Federal Communications Commission DA 13-1651
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Regent Broadcasting of El Paso, Inc. Debtor-in-
Possession
Former Licensee of Stations KLAQ(FM) and 
KROD(AM), El Paso, Texas
and 
Townsquare Media of El Paso, Inc.
Successor-in-Interest and Licensee of Stations 
KLAQ(FM) and KROD(AM), El Paso, Texas
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
File Number:  EB-10-IH-2145
NAL/Acct. No.:  201332080026
FRN:  0010632628
Facility ID Nos.:  48670 and 14908
ORDER
Adopted:  July 29, 2013 Released:  July 29, 2013
By the Acting Chief, Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (Bureau) and Townsquare Media of El Paso, Inc. (Townsquare El Paso).  The 
Consent Decree resolves and terminates the Bureau’s investigation into possible violations of Section 317 
of the Communications Act of 1934, as amended (Act), and Section 73.1212 of the Commission’s rules 
(Rules),1 in connection with the apparent failure by Regent Broadcasting of El Paso, Inc., Debtor-in-
Possession (Regent), the prior licensee, to properly disclose the sponsor of paid advertisements broadcast 
on Stations KLAQ(FM) and KROD(AM), El Paso, Texas (Stations) in 2010.  Townsquare El Paso 
assumed liability for the outcome of the Bureau’s investigation.2
2. The Bureau and Townsquare El Paso have negotiated the terms of the Consent Decree 
that resolves this matter, including a detailed, three-year compliance plan requirement.  A copy of the 
Consent Decree is attached hereto and incorporated by reference.  
  
1 See 47 C.F.R. § 73.1212.
2 Regent Broadcasting of El Paso, Inc., Debtor-in-Possession is not currently a Commission licensee but was a 
licensee and subject to these same laws at the time of the conduct at issue herein.  Townsquare El Paso’s corporate 
family acquired the Stations by assignment consummated July 1, 2010 and as part of that assignment, through Town 
Square Media, LLC agreed to accept liability for potential violations resulting from complaints (including those 
covered by this Order) that were pending against the Stations at the time of the assignment.  Those complaints, 
which included the instant Complaints, prompted inquiry with respect to Regent’s compliance with certain of the 
Commission’s rules but did not raise questions with respect to its basic qualifications.
Federal Communications Commission DA 13-1651
2
3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest will 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 Townsquare El Paso 
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 Sections 4(i), 4(j), and 503(b) of the 
Communications Act of 1934, as amended,3 and Sections 0.111 and 0.311 of the Rules,4 the Consent 
Decree attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation, as to the Stations 
and/or Townsquare El Paso, IS TERMINATED.
7. IT IS FURTHER ORDERED that any third-party complaints and allegations against 
the Station and/or Townsquare El Paso before the Enforcement Bureau related to the above-captioned 
investigation as of the date of this Consent Decree ARE DISMISSED.
8. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be
sent by both First Class U.S. Mail and Certified Mail, Return Receipt Requested, to Townsquare El 
Paso’s counsel, Howard Liberman, Esq. and Alisa Lahey, Esq., Drinker Biddle & Reath LLP, 1500 K 
Street, N.W., Washington, D.C.  20005-1209, and to the complainant.
FEDERAL COMMUNICATIONS COMMISSION
Robert H. Ratcliffe
Acting Chief, Enforcement Bureau
  
3 See 47 U.S.C. §§ 154(i), 154(j), 503(b).  
4 See 47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 13-1651
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Regent Broadcasting of El Paso, Inc. Debtor-in-
Possession
Former Licensee of Stations KLAQ(FM) and 
KROD(AM), El Paso, Texas
and 
Townsquare Media of El Paso, Inc.
Successor-in-Interest and Licensee of Stations 
KLAQ(FM) and KROD(AM), El Paso, Texas
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
File Number:  EB-10-IH-2145
NAL/Acct. No.: 201332080026
FRN:  0010632628
Facility ID Nos.:  48670 and 14908
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission (Bureau) and 
Townsquare Media of El Paso, Inc., by their authorized representatives, hereby enter into this Consent 
Decree for the purpose of terminating the Bureau’s investigation into possible violations of Section 317 of 
the Communications Act of 1934, as amended, and Section 73.1212 of the Commission’s Rules1
pertaining to sponsorship identification.
