Federal Communications Commission DA 14-1642
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Associated Telecommunications Management
Services, LLC
BLC Acquisition Group, LLC
Bellerud Acquisition Group, LLC
Ganoco Acquisition Group, LLC
Lifeconnex Acquisition Group, LLC
Triarch Acquisition Group, LLC
SCTxLink Acquisition Group, LLC
DialTone & More Acquisition Group, LLC
Ren-Tel Acquisition Group, LLC
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File No.: EB-IHD-14-00014841
1
NAL/Acct. No.: 201132080030 
FRN No. 0019354513
FRN No. 0019421031
FRN No. 0019389527
FRN No. 0019389485
FRN No. 0019387182
FRN No. 0019389451
FRN No. 0019419746
FRN No. 0019418581
FRN No. 0019418474
FORFEITURE ORDER
Adopted:  December 1, 2014 Released:  December 1, 2014
By the Chief, Enforcement Bureau:
I. INTRODUCTION
1. We impose a total penalty of $64,000 against eight subsidiaries of Associated 
Telecommunications Management Services, LLC (ATMS) for their unauthorized acquisition of eight 
domestic telecommunications services providers, in violation of Section 214(a) of the Communications 
Act of 1934 (Act) and Sections 63.03 and 63.04 of the Commission’s rules (Rules). The Act mandates
that a telecommunications service provider obtain Commission approval prior to a substantial change in 
its corporate control. This requirement allows the Commission to evaluate the acquiring company’s basic 
qualifications to determine whether the transaction is in the public interest and whether the acquiring 
company is prepared to meet its obligations as a Commission licensee.  
II. BACKGROUND
2. On July 15, 2011, the Bureau released a Notice of Apparent Liability for Forfeiture in 
this matter.
2
  In the NAL, the Bureau determined that the ATMS subsidiaries had apparently failed to 
                                                     
1
This case was formerly assigned File No. EB-10-IH-4133.
Federal Communications Commission DA 14-1642
2
obtain Commission approval prior to consummating eight substantial transfers of control of 
authorizations to operate lines for common carrier communications.
3
  The NAL proposed forfeitures 
totaling $64,000 against ATMS for apparent willful or repeated violations of Section 214 of the Act and 
Sections 63.03 and 63.04 of the Rules.
4
During the relevant time period, ATMS was a holding company
that Thomas Biddix, Kevin Brian Cox, and Leonard I. Solt owned and operated.
5
3. On August 15, 2011, ATMS filed a response to the NAL seeking a reduction in the 
forfeiture amount based on the fact that it self-disclosed and attempted to correct four of the unauthorized 
transfers prior to receiving the Bureau’s letter of inquiry LOI.
6
III. DISCUSSION
4. The Bureau proposed a forfeiture in this case in accordance with Section 503(b) of the 
Communications Act of 1934, as amended (Act),
7
Section 1.80 of the Rules,
8
and the Commission’s 
Forfeiture Policy Statement.
9
  When we assess forfeitures, Section 503(b)(2)(E) requires that we take into 
account the “nature, circumstances, extent, and gravity of the violation and, with respect to the violator, 
the degree of culpability, any history of prior offenses, ability to pay, and such other matters as justice 
may require.”
10
  As discussed below, we have fully considered ATMS’s response to the NAL, but we find 
it unpersuasive.  We therefore affirm the $64,000 total forfeiture proposed in the NAL.
5. ATMS does not contest our allegation that it willfully failed to obtain Commission 
approval prior to consummating eight substantial transfers of control of authorizations to operate lines for 
(Continued from previous page)                                                            
2
Associated Telecommunications Management Services, LLC, et al., Notice of Apparent Liability for Forfeiture, 26 
FCC Rcd 10205 (Enf. Bur. 2011) (NAL). The eight ATMS subsidiaries are: BLC Acquisition Group, LLC; Bellerud 
Acquisition Group, LLC; DialTone & More Acquisition Group, LLC; Ganoco Acquisition Group, LLC; Lifeconnex 
Acquisition Group, LLC; Ren-Tel Acquisition Group, LLC; SCTxLink Acquisition Group, LLC and Triarch 
Acquisition Group, LLC.  Id. at 10206–08, para. 3.  The NAL includes a more complete discussion of the facts and 
history of this case and is incorporated herein by reference.
