Federal Communications Commission DA 11-902
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Entertainment Media Trust
Dennis J. Watkins, Trustee
Licensee of Station WQQX 
East St. Louis, Illinois
Facility ID # 72815
Licensee of Station WQQW
Highland, Illinois
Facility ID # 90598
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EB-10-CG-0080
NAL/Acct. No.  201132320003
FRN:  0014655476
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted:  May 18, 2011 Released:  May 19, 2011
By the District Director, Chicago Office, Northeast Region, Enforcement Bureau:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (“NAL”), we find that Entertainment 
Media Trust, Dennis J. Watkins, Trustee, (“Entertainment Media Trust”), licensee of AM Stations WQQX, 
East St. Louis, Illinois and WQQW, Highland, Illinois, apparently willfully and repeatedly violated section 
73.3526 of the Commission’s Rules (“Rules”)1 by failing to maintain and make available local public 
inspection files for Stations WQQW and WQQX.  We conclude that Entertainment Media Trust is 
apparently liable for a forfeiture in the amount of twenty-four thousand dollars ($24,000).
II. BACKGROUND
2. On April 20, 2010, in response to a complaint regarding possible rule violations, an agent 
from the Enforcement Bureau’s Chicago Office conducted an inspection of co-located Stations WQQX 
and WQQW at the stations’ main studio in Belleville, Illinois. The agent conducted the inspection with 
the stations’ general manager and broadcast consultant. The agent found that neither station was maintaining 
a local public inspection file.  When asked about the stations’ public inspection files, station personnel were 
only able to produce ownership reports from 2008.
III. DISCUSSION
3. Section 503(b) of the Communications Act of 1934, as amended (“Act”),2 provides that any 
person who willfully or repeatedly fails to comply substantially with the terms and conditions of any license, 
or willfully or repeatedly fails to comply with any of the provisions of the Act or of any rule, regulation or 
order issued by the Commission thereunder, shall be liable for a forfeiture penalty.  Section 312(f)(1) of the 
Act defines willful as the “conscious and deliberate commission or omission of [any] act, irrespective of any 
  
1 47 C.F.R. § 73.3526(e)(12).
2 47 U.S.C. § 503(b).  
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intent to violate” the law.3 The legislative history to section 312(f)(1) of the Act clarifies that this definition 
of willful applies to both section 312 and 503(b) of the Act4 and the Commission has so interpreted the term 
in the section 503(b) context.5  The Commission may also assess a forfeiture for violations that are merely 
repeated, and not willful.6  The term “repeated” means the commission or omission of such act more than 
once or for more than one day.7
4. Section 73.3526(a)(2) of the Rules states that “[e]very permittee or licensee of an AM, 
FM, TV or a Class A TV station in the commercial broadcast services shall maintain a public inspection 
file containing the material” set forth in this section.8  The public inspection file must be maintained at the 
main studio of the station,9 and must be available for public inspection at any time during regular business 
hours.10  During regular business hours on April 21, 2010, an agent inspected Stations WQQX and 
WQQW and found that neither station was maintaining a public inspection file, and, accordingly, could 
not make such file available for inspection. Based on the evidence before us, we find that Entertainment 
Media Trust apparently willfully violated section 73.3526 of the Rules by failing to make available public 
inspection files for Stations WQQX and WQQW and willfully and repeatedly violated section 73.3526 of 
the Rules by failing to maintain complete public inspection files for those stations.
5. Pursuant to the Commission’s Forfeiture Policy Statement and section 1.80 of the Rules, 
the base forfeiture amount for each violation of the public file rules is $10,000.11 In assessing the monetary 
forfeiture amount, we must also take into account the statutory factors set forth in section 503(b)(2)(E) of 
the Act, which include the nature, circumstances, extent, and gravity of the violations, and with respect to 
the violator, the degree of culpability, and history of prior offenses, ability to pay, and other such matters as 
justice may require.12 Applying the Forfeiture Policy Statement, section 1.80 of the Rules, and the statutory 
factors to the instant case, we conclude that Entertainment Media Trust is apparently liable for a forfeiture in 
  