I.         DEFINITIONS
2. 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 the 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 
each Commission licensee, including Townsquare El Paso, is subject by virtue of 
  
1 See 47 U.S.C. § 317; 47 C.F.R. § 73.1212.
Federal Communications Commission DA 13-1651
2
it being a Commission licensee, including but not limited to Section 317 of the 
Act and Section 73.1212 of the Commission’s Rules.2
(f) “Complainant” means the individual transmitting and filing the third-party 
Complaints received by, or in the possession of, the Bureau and alleging
violation of Section 317 of the Act and/or Section 73.1212 of the Sponsorship ID 
Laws, as described in this Consent Decree at paragraph 4.
(g) “Complaints” means the third-party complaint(s) alleging violation of the 
Commission’s Sponsorship ID laws and received by, or in the possession of, the 
Bureau, as described in this Consent Decree at paragraph 4.  
(h) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 11.
(i) “Covered Employees” means all employees and agents of Townsquare El Paso 
who perform, supervise, oversee, and/or manage the performance of duties that 
relate to Townsquare El Paso’s responsibilities under the Sponsorship ID Laws, 
including those employees and agents who serve as on-air talent and/or 
materially participate in the on-air broadcast of program material and/or in the 
making of programming decisions, as well as their supervisory employees and 
agents.
(j) “Effective Date” means the date on which the Bureau releases the Adopting 
Order.
(k) “Investigation” means the investigation commenced by the Bureau’s June 30, 
2010 Letter of Inquiry regarding whether Regent violated the 
Sponsorship ID Laws.
(l) “Operating Procedures” means the standard, internal operating procedures and 
compliance policies established by Townsquare El Paso to implement the 
Compliance Plan.
(m) “Parties” means Townsquare El Paso and the Bureau, each of which is a “Party.”
(n) “Regent” means Regent Broadcasting of El Paso, Inc. Debtor-in-Possession, the  
former licensee of the Stations, and its successors-in-interest before July 1, 
2010.3
  
2 Regent Broadcasting of El Paso, Inc. Debtor-in-Possession is not currently a Commission licensee but was a 
licensee and subject to these same laws at the time of the conduct at issue herein.  Townsquare El Paso’s corporate 
family acquired the Stations by assignment consummated July 1, 2010, and as part of that assignment, through 
Town Square Media, LLC, agreed to accept liability for potential violations resulting from complaints (including the 
instant Complaints) that were pending against the Stations at the time of the assignment.  Those complaints, which 
included the instant Complaints, prompted inquiry with respect to Regent’s compliance with certain of the 
Commission’s rules but did not raise questions with respect to its basic qualifications.
3 On July 1, 2010, Townsquare Media, LLC became the Stations’ corporate parent.  See supra note 2.
Federal Communications Commission DA 13-1651
3
(o) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(p) A “Sponsored Broadcast” is matter transmitted by a broadcast station that is aired 
in exchange for valuable consideration that is “directly or indirectly paid or 
promised to or charged or accepted by, the station so broadcasting,” especially 
the types of broadcasts covered by Section 73.1212(f) of the Commission’s 
Rules.
(q) “Sponsorship ID Laws” means, individually or collectively, Section 
317 of the Act and Section 73.1212 of the Commission’s Rules.
(r) “Stations” means Station KLAQ(FM), El Paso, Texas (Facility ID 48670) 
and Station KROD(AM), El Paso, Texas (Facility ID 14908), each a “Station.”
(s) “Townsquare El Paso” means Townsquare Media of El Paso, Inc.;4 its corporate 
family, including Town Square Media, LLC; and Townsquare El Paso’s 
successors-in-interest.
