Federal Communications Commission DA 14-1692
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Journal Broadcast Corporation
Licensee of Station KTNV-TV, Las Vegas, 
Nevada
)
)
)
)
)
)
)
)
)
)
File Nos.:  EB-IHD-14-00016141 and 
                  EB-09-IH-1918
Acct. No.:  201532080004
FRN:  0002710192
Facility ID No.:  74100
ORDER
Adopted:  December 5, 2014 Released:  December 5, 2014
By the Chief, Enforcement Bureau:
1. The Federal Communications Commission’s sponsorship identification laws protect 
consumers and promote fair competition by requiring that the sponsors of paid programming material are 
clearly identified.  Generally, it is clear when an announcement is a commercial that is paid for by a
sponsor.  In some cases, however, an announcement may appear to be the station’s editorial opinion or 
even station-produced news, when, in fact, it is dictated by—and paid for by—a third party.  In such 
cases, the sponsorship identification laws protect consumers by requiring that the third party is clearly 
disclosed as the sponsor of the announcement.  Among other things, these laws prevent broadcasters, 
advertisers, and others from presenting paid announcements that the public can perceive as the station’s 
editorial or objective content while concealing that the station is being paid by a third party to promote a 
particular message.  Enforcement of the sponsorship identification laws also protects fair competition 
among advertisers.  We seek to prevent sponsors from gaining unfair advantage by paying stations to 
present promotional messages as station news or editorial content without appropriate disclosures, while 
their competitors observe the rules and present their content as acknowledged commercial advertisements.
2. In this case, the Enforcement Bureau (Bureau) of the Federal Communications 
Commission investigated a complaint that KTNV-TV in Las Vegas broadcast what appeared to be news 
reports about liquidation sales at local car dealerships, without disclosing that the dealerships had paid the 
station to air the reports.  Our investigation revealed that KTNV-TV produced and aired “Special 
Reports,” formatted in the style of news reports, concerning the liquidation sales and that the “Special 
Reports” did not include explicit disclaimers that the car dealerships had paid for the “Special Reports.”  
Journal Broadcasting Corporation (Journal), the licensee of KTNV-TV, admits that these broadcasts 
violated the sponsorship identification laws.  Journal will pay $115,000 to resolve the allegations and 
agrees to implement a three-year compliance plan to avoid future violations of the sponsorship 
identification laws.  
3. In this Order, we adopt the attached Consent Decree entered into between the Bureau and 
Journal.  The Consent Decree resolves and terminates the Bureau’s investigation into Journal’s violations 
of Section 317 of the Communications Act of 1934, as amended (Act), and Section 73.1212 of the 
Commission’s rules (Rules) pertaining to sponsorship identification.
1
  
                                                     
1
47 U.S.C. § 317; 47 C.F.R. § 73.1212.
Federal Communications Commission DA 14-1692
2
4. The Bureau and Journal have negotiated the terms of the Consent Decree that resolves 
this matter.  A copy of the Consent Decree is attached hereto and incorporated herein by reference. 
5. 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.
6. 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 Journal possesses the basic 
qualifications, including those related to character, to hold or obtain any Commission license or 
authorization.
7. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i), 4(j), and 503(b) of the 
Act,
2
and Sections 0.111 and 0.311 of the Rules,
3
the Consent Decree attached to this Order IS 
ADOPTED.
8. IT IS FURTHER ORDERED that the above-captioned investigation IS
TERMINATED.
9. IT IS FURTHER ORDERED that any third-party complaints and allegations against 
KTNV-TV and/or Journal related to the above-captioned investigation that are currently pending before 
the Bureau as of the date of this Consent Decree ARE DISMISSED.
10. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by First Class U.S. Mail and Certified Mail to Journal’s counsel, Dennis P. Corbett, Esq., Lerman 
Senter PLLC, 2000 K Street, NW, Suite 600, Washington, DC 20006.  
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief
Enforcement Bureau
                                                     
