Federal Communications Commission DA 12-357
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Uniradio Corporation
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File No.:  EB-10-SE-145
Acct. No.: 201232100020
FRN:  0008982407
ORDER
Adopted:  March 14, 2012  Released:  March 14, 2012
By the Chief, Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (Bureau) of the Federal Communications Commission and Uniradio 
Corporation (Uniradio).  The Consent Decree resolves and terminates the Bureau’s investigation 
into Uniradio’s compliance with Section 325(c) of the Communications Act of 1934, as amended 
(Act),1 pertaining to the delivery of programming to a foreign broadcast station.  
2. The Bureau and Uniradio have negotiated a Consent Decree that resolves this 
matter.  A copy of the Consent Decree is attached hereto and incorporated herein 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 Uniradio 
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 Act,2 and 
Sections 0.111 and 0.311 of the Commission’s Rules,3 the Consent Decree attached to this Order 
IS ADOPTED.
  
1 47 U.S.C. § 325(c).
2 Id. § 154(i).
3 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 a copy of this Order and Consent Decree 
shall be sent by first class mail and certified mail, return receipt requested, to Ricardo Astiazaran, 
General Manager, Uniradio Corporation, 5030 Camino De La Siesta, Suite 403, San Diego, CA 
92108, and to Mark C. Del Bianco, Esq., Counsel for Uniradio Corporation, 3929 Washington 
Street, Kensington, MD 20895.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison 
Chief, Enforcement Bureau
Federal Communications Commission DA 12-357
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Uniradio Corporation
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)
)
)
)
File No.:  EB-10-SE-145
Acct. No.: 201232100020
FRN:  0008982407
CONSENT DECREE
The Enforcement Bureau of the Federal Communications Commission and Uniradio 
Corporation, by their authorized representatives, hereby enter into this Consent Decree for the 
purpose of terminating the Enforcement Bureau’s investigation into possible violations of Section 
325(c) of the Communications Act of 1934, as amended,4 pertaining to the delivery of 
programming to a foreign broadcast station.
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) “Communications Laws” means collectively, the Act, the Rules, and the 
published and promulgated orders and decisions of the Commission to 
which Uniradio is subject by virtue of its business activities, including but 
not limited to, the Licensing and Permitting Rules.
(f) “Compliance Plan” means the compliance obligations and compliance 
program described in this Consent Decree at paragraph 9.
(g) “Covered Employees” means all employees and agents of Uniradio who 
perform duties, or supervise, oversee, or manage the performance of duties 
that relate to Uniradio’s responsibilities under the Licensing and Permitting 
Rules.  
  
4 47 U.S.C. § 325(c).
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(h) “Effective Date” means the date on which the Bureau releases the Adopting 
Order.
(i) “Investigation” means the investigation commenced by the Bureau’s July 
25, 2011 letter of inquiry5 regarding Uniradio’s delivery of cross-border 
programming to Mexican broadcast station XERCN, Tijuana, Mexico. 
(j) “Licensing and Permitting Rules” means Section 325(c), Section 301of the 
Act, Section 1.949(a) of the Rules, and other Communications Laws that 
prohibit the use or operation of a wireless radio station or the delivery of 
programming to a foreign broadcast station without a valid authorization.
(k) “Operating Procedures” means the standard, internal operating procedures 
and compliance policies established by Uniradio to implement the 
Compliance Plan.
(l) “Parties” means Uniradio and the Bureau, each of which is a “Party.”
(m) “Rules” means the Commission’s regulations found in Title 47 of the Code 
of Federal Regulations.
(n) “Section 325(c)” means Section 325(c) of the Act, 47 U.S.C. § 325(c).
(o) “Uniradio” means Uniradio Corporation and its predecessors-in-interest and 
successors-in-interest.