3
NAL, 26 FCC Rcd at 10208, para. 5.
4
47 U.S.C. § 214(a); 47 C.F.R. §§ 63.03-63.04.
5
On April 10, 2014, the Criminal Division of the Department of Justice announced the indictment of Mr. Biddix, 
Mr. Cox, and Mr. Solt for allegedly using ATMS and its subsidiaries to defraud the federal Lifeline Program out of 
approximately $32 million. See Dept. of Justice, Office of Public Affairs, “Three Men charged with Allegedly 
Defrauding the FCC of Approximately $32 million,” (Apr. 10, 2014), available at
http://www.justice.gov/opa/pr/three-men-charged-allegedly-defrauding-fcc-approximately-32-million; “Federal 
Communications Commission, “News Release, “Chairman Wheeler Applauds Indictment of Three Men on Lifeline 
Fraud Charges,” (Apr. 10, 2014), available at https://apps.fcc.gov/edocs_public/attachmatch/DOC-326532A1.pdf.
The Commission established the Lifeline Program to “help qualifying consumers have the opportunities and security 
that phone service brings, including being able to connect to jobs, family members, and emergency services.”  Easy 
Tel. Servs. d/b/a Easy Wireless, File No. EB-IHD-13-00010590, Notice of Apparent Liability for Forfeiture, 28 FCC 
Rcd 14433, 14433, para. 2 (2013).
6
Associated Telecommunications Management Services, LLC, et al., Statement Seeking Reduction in Proposed 
Forfeiture (filed Aug. 15, 2011) (on file in EB-IHD-14-00014841) (NAL Response).
7
47 U.S.C. § 503(b).
8
47 C.F.R. § 1.80.
9
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, 
Memorandum Opinion and Order, 15 FCC Rcd 303 (1999). 
10
47 U.S.C. § 503(b)(2)(E).
Federal Communications Commission DA 14-1642
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common carrier communications.
11
  Thus, we find that ATMS willfully violated Section 214(a) of the Act 
and Sections 63.03 and 63.04 of the Rules.
6. The Commission’s Forfeiture Policy Statement specifies that the Commission shall 
impose a forfeiture based upon consideration of the factors enumerated in what is now Section 
503(b)(2)(E) of the Act.
12
Taking all of these factors into consideration, we find that each of ATMS 
subsidiaries is liable for an $8,000 forfeiture, for a total penalty of $64,000.  As explained in the NAL, 
this total results from applying the base forfeiture amount of $8,000 to each subsidiary’s separate 
unauthorized substantial transfer of control.
13
  
7. ATMS seeks a reduction from the proposed forfeiture based on the fact that it self-
disclosed and attempted to correct four of the unauthorized transfers prior to receiving the Bureau’s 
LOI.
14
  Such partial disclosure and compliance efforts are insufficient to warrant a reduction in the 
proposed forfeitures.  Although the Commission has in certain circumstances reduced proposed 
forfeitures “based on . . . good faith corrective efforts . . . taken prior to Commission notification” of the 
violations,” a “lack of diligence” in addressing all aspects of the violations precludes any such reduction 
here.
15
  ATMS did not disclose or attempt to correct four of the eight violations until after it had received 
the LOI, despite the fact that the eight transactions at issue occurred within the same time frame.
16
  Under 
these circumstances, a reduction of the proposed forfeiture is not warranted.  Weighing the relevant 
statutory factors and our own forfeiture guidelines, we conclude, based upon the evidence before us, that 
the proposed forfeiture of $64,000 properly reflects the seriousness, duration, and scope of the violations
of ATMS and its subsidiaries.
