Federal Communications Commission DA 12-597 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Cebridge Acquisition, LP  
Honey Grove, Texas
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File No.:  EB-11-DL-0078
NAL/Acct. No.:  201232500007
FRN:  0014367650
System ID: 012049
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted:  April 17, 2012 Released:  April 17, 2012
By the District Director, Dallas Office, South Central Region, Enforcement Bureau:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (NAL), we find that Cebridge 
Acquisition, LP (Cebridge), operator of the cable television system in Honey Grove, Texas, apparently 
willfully violated Sections 76.605(a)(12) and 76.611(a)(1) of the Commission’s rules (Rules),1 by failing to 
prevent excessive signal leakage in the Honey Grove cable system.  We conclude that Cebridge is 
apparently liable for a forfeiture in the amount of eight thousand dollars ($8,000).  
II. BACKGROUND
2. On September 15, 2011, an agent from the Dallas Office of the Enforcement Bureau 
(Dallas Office) inspected the Honey Grove cable system and observed six leaks on the frequency 121.2625 
MHz.  All six leaks measured over 287 microvolts per meter (?V/m) at a distance of at least 3 meters; the 
highest leak measured at 2211.69 ?V/m.  The Cumulative Leakage Index (CLI) for all six of the measured 
leaks was calculated at 67.717.   
3. On September 16, 2011, the Dallas Office informed Cebridge that the Honey Grove system 
failed CLI testing and ordered Cebridge to shutdown until the signal leakage was eliminated.2 On 
September 27, 2011, Cebridge informed the Dallas Office via telephone that it had repaired all of the leaks 
found by the Dallas Office on September 15th and had brought the system’s CLI into compliance.  
III. DISCUSSION
4. Section 503(b) of the Communications Act of 1934, as amended (Act), 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.3  Section 312(f)(1) of the 
  
1 47 C.F.R. §§ 76.605(a)(12), 76.611(a)(1).
2 Section 76.613 of the Rules authorizes representatives of the Commission’s local field offices to direct cable 
operators to suspend operations immediately in the event of harmful interference to radio communications involving 
the safety of life and protection of property, until such interference has been eliminated.  47 C.F.R. § 76.613.
3 47 U.S.C. § 503(b).
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Act defines “willful” as the “conscious and deliberate commission or omission of [any] act, irrespective of 
any intent to violate” the law.4 The legislative history to Section 312(f)(1) of the Act clarifies that this 
definition of willful applies to both Sections 312 and 503(b) of the Act,5 and the Commission has so 
interpreted the term in the Section 503(b) context.6  The Commission may also assess a forfeiture for 
violations that are merely repeated, and not willful.7  The term “repeated” means the commission or 
omission of such act more than once or for more than one day.8  
A. Failure to Prevent Excessive Cable Signal Leakage
5. Protecting the aeronautical frequencies from harmful interference is of paramount 
importance.9 To this end, the Commission has established cable signal leakage rules to control emissions 
that could cause cable systems to interfere with aviation frequencies.10 The Commission determined the 
tolerable levels of unwanted signals on the aeronautical frequencies in two ways.  First, leakage at any 
given point must not exceed 20 µV/m.11 Second, cable systems must meet basic signal leakage 
performance criteria as a prerequisite for operation on aeronautical frequencies.  This is referred to as the 
system’s cumulative leakage index or “CLI.”  Signal leakage levels that exceed these aforementioned 
thresholds are considered harmful interference.  The Commission requires that each system annually 
measure its CLI (10 log IĄ) to demonstrate that any signal leakage is within permissible levels (i.e., a CLI 
of less than 64),12 the results of which must be reported to Commission.13 The rules also require cable 
  