II. BACKGROUND
2. Section 325(c) prohibits the transmission or delivery of programming from a 
broadcast studio, place or other apparatus within the United States to a broadcast station located 
in a foreign country that can be received consistently in the United States without first obtaining a 
permit from the Commission.6 The Commission reviews an application for a Section 325(c) 
permit under the same public interest, convenience, and necessity standard that is applied to 
applications for station licenses.7 Section 325(c) serves to prevent interference to broadcast 
stations’ signals as well as the introduction of broadcast material deemed inimical to the public 
interest, within the United States.8
  
5 See Letter from John D. Poutasse, Acting Chief, Spectrum Enforcement Division, Enforcement Bureau, 
Federal Communications Commission to Ricardo Astiazaran, General Manager, Uniradio Corporation 
(July 25, 2011).
6 See 47 U.S.C. § 325(c).
7 See 47 U.S.C. § 325(d); see also 47 U.S.C. § 309(a).
8 See American Broadcasting Cos., Inc., 35 FCC 2d 1, 5–6, para. 9 (1972); see also Fox Television 
Stations, Inc., 77 RR 2d 132, 133, 137–38, paras. 5, 30, 33–35 (1994), vacated and remanded on other 
grounds, Channel 51 of San Diego v. FCC, 79 F.3d 1187, 1188–89 (D.C. Cir. 1996), rev'd on remand, Fox 
Television Stations, Inc., 11 FCC Rcd 14870, 14875–78, paras. 16–25 (1996); aff'd sub nom, Radio 
Television S.A. de C.V. et al. v. FCC, 130 F.3d 1078 (D.C. Cir. 1997).
Federal Communications Commission DA 12-357
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3. On September 13, 2010, Uniradio filed a request for special temporary authority 
(STA Request) to deliver cross-border programming to Mexican broadcast station XERCN, 
Tijuana, Mexico (XERCN).9 In its STA Request, Uniradio voluntarily disclosed that it lacked 
authority for certain ongoing cross border transmissions of Spanish language programming to 
XERCN.  Uniradio further reported that it had discovered the previous week that an application 
prepared in May 2009 for the renewal of its Section 325(c) permit had not been filed with the 
Commission.10 Uniradio submitted an application for a new Section 325(c) permit on September 
14, 2010.  The International Bureau granted the STA Request on September 22, 201011 and 
granted Uniradio’s application for a new Section 325(c) permit on November 2, 2010.12 The 
International Bureau subsequently referred Uniradio’s apparent violation to the Bureau for 
investigation and possible enforcement action.
4. On July 25, 2011, the Bureau’s Spectrum Enforcement Division issued the letter 
of inquiry (LOI) to Uniradio, directing the company to submit a sworn written response to a 
series of questions regarding its compliance with Section 325(c).13 Uniradio responded to the 
LOI on August 19, 2011 (LOI Response).14 In the LOI Response, Uniradio confirmed the 
information previously submitted in its STA request regarding certain unauthorized foreign 
transmissions, but claimed that it filed both the STA Request and the application for a new 
Section 325(c) permit promptly after discovering the issue.15 The Bureau and Uniradio 
subsequently entered into tolling agreements to toll the statute of limitations.16  
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.
  
9 See Letter from Mark C. Del Bianco, Counsel for Uniradio, to Marlene H. Dortch, Secretary, Federal 
Communications Commission (Sept. 13, 2010) (File No. 325-STA-20100913-00005).  
10 Id. at 1.
11 See Permit to Deliver Programs to Foreign Broadcast Stations, Re: Actions Taken, Public Notice, Report 
No. 325-00156 (Sept. 22, 2010), available at http://licensing.fcc.gov/ibfsweb/ib.page.FetchPN? 
report_key=840663, amended, Report No. 325-00159 (Oct. 13, 2010), available at http://licensing.fcc.gov/ 
ibfsweb/ib.page.FetchPN?report_key=844838.
12 See Permit to Deliver Programs to Foreign Broadcast Stations, Re: Actions Taken, Public Notice, Report 
No. 325-00160 (Nov. 2, 2010), available at 
http://licensing.fcc.gov/ibfsweb/ib.page.FetchPN?report_key=849250.
13 See supra note 2.    
14 See Letter from Mark C. Del Bianco, Counsel for Uniradio Corporation, to John D. Poutasse, Acting 
Chief, Spectrum Enforcement Division, Enforcement Bureau, Federal Communications Commission (Aug. 
19, 2011).