IV. CONCLUSION
8. Based on the record before us and in light of the applicable statutory factors, we hereby 
affirm our conclusion in the NAL that ATMS and its subsidiaries willfully violated Section 214(a) of the 
Act and Sections 63.03 and 63.04 of the Rules by failing to obtain Commission approval prior to 
consummating eight substantial transfers of control of authorizations to operate lines for common carrier 
communications.  We decline to cancel or reduce the forfeiture amounts, which properly reflect the 
seriousness, duration, and scope of ATMS’s violations. We therefore conclude that ATMS is liable for 
forfeitures totaling $64,000.
V. ORDERING CLAUSES
9. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, Sections 0.111, 0.311, and 1.80 of the Commission’s rules,
17
BLC Acquisition 
Group, LLC, IS LIABLE FOR A MONETARY FORFEITURE in the amount of eight thousand 
                                                     
11
NAL, 26 FCC Rcd at 10208, para. 5.
12
47 U.S.C. § 503(b)(2)(E).
13
NAL, 26 FCC Rcd at 10209, para. 6.
14
NAL Response at 2–3.
15
Sutro Corporation, Payette, Idaho, Memorandum Opinion and Order, 19 FCC Rcd 15274, 15277, para. 10 (2004).
16
See Letter from Lance J.M. Steinhart, Lance J. Steinhart, P.C., to Marlene H. Dortch, Secretary, FCC, Request for 
Special Temporary Authority of Bellerud Acquisition Group, LLC, Docket No. WC 10-11 (filed Jan. 7, 2010) (on 
file in EB-IHD-14-00014841) (stating that ATMS’s owners initiated a series of unauthorized transfers of control 
“[b]eginning on or about September 1, 2009); E-Mail from Robert G. Morse, Wilkinson, Barker, Knauer, LLP, to 
Robert Krinsky, Investigations and Hearings Division, FCC Enforcement Bureau (Nov. 9, 2010) (on file in EB-IHD-
14-00014841) (stating that the four unauthorized transfers of control disclosed in ATMS’s LOI Response “occurred on 
or about November 30, 2009”).
17
See 47 U.S.C. § 503(b); 47 C.F.R. §§ 0.111, 0.311, 1.80.
Federal Communications Commission DA 14-1642
4
dollars ($8,000) for willfully or repeatedly violating Section 214(a) of the Communications Act of 1934, 
as amended, and Sections 63.03 and 63.04 of the Commission’s rules.
18
10. IT IS FURTHER ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, Sections 0.111, 0.311, and 1.80 of the Commission’s rules, Bellerud 
Acquisition Group, LLC, IS LIABLE FOR A MONETARY FORFEITURE in the amount of eight
thousand dollars ($8,000) for willfully or repeatedly violating Section 214(a) of the Communications Act 
of 1934, as amended, and Sections 63.03 and 63.04 of the Commission’s rules. 
11. IT IS FURTHER ORDERED that, pursuant to Section 503(b) of the Communications
Act of 1934, as amended, Sections 0.111, 0.311, and 1.80 of the Commission’s rules, DialTone & More 
Acquisition Group, LLC, IS LIABLE FOR A MONETARY FORFEITURE in the amount of eight
thousand dollars ($8,000) for willfully or repeatedly violating Section 214(a) of the Communications Act 
of 1934, as amended, and Sections 63.03 and 63.04 of the Commission’s rules.
12. IT IS FURTHER ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, Sections 0.111, 0.311, and 1.80 of the Commission’s rules, Ganoco Acquisition 
Group, LLC, IS LIABLE FOR A MONETARY FORFEITURE in the amount of eight thousand
dollars ($8,000) for willfully or repeatedly violating Section 214(a) of the Communications Act of 1934, 
as amended, and Sections 63.03 and 63.04 of the Commission’s rules.