II. BACKGROUND
3. The Sponsorship ID Laws establish the general obligation of a broadcast station to air 
sponsorship identification announcements whenever any “money, service or other valuable 
consideration”5 is paid or promised to the station for the broadcast of program material.6 The 
Commission has noted that the Sponsorship ID Laws are “grounded in the principle that listeners and 
viewers are entitled to know who seeks to persuade them”7 and has warned that it would take enforcement 
action against broadcast stations and cable operators that did not comply with these disclosure 
requirements.8 Stations are exempt from making sponsorship identification announcements in certain 
circumstances, but these exemptions do not apply when the consideration paid or promised to a station is 
in the form of “money.”9 Section 73.1212(f) states that “[i]n the case of broadcast matter advertising 
commercial products or services,” the licensee must broadcast “an announcement stating the sponsor’s 
corporate or trade name, or the name of the sponsor’s product . . . .”10 That section also provides that in 
such circumstances, “when it is clear that the mention of the name of the product constitutes a 
sponsorship identification, [the name of the product] shall be deemed sufficient” to comply with the 
Sponsorship ID Laws.11 In this case, Regent failed to mention the “sponsor’s corporate or trade name, or 
the name of the sponsor’s product,”12 in violation of the Sponsorship ID Laws.
  
4 See supra note 2.
5 47 U.S.C. § 317(a)(1).  See also 47 C.F.R. §§ 73.1212(a). 
6 See 47 U.S.C. § 317(a)(1); 47 C.F.R. §§ 73.1212(a).
7 Commission Reminds Broadcast Licensees, Cable Operators and Others of Requirements Applicable to Video 
News Releases and Seeks Comment on the Use of Video News Releases by Broadcast Licensees and Cable 
Operators, Public Notice, 20 FCC Rcd 8593, 8593–94 (2005). 
8 See, e.g., id.
9 See id. 
10 47 C.F.R. § 73.1212(f).
11 Id.
12 Id.
Federal Communications Commission DA 13-1651
4
4. The Bureau received Complaints, which alleged that Station KLAQ(FM) aired 
advertisements that failed to identify the sponsor of the advertisement and the product advertised.13 The 
Complaints alleged that the advertisements were sponsored by The Cigarette Outlet, and that the Station 
intentionally omitted the sponsor of the announcements, whose name contains the word “cigarette,” from 
the advertisements in order to avoid violating Section 73.4055 of the Commission’s Rules and 15 U.S.C § 
1335, both of which prohibit the broadcast of cigarette advertisements.14
5. The Bureau issued a letter of inquiry (LOI) on June 30, 2010 regarding the issues raised 
in the Complaints.15 In its response to the LOI,16 Regent confirmed that both KLAQ(FM) and 
KROD(AM) had received money from The Cigarette Outlet as payment for the Stations’ broadcast of 
advertisements for The Cigarette Outlet store and that the Stations broadcast the subject advertisements.17  
Regent further confirmed that the Stations omitted both the word “cigarette” and the name “The Cigarette 
Outlet” from those advertisements.18 Regent acknowledged the applicability of the Commission’s 
Sponsorship ID Laws to The Cigarette Outlet’s advertisements but effectively denied violating those 
Laws by arguing that it was unnecessary to include the advertiser’s full name in the announcements 
because the “identity of each [a]dvertisement’s sponsor and the fact of sponsorship of its business were 
obvious”19 due to the advertisements’ inclusion of the address and phone number of The Cigarette Outlet, 
as well as directions to its only store.20 The Bureau disagrees with this assertion.
III. TERMS OF AGREEMENT
6. 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.
7. Jurisdiction.  Townsquare El Paso 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.
  
13 See Complaint from Robert King to Hillary DeNigro, Chief, Investigations and Hearings Division, FCC 
Enforcement Bureau (Apr. 12, 2010) (on file in EB-10-IH-2145); Complaint from Robert King to Hillary DeNigro, 
Chief, Investigations and Hearings Division, FCC Enforcement Bureau  (Apr. 21, 2010) (on file in EB-10-IH-2145); 
E-mail from Robert King to Hillary DeNigro, Chief, Investigations and Hearings Division, FCC Enforcement 
Bureau (Apr. 28, 2010, 14:37 EDT) (on file in EB-10-IH-2145).  