15 LOI Response at 1.
16 See, e.g., Tolling Agreement Extension, File No. EB-10-SE-145, executed by and between John D. 
Poutasse, Acting Chief, Spectrum Enforcement Division, Enforcement Bureau, Federal Communications 
Commission, and Ricardo Astiazaran, General Manager, Uniradio Corporation (Dec. 13, 2011).
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6. Jurisdiction.  Uniradio agrees that the Bureau has jurisdiction over it and the 
matters contained in this Consent Decree and that the Bureau 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 Effective Date as defined herein.  As of the Effective Date, the Adopting 
Order and this Consent Decree shall have the same force and effect as any other order of the 
Commission.  Any violation of the Adopting Order or of the terms of this Consent Decree shall 
constitute a separate violation of a Commission order, entitling the Commission 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 the Investigation.  In consideration for the termination of the 
Investigation, Uniradio 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 the Investigation through the Effective Date, 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 Uniradio concerning the matters that were the subject of the 
Investigation.  The Bureau also agrees that in the absence of new material evidence it will not use 
the facts developed in the Investigation through the Effective Date, 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 Uniradio with respect to Uniradio’s basic qualifications, 
including its character qualifications, to be a Commission licensee or to hold Commission 
licenses or authorizations.  
9. Compliance Plan.  For purposes of settling the matters set forth herein, Uniradio 
agrees that it shall within sixty (60) calendar days after the Effective Date, develop and 
implement a Compliance Plan to help ensure future compliance with the Communications Laws, 
including the Licensing and Permitting Rules, and with the terms and conditions of this Consent 
Decree.  The Compliance Plan shall include, without limitation, the following components:
(a) Compliance Officer.  Within thirty (30) calendar days after the Effective 
Date, Uniradio shall designate a senior corporate manager with the requisite 
corporate and organizational authority to serve as Compliance Officer and to 
discharge the duties set forth below.  The person designated as the 
Compliance Officer shall be responsible for developing, implementing, and 
administering the Compliance Plan and ensuring that Uniradio complies with 
the terms and conditions of the Compliance Plan and this Consent Decree.  In 
addition to the general knowledge of the Communications Laws necessary to 
discharge his/her duties under this Consent Decree, the Compliance Officer 
shall have specific knowledge of the Licensing and Permitting Rules prior to 
assuming his/her duties.  In addition, the Compliance Officer shall have 
reviewed and be familiar with the conditions imposed by the Commission in 
all Section 325(c) permits issued to Uniradio.
(b) Operating Procedures.  Within sixty (60) calendar days after the Effective 
Date, Uniradio shall establish Operating Procedures that all Covered 
Employees must follow to help ensure Uniradio’s compliance with the 
Licensing and Permitting Rules.  As part of the Operating Procedures, the 
Federal Communications Commission DA 12-357
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Compliance Officer shall designate a Covered Employee to be responsible 
for developing and maintaining a database of all licenses, permits, and other 
authorizations issued to Uniradio by the Commission, including all permits 
issued to Uniradio pursuant to Section 325(c), and the expiration date of each 
such authorization.  The Compliance Officer shall ensure that Uniradio 
timely files an application for renewal of any license, permit, or authorization 
for which renewal is required under the Licensing and Permitting Rules.  
Uniradio shall also adopt Operating Procedures to ensure regular monitoring 
of its compliance with the conditions imposed by its Section 325(c) permits 
and other licenses and authorizations. 
(c) Compliance Manual.  Within sixty (60) calendar days after the Effective 
Date, the Compliance Officer shall develop and distribute a Compliance 
Manual to all Covered Employees.  The Compliance Manual shall explain 
the requirements of the Licensing and Permitting Rules, and shall set forth 
the Operating Procedures that Covered Employees shall follow to help 
ensure compliance with such requirements.  In addition, the Compliance 
Manual shall set forth the Operating Procedures that Covered Employees 
shall follow to help ensure Uniradio’s compliance with the conditions 
imposed by its Section 325(c) permits.  Uniradio shall periodically review 
and revise the Compliance Manual as necessary to ensure that the 
information set forth therein remains current and complete.  Uniradio shall 
distribute any revisions to the Compliance Manual promptly to all Covered 
Employees.