3 47 U.S.C. § 312(f)(1).
4 H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982) (“This provision [inserted in section 312] defines the terms 
‘willful’ and ‘repeated’ for purposes of section 312, and for any other relevant section of the act (e.g., section 
503)….   As defined … ‘willful’ means that the licensee knew that he was doing the act in question, regardless of 
whether there was an intent to violate the law. ‘Repeated’ means more than once, or where the act is continuous, for 
more than one day. Whether an act is considered to be ‘continuous’ would depend upon the circumstances in each 
case. The definitions are intended primarily to clarify the language in sections 312 and 503, and are consistent with 
the Commission’s application of those terms …”).
5 See, e.g., Application for Review of Southern California Broadcasting Co., Memorandum Opinion and Order, 6 
FCC Rcd 4387, 4388 (1991) (“Southern California Broadcasting Co.”), recon. denied, 7 FCC Rcd 3454 (1992).
6 See, e.g., Callais Cablevision, Inc., Notice of Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359, 1362 
¶ 10 (2001) (“Callais Cablevision, Inc.”) (proposing a forfeiture for, inter alia, a cable television operator’s repeated 
signal leakage). 
7 Section 312(f)(2) of the Act, 47 U.S.C. § 312(f)(2), which also applies to violations for which forfeitures are 
assessed under section 503(b) of the Act, provides that “[t]he term ‘repeated’, when used with reference to the 
commission or omission of any act, means the commission or omission of such act more than once or, if such 
commission or omission is continuous, for more than one day.” 
8 47 C.F.R. § 73.3526(a)(2).
9 47 C.F.R. § 73.3526(b).
10 47 C.F.R. § 73.3526(c).
11 The Commission’s Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the 
Forfeiture Guidelines, Report and Order,12 FCC Rcd 17087 (1997) (“Forfeiture Policy Statement”), recon. denied,
15 FCC Rcd 303 (1999); 47 C.F.R. §1.80.
12 47 U.S.C. § 503(b)(2)(E).
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the amount of $24,000 ($12,000 for Station WQQX and $12,000 for WQQW).  Our decision to upwardly 
adjust the base forfeiture amount by $2,000 for each station is influenced by our finding in another 
enforcement action issued today involving an inspection of two other stations owned by Entertainment 
Media Trust on the same day as the inspection here.13 That inspection found additional public inspection 
file violations at both stations, raising concerns that Entertainment Media Trust may have a systematic 
compliance issue with the Commission’s public inspection file rules.  We strongly encourage Entertainment 
Media Trust to review those rules closely and ensure that all of its facilities are in compliance.
IV. ORDERING CLAUSES
6. Accordingly, IT IS ORDERED that, pursuant to section 503(b) of the Communications 
Act of 1934, as amended, and sections 0.111, 0.311, 0.314 and 1.80 of the Commission’s Rules, 
Entertainment Media Trust, Dennis J. Watkins, Trustee, is hereby NOTIFIED of this APPARENT 
LIABILITY FOR A FORFEITURE in the amount of twenty-four thousand dollars ($24,000) for 
violations of section 73.3526 of the Rules.14
7. IT IS FURTHER ORDERED that, pursuant to section 1.80 of the Commission’s Rules 
within thirty days of the release date of this Notice of Apparent Liability for Forfeiture, Entertainment 
Media Trust, Dennis J. Watkins, Trustee, SHALL PAY the full amount of the proposed forfeiture or 
SHALL FILE a written statement seeking reduction or cancellation of the proposed forfeiture.
8. Payment of the forfeiture must be made by credit card, check or similar instrument, 
payable to the order of the Federal Communications Commission.  The payment must include the 
Account Number and FRN Number referenced above.  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 (payment type code).  Requests for full payment under an installment plan should be 
sent to: Chief Financial Officer — Financial Operations, 445 12th Street, S.W., Room 1-A625, 
Washington, D.C. 20554.8  If you have questions, please contact the Financial Operations Group Help 
Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov.  If payment is made, Entertainment Media 
Trust shall send electronic notification on the date said payment is made to NER-Response@fcc.gov.
9. The written statement seeking reduction or cancellation of the proposed forfeiture, if any, 
must include a detailed factual statement supported by appropriate documentation and affidavits pursuant 
to sections 1.80(f)(3) and 1.16 of the Rules.  The written statement, if any, must be mailed to Federal 
Communications Commission, Enforcement Bureau, Northeast Region, Chicago Office, 1550 North 
Northwest Highway, Room 306, Park Ridge, Illinois  60068 and must include the NAL/Acct. No. 
referenced in the caption.  The statement should also be emailed to NER-Response@fcc.gov.
10. The Commission will not consider reducing or canceling a forfeiture in response to a claim 
of inability to pay unless the petitioner submits:  (1) federal tax returns for the most recent three-year period; 
(2) financial statements prepared according to generally accepted accounting practices (“GAAP”); or (3) 
  
13 Entertainment Media Trust, Dennis J. Watkins, Trustee, Notice of Apparent Liability, DA 11- 900 (Enf. Bur. rel. 
May 19, 2011).
14 47 U.S.C. § 503(b), 47 C.F.R. §§ 0.111, 0.311, 0.314, 1.80, 73.3526.
8 See 47 C.F.R. § 1.1914.
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some other reliable and objective documentation that accurately reflects the petitioner’s current financial 
status.  Any claim of inability to pay must specifically identify the basis for the claim by reference to the 
financial documentation submitted.
11. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by both Certified Mail, Return Receipt Requested, and regular mail, to 
Entertainment Media Trust, Dennis J. Watkins, Trustee, at 6500 W. Main Street, Suite 315, Belleville, IL 
62223.
FEDERAL COMMUNICATIONS COMMISSION
James M. Roop
District Director
Chicago Office
Northeast Region
Enforcement Bureau