14 See 15 U.S.C. § 1335; 47 C.F.R. § 73.4055; supra note 13. 
15 See Letter from Anjali K. Singh, Acting Assistant Chief, Investigations and Hearings Division, FCC Enforcement 
Bureau to Regent Trust (June 30, 2010) (on file in EB-10-IH-2145).  Regent Trust was the licensee of the Stations 
from April 27, 2010 (See FCC File No. BALH-20100323AHU) until July 1, 2010 (See FCC File No. BALH-
20100232ACK). 
16 See Letter from Mark B. Denbo, Counsel to Regent Broadcasting of El Paso, Inc., to Marlene H. Dortch, 
Secretary, Federal Communications Commission at 1–2 (July 30, 2010) (on file in EB-10-IH-2145). 
17 See id. at 3, Ex. 4.  
18 See id. at 4.
19 Id. 
20 See id. 
Federal Communications Commission DA 13-1651
5
8. 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.
9. 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, Townsquare El Paso
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, 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 Townsquare El Paso 
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 Townsquare El Paso with respect to its
basic qualifications, including its character qualifications, to be a Commission licensee or to hold 
Commission licenses or authorizations.
10. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, 
Townsquare El Paso 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 Townsquare El Paso 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 Sponsorship ID Laws prior to assuming his/her duties and 
shall commit to enforcing high standards with respect to the Sponsorship ID Laws to avoid violations.
11. Compliance Plan.  For purposes of settling the matters set forth herein, Townsquare El 
Paso agrees that it shall, within sixty (60) calendar days of the Effective Date, develop and implement a 
Compliance Plan designed to ensure future compliance with the Communications Laws and with the 
terms and conditions of this Consent Decree.  With respect to the Sponsorship ID Laws, Townsquare El 
Paso shall implement the following procedures: 
(a) Operating Procedures for broadcasts subject to the Sponsorship ID Laws.  
Within sixty (60) calendar days after the Effective Date, Townsquare El Paso 
shall establish Operating Procedures that all Covered Employees must follow to 
help ensure Townsquare El Paso’s compliance with the Sponsorship ID Laws.  
Townsquare El Paso’s Operating Procedures shall include internal procedures 
and policies specifically designed to ensure that Townsquare El Paso discloses 
the sponsorship status and the sponsor of broadcasts that are aired in exchange 
for valuable consideration or otherwise require sponsorship identification, 
consistent with Section 317 of the Act and Section 73.1212 of the Commission’s 
Rules.  Townsquare El Paso also shall develop a Compliance Checklist that 
describes the steps that a Covered Employee must follow to ensure that 
Sponsored Broadcasts will not result in a violation of the Communications Laws 
regarding sponsorship ID.  At a minimum, the Compliance Checklist shall 
Federal Communications Commission DA 13-1651
6
require a multi-level review of Sponsored Broadcasts that air over the Station.  
All scripts of announcements shall be reviewed prior to broadcast for compliance 
with the Sponsorship ID Laws by at least two station employees, one of whom 
shall be a management-level employee.
(b) Compliance Manual.  Within sixty (60) calendar days after the Effective Date, 
the Compliance Officer (with assistance of counsel as appropriate) shall develop 
and distribute a Compliance Manual to all Covered Employees.  The Compliance 
Manual shall explain the Sponsorship ID Laws and set forth the Operating 
Procedures that Covered Employees shall follow to help ensure Townsquare El 
Paso’s compliance with the Communications Laws.  Townsquare El Paso shall 
periodically review and revise the Compliance Manual as necessary to ensure 
that the information set forth therein remains current and complete.  Townsquare 
El Paso shall distribute any revisions to the Compliance Manual promptly to all 
Covered Employees.
(c) Compliance Training Program.  Townsquare El Paso shall establish and 
implement a Compliance Training Program on compliance with the Sponsorship 
ID Laws and the Operating Procedures.  As part of the Compliance Training 
Program, Covered Employees shall be advised of Townsquare El Paso’s 
obligation to report any noncompliance with the Sponsorship ID Laws under 
paragraph 12 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 ninety (90) 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.  
Townsquare El Paso 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.
(i) Hotline.  The Compliance Officer shall maintain a hotline for 
employees to call the Compliance Officer to obtain advice on 
compliance with the Compliance Plan and report violations of 
the Compliance Plan.