(d) Compliance Training.  Within sixty (60) calendar days after the Effective 
date, Uniradio shall establish and implement a Compliance Training Program 
on compliance with the Licensing and Permitting Rules and the Operating 
Procedures.  As part of the Compliance Training Program, Covered 
Employees shall be advised of Uniradio’s obligation to report any 
noncompliance with the Licensing and Permitting Rules under paragraph 10 
of this Consent Decree and shall be instructed on how to disclose 
noncompliance to the Compliance Officer.  All Covered Employees shall be 
trained pursuant to the Compliance Training Program within sixty (60) 
calendar days after the Effective Date, except that any person who becomes a 
Covered Employee at any time after the Effective Date shall be trained 
within thirty (30) calendar days after the date such person becomes a 
Covered Employee.  Uniradio shall repeat the compliance training on an 
annual basis, and shall periodically review and revise the Compliance 
Training Program as necessary to ensure that it remains current and complete 
and to enhance its effectiveness.
(e) Termination Date.  Unless stated otherwise, the requirements of this 
paragraph 9 of the Consent Decree shall expire twenty-four (24) months after 
the Effective Date.
10. Reporting Noncompliance. Uniradio shall report any noncompliance with the 
Licensing and Permitting Rules and any noncompliance with the terms and conditions of this 
Consent Decree within fifteen (15) calendar days after discovery of such noncompliance.  Such 
reports shall include a detailed explanation of (i) each instance of noncompliance; (ii) the steps 
Federal Communications Commission DA 12-357
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that Uniradio has taken or will take to remedy such noncompliance; (iii) the schedule on which 
such remedial actions will be taken; and (iv) the steps that Uniradio has taken or will take to 
prevent the recurrence of any such noncompliance.  All reports of noncompliance shall be 
submitted to the Chief, Spectrum Enforcement Division, Enforcement Bureau, Federal 
Communications Commission, Room 3-C366, 445 12th Street, S.W. Washington, D.C. 20554, 
with a copy submitted electronically to Kevin Pittman at Kevin.Pittman@fcc.gov and to 
Daudeline Meme at Daudeline.Meme@fcc.gov.  The reporting obligations set forth in this 
paragraph 10 shall expire twenty-four (24) months after the Effective Date.      
11. Compliance Reports.  Uniradio shall file Compliance Reports with the 
Commission ninety (90) calendar days after the Effective Date, twelve (12) months after the 
Effective Date, and twenty-four (24) months after the Effective Date.
(a) Each compliance report shall include a detailed description of Uniradio’s 
efforts during the relevant period to comply with the Licensing and 
Permitting Rules, and with the terms and conditions of this Consent Decree.  
In addition, each Compliance Report shall include a certification by the 
Compliance Officer, as an agent of and on behalf of Uniradio, stating that the 
Compliance Officer has personal knowledge that Uniradio (i) has established 
and implemented the Compliance Plan; (ii) has utilized the Operating 
Procedures since the implementation of the Compliance Plan; and (iii) is not 
aware of any instances of noncompliance with the terms and conditions of 
this Consent Decree, including the reporting obligations set forth in 
paragraph 10 hereof.
(b) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and must comply with Section 1.16 
of the Rules17 and be subscribed to as true under penalty of perjury in 
substantially the form set forth therein.
(c) If the Compliance Officer cannot provide the requisite certification, the 
Compliance Officer, as an agent of and on behalf of Uniradio, shall provide 
the Commission with a detailed explanation of the reason(s) why and 
describe fully (i) each instance of noncompliance; (ii) the steps that Uniradio 
has taken or will take to remedy such noncompliance, including the schedule 
on which proposed remedial actions will be taken; and (iii) the steps that 
Uniradio has taken or will take to prevent the recurrence of any such 
noncompliance, including the schedule on which such preventive action will 
be taken.
(d) 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, with a copy 
submitted electronically to Kevin Pittman at Kevin.Pittman@fcc.gov and to 
Daudeline Meme at Daudeline.Meme@fcc.gov.
12. Voluntary Contribution.  Uniradio agrees that it will make a voluntary 
contribution to the United States Treasury in the amount of nine thousand dollars ($9,000), such 
  
17 47 C.F.R. § 1.16.