13. IT IS FURTHER ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, Sections 0.111, 0.311, and 1.80 of the Commission’s rules, Lifeconnex 
Acquisition Group, LLC, IS LIABLE FOR A MONETARY FORFEITURE in the amount of eight 
thousand dollars ($8,000) for willfully or repeatedly violating Section 214(a) of the Communications Act 
of 1934, as amended, and Sections 63.03 and 63.04 of the Commission’s rules.
14. IT IS FURTHER ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, Sections 0.111, 0.311, and 1.80 of the Commission’s rules, Ren-Tel Acquisition 
Group, LLC, IS LIABLE FOR A MONETARY FORFEITURE in the amount of eight thousand
dollars ($8,000) for willfully or repeatedly violating Section 214(a) of the Communications Act of 1934, 
as amended, and Sections 63.03 and 63.04 of the Commission’s rules.
15. IT IS FURTHER ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, Sections 0.111, 0.311, and 1.80 of the Commission’s rules, SCTxLink 
Acquisition Group, LLC, IS LIABLE FOR A MONETARY FORFEITURE in the amount of eight 
thousand dollars ($8,000) for willfully or repeatedly violating Section 214(a) of the Communications Act 
of 1934, as amended, and Sections 63.03 and 63.04 of the Commission’s rules.
16. IT IS FURTHER ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, Sections 0.111, 0.311, and 1.80 of the Commission’s rules, Triarch Acquisition 
Group, LLC, IS LIABLE FOR A MONETARY FORFEITURE in the amount of eight thousand 
dollars ($8,000) for willfully or repeatedly violating Section 214(a) of the Communications Act of 1934, 
as amended, and Sections 63.03 and 63.04 of the Commission’s rules.
17. Payment of the forfeitures shall be made in the manner provided for in Section 1.80 of 
the Commission’s rules no later than December 19, 2014.
19
If the forfeitures are not paid within the 
period specified, the case may be referred to the U.S. Department of Justice for enforcement of the 
forfeiture pursuant to Section 504(a) of the Communications Act of 1934, as amended.
20
  ATMS and the 
ATMS Subsidiaries shall send electronic notification of the payments to William A. Kehoe at 
                                                     
18
See 47 U.S.C. § 214(a); 47 C.F.R. §§ 63.03-63.04.  
19
See 47 C.F.R. § 1.80.
20
See 47 U.S.C. 504(a).
Federal Communications Commission DA 14-1642
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William.Kehoe@fcc.gov, and Robert B. Krinsky at Robert.Krinsky@fcc.gov on the date said payment is
made.
18. The payments must be made by check or similar instrument, wire transfer, or credit card, 
and must include the NAL/Account Numbers and FRNs referenced above.  ATMS and the ATMS 
Subsidiaries shall send electronic notification of the payments to William A. Kehoe at 
William.Kehoe@fcc.gov, and Robert B. Krinsky at Robert.Krinsky@fcc.gov on the date said payment is
made.  Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice) must be 
submitted.
21
  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 Indigo Wireless, Inc. should follow based on the form of payment it selects:
? 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.
19. Any request for making full payment over time under an installment plan should be sent 
to: Chief Financial Officer—Financial Operations, Federal Communications Commission, 445 12th 
Street, S.W., Room 1-A625, Washington, DC 20554.
22
  If ATMS or the ATMS Subsidiaries have
questions regarding payment procedures, it should contact the Financial Operations Group Help Desk by 
phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.  
20. IT IS FURTHER ORDERED that a copy of this Forfeiture Order shall be sent by first 
class mail and certified mail, return receipt requested, to Thomas Biddix, Associated Telecommunications 
Management Services, LLC, 6905 N. Wickham Road, Suite 403, Melbourne, FL 32940 and to Kepler 
Funk, Funk, Szachacz & Diamond, LLC, 3962 West Eau Galle Boulevard, Suite B, Melbourne, FL 
32934.
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief
Enforcement Bureau
                                                     
21
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
22
See 47 C.F.R. § 1.1914.