(ii) Contractual Agreements.  Townsquare El Paso will ensure that 
all contractual agreements with respect to Covered Employees 
shall include a contractual clause relating to compliance with the 
Sponsorship Identification Laws.
(iii) Commitment to High Standards for the Identification of 
Program Sponsors and the Airing of Sponsored Content.  
Townsquare El Paso commits to enforcing high standards with 
respect to the Sponsorship ID Laws to avoid violations.
(d) Sponsor Education.  Townsquare El Paso will also implement and maintain a 
plan to educate prospective sponsors about appropriate sponsorship content and 
how it incorporates such sponsorship content in the messages that it prepares for 
Federal Communications Commission DA 13-1651
7
the sponsor’s approval and eventual broadcast.  To that end, Townsquare El Paso 
will summarize the Sponsorship ID Laws for each client prior to accepting any 
contract to air messages over the Station and preparing the message for the 
sponsor’s review.  Townsquare El Paso will not broadcast any announcement that 
does not comply with the Sponsorship ID Laws.
(e) Annual Report.  The Compliance Officer shall submit reports to the 
Townsquare El Paso’s Board of Directors concerning the Townsquare El Paso’s 
compliance with this Compliance Plan.  The first such report shall be submitted 
within sixty (60) days of the Effective Date and additional reports shall be 
submitted at least annually thereafter.
12. Reporting Noncompliance.  Townsquare El Paso shall report any noncompliance with 
the Sponsorship ID Laws, and with the terms and conditions of this Consent Decree within thirty (30) 
calendar days after discovery of such noncompliance.  Such reports shall include a detailed explanation of 
(i) each instance of noncompliance; (ii) the steps that Townsquare El Paso 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 Townsquare El Paso has taken or will take to prevent the recurrence of any such 
noncompliance.  All reports of noncompliance shall be submitted to the Chief, Investigations and 
Hearings Division, Enforcement Bureau, Federal Communications Commission, Room 4-C330, 445 12th 
Street, S.W., Washington, DC 20554, with a copy submitted electronically to Theresa Z. Cavanaugh at 
Terry.Cavanaugh@fcc.gov, Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, Anjali Singh at 
Anjali.Singh@fcc.gov, and Judy Lancaster at Judy.Lancaster@fcc.gov. 
13. Compliance Reports.  Townsquare El Paso shall file Compliance Reports with the 
Commission ninety (90) days after the Effective Date, twelve (12) months after the Effective Date, 
twenty-four (24) months after the Effective Date, and thirty-six (36) months after the Effective Date.
(a) Each Compliance Report shall include a detailed description of Townsquare El 
Paso’s efforts during the relevant period to comply with the terms and conditions 
of this Consent Decree and the Sponsorship ID Laws.  In addition, each 
Compliance Report shall include a certification by the Compliance Officer, as an 
agent of and on behalf of Townsquare El Paso, stating that the Compliance 
Officer has personal knowledge that Townsquare El Paso (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 paragraphs 11 and 12 
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 Rules21 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 Townsquare El Paso, shall 
provide the Commission with a detailed explanation of the reason(s) why and 
  
21 47 C.F.R. § 1.16.
Federal Communications Commission DA 13-1651
8
describe fully:  (i) each instance of noncompliance; (ii) the steps that Townsquare 
El Paso has taken or will take to remedy such noncompliance, including the 
schedule on which proposed remedial action will be taken; and (iii) the steps that 
Townsquare El Paso 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, Investigations and 
Hearings Division, Enforcement Bureau, Federal Communications Commission, 
Room 4-C330, 445 12th Street, S.W., Washington, DC 20554, with a copy 
submitted electronically to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov, 
Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, Anjali Singh at Anjali.Singh@fcc.gov, 
and Judy Lancaster at Judy.Lancaster@fcc.gov. 