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Voluntary Contribution to be made in three equal payments (each an Installment Payment) of 
three thousand dollars ($3,000).   The first Installment Payment is due within thirty (30) calendar 
days of the Effective Date, the second Installment Payment is due within six (6) months after the 
Effective Date, and the final Installment Payment is due within twelve (12) months after the 
Effective Date (Maturity Date).  Uniradio acknowledges and agrees that upon execution of this 
Consent Decree, the Voluntary Contribution and each Installment Payment shall become a 
“Claim “ or “Debt” as defined in 31 U.S.C. § 3701(b)(1).18 Upon an Event of Default, all 
procedures for collection permitted by law may, at the Commission’s discretion, be initiated.  In 
addition, Uniradio agrees that it will make the first and all subsequent Installment Payments in 
United States Dollars without further demand or notice by the dates specified above.  Installment 
Payments must be made by check or similar instrument, payable in United States Dollars to the 
order of the Federal Communications Commission.  The payments must include the Account 
Number and FRN referenced in the caption to the Adopting Order.  Payments by check or money 
order may be mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 
63197-9000.  Payments by overnight mail may be sent to U.S. Bank – Government Lockbox 
#979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.  Payments by wire 
transfer may be made to ABA Number 021030004, receiving bank TREAS/NYC, and Account 
Number 27000001.  For payments 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).  
Uniradio shall also send electronic notification to Kevin Pittman at Kevin.Pittman@fcc.gov, 
Daudeline Meme at Daudeline.Meme@fcc.gov, and Samantha Peoples at Sam.Peoples@fcc.gov. 
on the date each payment is made.
13. Event of Default.  Uniradio agrees that an Event of Default shall occur upon the 
failure by Uniradio to pay the full amount of any Installment Payment on or before the due date 
specified in this Consent Decree.
14. Interest, Charges for Collection, and Acceleration of Maturity Date.  Upon 
an Event of Default under this Consent Decree, the then unpaid amount of the Voluntary 
Contribution shall accrue interest, computed using the rate of the U.S. Prime Rate in effect on the 
date of the Event of Default, plus 4.75 percent, from the date of the Event of Default until 
payment in full.  Upon an Event of Default, the then unpaid amount of the Voluntary 
Contribution, together with interest, as aforesaid, any penalties permitted and/or required by the 
law, including but not limited to 31 U.S.C. § 3717 and administrative charge(s), plus the costs of 
collection, litigation, and attorneys’ fees, shall become immediately due and payable, without 
notice, presentment, demand, protest, or notice of protest of any kind, all of which are waived by 
Uniradio.
15. Waivers.  Uniradio 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 an Adopting 
Order as defined herein.  Uniradio 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 
Uniradio nor the Commission shall contest the validity of the Consent Decree or of the Adopting 
Order, and Uniradio shall waive any statutory right to a trial de novo.  Uniradio hereby agrees to 
  
18 Debt Collection Improvement Act of 1996, Pub. L. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996).
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waive any claims it may 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.
16. 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.
17. 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 Uniradio does 
not expressly consent) that provision will be superseded by such Rule or Commission order.
18. Successors and Assigns.  Uniradio agrees that the provisions of this Consent 
Decree shall be binding on its successors, assigns, and transferees.  
19. Final Settlement.  The Parties agree and acknowledge that this Consent Decree 
shall constitute a final settlement between the Parties with respect to the Investigation.  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 Communications Laws.
20. Modifications.  This Consent Decree cannot be modified without the advance 
written consent of both Parties.
21. 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.
22. Authorized Representative.  The individual signing this Consent Decree on 
behalf of Uniradio represents and warrants that he is authorized by Uniradio to execute this 
Consent Decree and to bind Uniradio to the obligations set forth herein.  The FCC signatory 
represents that he is signing this Consent Decree in his official capacity and that he is authorized 
to execute this Consent Decree.
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23. 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.
_______________________________
John D. Poutasse
Acting Chief
Spectrum Enforcement Division
Enforcement Bureau
________________________________
Date
________________________________
Ricardo Astiazaran 
General Manager
Uniradio Corporation
________________________________
Date