4 47 U.S.C. § 312(f)(1).
5 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 . . . .”).
6 See, e.g., Application for Review of Southern California Broadcasting Co., Memorandum Opinion and Order, 6 
FCC Rcd 4387, 4388 (1991), recons. denied, 7 FCC Rcd 3454 (1992).
7 See, e.g., Callais Cablevision, Inc., Notice of Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359, 1362, 
para. 10 (2001) (Callais Cablevision, Inc.) (proposing a forfeiture for, inter alia, a cable television operator’s 
repeated signal leakage).
8 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.”  See Callais Cablevision, Inc., 16 FCC Rcd at 1362. 
9 The aeronautical bands are 108-137 MHz and 225-400 MHz.  These frequencies encompass both radionavigation 
frequencies, 108–118 MHZ and 328.6–335.4 MHz, and communications frequencies, 118–137 MHz, 225–
328.6 MHz, and 335.4–400 MHz.  The international distress and calling frequencies, 121.5 MHz, 156.8 MHz, and 
243 MHz, receive heightened protection.  See 47 C.F.R. § 76.616.  These frequencies are critical for Search and 
Rescue Operations, including for use by Emergency Locator Transmitters on planes and Emergency Position 
Indicating Radio Beacons on boats.  See generally 47 C.F.R. Part 80, Subpart V and 47 C.F.R. §§ 87.193–87.199.  
Harmful interference includes any interference that “endangers the functioning of a radionavigation service or of 
other safety services.”  See 47 C.F.R. §§ 2.1, 76.613(a).  See, e.g., Callais Cablevision, Inc., 16 FCC Rcd 1359 
(2001).    
10 See 47 C.F.R. §§ 76.601-76.617.  See also Amendment of Part 76 of the Commission’s Rules to Add Frequency 
Channelling Requirements and Restrictions and to Require Monitoring for Signal Leakage from Cable Television 
Systems, Memorandum Opinion and Order, 101 FCC 2d 117, 123, para. 14 (1985).
11 47 C.F.R. § 76.605(a)(12).
12 47 C.F.R. § 76.611(a).
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operators to provide for a program of regular monitoring of their systems to detect leaks.14 The cable 
system operator must promptly take measures to eliminate any harmful interference it causes,15 and must 
maintain a log for two years showing the date and location of each leakage source and the date on which the 
leakage was repaired.16
6. As discussed above, Section 76.605(a)(12) of the Rules states that signal leakage from a 
cable television system shall be limited to 20 µV/m at 3 meters,17 and Section 76.611(a)(1) of the Rules 
states that no cable television system shall provide service in the aeronautical radio bands unless the 
system’s CLI is less than 64.18  On September 15, 2011, agents from the Dallas Office measured six leaks 
on aeronautical frequencies that exceeded 287 µV/m at 3 meters in the Honey Grove cable system, which 
translates into a CLI of 67.717.19  Thus, based on the evidence before us, we find that Cebridge apparently 
willfully violated Sections 76.605(a)(12) and 76.611(a)(1) of the Rules by operating the Honey Grove  
cable system with excessive signal leakage.
B. Proposed Forfeiture
7. Pursuant to the Commission’s Forfeiture Policy Statement and Section 1.80 of the Rules, 
the base forfeiture for violation of rules relating to distress and safety frequencies is $8,000.20  Cable signal 
leakage in the aeronautical bands constitutes harmful interference to distress and safety frequencies.21  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, any history of prior offenses, ability to 
pay, and other such matters as justice may require.22 Applying the Forfeiture Policy Statement, Section 1.80 
of the Rules, and the statutory factors to the instant case, we conclude that Cebridge is apparently liable for a 
forfeiture in the amount of $8,000.
IV. ORDERING CLAUSES
8. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, and Sections 0.111, 0.204, 0.311, 0.314 and 1.80 of the Commission’s rules, 
Cebridge Acquisition, LP is hereby NOTIFIED of this APPARENT LIABILITY FOR A 
FORFEITURE in the amount of eight thousand dollars ($8,000) for violations of Sections 76.605(a)(12) 
and 76.611(a)(1) of the Commission’s rules.23
  
(...continued from previous page)
13 47 C.F.R. § 76.615(b)(7).
14 47 C.F.R. § 76.614.
15 47 C.F.R. § 76.613(b).
16 47 C.F.R. § 76.1706.
17 See 47 C.F.R. § 76.605(a)(12).
18 See 47 C.F.R. § 76.611(a)(1).
19 As previously noted, on September 27, 2011, Cebridge informed the Dallas Office that these leaks were corrected 
and the cable system’s CLI complied with the Rules.  
20 See 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), recons. denied, 
15 FCC Rcd 303 (1999); 47 C.F.R. § 1.80.
21 See 47 C.F.R. §§ 2.1, 76.613(a).
22 47 U.S.C. § 503(b)(2)(E).
23 47 U.S.C. § 503(b); 47 C.F.R. §§ 0.111, 0.204, 0.311, 0.314, 1.80, 76.605(a)(12), 76.611(a)(1).
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9. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Commission’s rules, 
within thirty (30) calendar days of the release date of this Notice of Apparent Liability for Forfeiture, 
Cebridge Acquisition, LP SHALL PAY the full amount of the proposed forfeiture or SHALL FILE a 
written statement seeking reduction or cancellation of the proposed forfeiture.
10. 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 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. 
20554.24  If you have questions regarding payment procedures, please contact the Financial Operations 
Group Help Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov.  Cebridge Acquisition, LP   
shall also send electronic notification on the date said payment is made to SCR-Response@fcc.gov.
11. 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.25 Mail the written statement to Federal Communications 
Commission, Enforcement Bureau, South Central Region, Dallas Office, 9330 LBJ Freeway, Suite 1170, 
Dallas, TX 75243, and include the NAL/Acct. No. referenced in the caption.  The statement should also 
be emailed to SCR-Response@fcc.gov.  
12. 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) 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. 
  
24 See 47 C.F.R. § 1.1914.
25 47 C.F.R. §§ 1.16, 1.80(f).
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13. 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 Cebridge 
Acquisition, LP at 12444 Powerscourt Drive, Suite 450, St. Louis, MO 63131.
FEDERAL COMMUNICATIONS COMMISSION
James D. Wells
District Director
Dallas Office
South Central Region
Enforcement Bureau