14. FCC Enforcement Actions.  If, as a result of a possible future violation of the 
Sponsorship ID Laws at one of its Stations, Townsquare El Paso receives a Notice of Apparent Liability 
or similar Bureau document proposing a forfeiture, a Bureau document contemplating license non-
renewal or revocation, or a Forfeiture, Townsquare El Paso shall: 
(a)  suspend each employee accused of violating the Sponsorship ID Laws and   
undertake an investigation of each such incident; 
(b) require that each such employee receive remedial training on the Sponsorship ID 
Laws and the Compliance Plan and successfully demonstrate to the Compliance 
Officer and Station management that he or she understands such regulations and 
policies before allowing such employee to resume his or her duties;
(c) take disciplinary action, up to and including termination, against each employee who 
is materially involved in the violation of the Sponsorship ID Laws, if such violation 
results in a final adjudication by the Commission that Townsquare El Paso violated 
the Sponsorship ID Laws.
15. Termination Date.  Unless stated otherwise, the requirements set forth in paragraphs 10
through 14 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.  
16. Section 73.1212 Complaints; Subsequent Investigations.   Nothing in this Consent 
Decree shall prevent the Commission or its delegated authority from adjudicating complaints filed 
pursuant to Section 73.1212 of the Commission’s Rules against Townsquare El Paso or its affiliates for 
alleged violations of the Act or the Commission’s Rules or for any other type of alleged misconduct, 
regardless of when such misconduct took place.  The Commission’s adjudication of any such complaints 
will be based solely on the record developed in that proceeding.  Except as expressly provided in this 
Consent Decree, this Consent Decree shall not prevent the Commission from investigating new evidence 
of noncompliance by Townsquare El Paso with the Communications Laws. 
17. Voluntary Contribution.  Townsquare El Paso agrees that it will make a voluntary 
contribution to the United States Treasury in the amount of fifteen thousand dollars ($15,000) within 
thirty (30) calendar days after the Effective Date.  Townsquare El Paso shall also send electronic 
notification of payment to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov, Jeffrey J. Gee at 
Jeffrey.Gee@fcc.gov, Anjali Singh at Anjali.Singh@fcc.gov, and to Judy Lancaster at 
Judy.Lancaster@fcc.gov on the date said payment is made.  The payment must be made by check or 
Federal Communications Commission DA 13-1651
9
similar instrument, wire transfer, or credit card, and must include the NAL/Account number and FRN 
referenced above.  Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice) 
must be submitted.22 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).  Below 
are additional instructions you should follow based on the form of payment you select:23
? Payment by check or money order must be made payable to the order of the Federal 
Communications Commission. Such payments (along with the completed Form 159) must be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank – Government Lockbox #979088, SL-MO-C2-
GL, 1005 Convention Plaza, St. Louis, MO 63101.
? Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and Account Number 27000001. To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
at (314) 418-4232 on the same business day the wire transfer is initiated.
? Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.   
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank –
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.
18. Waivers.  Townsquare El Paso 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.  Townsquare El Paso 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 Townsquare El 
Paso nor the Commission shall contest the validity of the Consent Decree or the Adopting Order, and 
Townsquare El Paso shall waive any statutory right to a trial de novo.  Townsquare El Paso hereby agrees 
to 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.
19. 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.  
20. Subsequent Rule or Order.  The Parties agree that if any provision of this 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 Townsquare El Paso does not 
expressly consent) that provision will be superseded by such Rule or Commission order.
  
22 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
23 If Townsquare El Paso has questions regarding payment procedures, it should contact the Financial Operations 
Group Help Desk by phone at 1-877-480-3201, or by e-mail at ARINQUIRIES@fcc.gov.
Federal Communications Commission DA 13-1651
10
21. Successors and Assigns.  Townsquare El Paso agrees that the provisions of this Consent 
Decree shall be binding on its successors, assigns, and transferees.
22. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.
23. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
24. 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.
25. Authorized Representative.  The individual signing this Consent Decree on behalf of 
Townsquare El Paso represents and warrants that he is authorized by Townsquare El Paso to execute this 
Consent Decree and to bind Townsquare El Paso 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. 
Federal Communications Commission DA 13-1651
11
26. 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.
FEDERAL COMMUNICATIONS COMMISSION
______________________________________
Robert H. Ratcliffe
Acting Chief, Enforcement Bureau 
______________________________________
Date
TOWNSQUARE MEDIA OF EL PASO, INC.
 
_____________________________________
By:  Alex Berkett
Executive Vice President
 
 
_____________________________________
Date