Laughner at 
Nissa.Laughner@fcc.gov, and Ricardo Durham at Ricardo. Durham@fcc.gov.
(e) Termination Date. Unless stated otherwise, the requirements of this Consent Decree will 
expire twenty-four (24) months from the Effective Date.
10. Section 208 Complaints; Subsequent Investigations. Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
section 208 of the Act against PTSI or its affiliates for alleged violations of the Act, or for any other type 
of alleged misconduct, regardless of when such misconduct took place.  The Commission’s adjudication 
of any such complaint will be based solely on the record developed in that proceeding.  Except as 
Federal Communications Commission DA 09-1025 
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expressly provided in this Consent Decree, this Consent Decree shall not prevent the Commission from 
investigating new evidence of noncompliance by PTSI with the Act, the Rules, or the Order.
11. Voluntary Contribution.  PTSI agrees that it will make a voluntary contribution to the 
United States Treasury in the amount of $9,000.  The payment will be made within 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). PTSI will also send electronic notification on the 
date said payment is made to Nissa Laughner at Nissa.Laughner@fcc.gov and Ricardo. 
Durham@fcc.gov.
12. Waivers.  PTSI 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.  PTSI 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 PTSI nor the Commission shall contest the validity of the Consent Decree or the 
Adopting Order, and PTSI shall waive any statutory right to a trial de novo.  PTSI 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.
13. 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.
14. 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 PTSI does not expressly 
consent) that provision will be superseded by such Commission rule or Order.
15. Successors and Assigns. PTSI agrees that the provisions of this Consent Decree shall be 
binding on its successors, assigns, and transferees.
16. 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.
17. Modifications. This Consent Decree cannot be modified without the advance written 
consent of both Parties.
18. 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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19. Authorized Representative.  Each party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.
20. 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.
_______________________________
Kathryn S. Berthot
Division Chief
Enforcement Bureau 
________________________________
Date
________________________________
Ron Strecker
Chief Executive Officer
Panhandle Telecommunication Systems, Inc.
________________________________
Date