2
47 U.S.C. §§ 154(i), 154(j), 503(b).
3
47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 14-1692
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Journal Broadcast Corporation
Licensee of Station KTNV-TV, Las Vegas, 
Nevada
)
)
)
)
)
)
)
)
)
)
File Nos.:  EB-IHD-14-00016141 and 
                  EB-09-IH-1918
Acct. No.:  201532080004
FRN:  0002710192
Facility ID No.:  74100
CONSENT DECREE
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission 
(Commission or FCC) and Journal Broadcast Corporation (Journal), licensee of Station KTNV-TV, by 
their authorized representatives, hereby enter into this Consent Decree for the purpose of terminating the 
Bureau’s investigation into Journal’s violations of Section 317 of the Communications Act of 1934, as 
amended (Act), and Section 73.1212 of the Commission’s rules (Rules) pertaining to sponsorship 
identification.
1
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 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 
each Commission licensee, including Journal, is subject by virtue of its being a 
Commission licensee, including but not limited to the Sponsorship Identification 
Laws.
(f) “Complaint” means the third-party Complaint received by, or in the possession 
of, the Bureau and alleging violation of the Sponsorship Identification Laws, as 
described in this Consent Decree at paragraph 4.
(g) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 14.
(h) “Consideration” means anything of value, including but not limited to, cash, 
checks, salaries, fees, commissions, loans, management fees, consulting fees, 
                                                     
1
47 U.S.C. § 317; 47 C.F.R. § 73.1212.
Federal Communications Commission DA 14-1692
2
honoraria, per diem allowances, payments of third-party invoices, travel and/or 
hotel expenses, meals, gifts, bonuses, services, purchases of, or promises to 
purchase, advertising time, and/or any other things of value, from any source, or 
given by third parties, to another.  
(i) “Covered Employees” means all employees and agents of Journal who perform, 
or supervise, oversee, and/or manage the performance of, duties that relate to 
Journal’s responsibilities for the Station under the Sponsorship Identification 
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 for the Station, 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 September 
26, 2013, Letter of Inquiry regarding whether Journal violated the Sponsorship 
Identification Laws.
(l) “Journal” means Journal Broadcast Corporation, including all of its subsidiaries 
and affiliates, its predecessors-in-interest, and its successors-in-interest, provided, 
however, that upon closing of the transaction announced on July 30, 2014 
between Journal and the E.W. Scripps Company, this Consent Decree shall 
continue to apply only to the stations licensed to Journal as of the date of this 
Agreement.
(m) “Operating Procedures” means the standard, internal operating procedures and 
compliance policies established by Journal to implement the Compliance Plan.
(n) “Parties” means Journal and the Bureau, each of which is a “Party.”
(o) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(p) “Sponsored Broadcast” is a matter transmitted by a broadcast station that is aired 
in exchange for Consideration that is “directly or indirectly paid, or promised to 
or charged or accepted by, the station so broadcasting,” including, but not limited 
to, the types of broadcasts covered by Section 317 of the Act.
2
(q) “Sponsorship Identification Laws” means, individually or collectively, Section 
317 of the Act and Section 73.1212 of the Rules,
3
and the decisions and orders of 
the Commission interpreting these provisions.
(r) “Station” means Station KTNV-TV, Las Vegas, Nevada (Facility ID 74100).
II. BACKGROUND
3. The Sponsorship Identification Laws establish the general obligation of a broadcast 
station to air sponsorship identification announcements whenever any “money, service or other valuable 
consideration” is paid or promised to the station for the broadcast of program material.
4
  The Commission 
has noted that the Sponsorship Identification Laws are “grounded in the principle that listeners and 
                                                     
2
47 U.S.C. § 317.  See 47 C.F.R. § 73.1212.  
3
See 47 U.S.C. § 317; 47 C.F.R. § 73.1212.
4
47 U.S.C. § 317(a)(1); 47 C.F.R. § 73.1212(a).
Federal Communications Commission DA 14-1692
3
viewers are entitled to know who seeks to persuade them.”
5
  The disclosures required by the Sponsorship 
Identification Laws provide listeners and viewers with information concerning the source of material in 
order to prevent misleading or deceiving those listeners and viewers.
6
  The Commission has warned that it 
would take enforcement action against broadcast stations and cable operators that did not comply with 
these disclosure requirements.
7
  
4. The Bureau received a Complaint alleging that Arrowhead Advertising, an advertising 
agency in Las Vegas, Nevada that represented local automobile dealerships, approached several local
television stations, including KTNV-TV, offering to buy air time for commercials if the stations aired 
“news” programming concerning automobile liquidation sales events at the dealerships.
8
5. The Bureau’s investigation revealed that KTNV-TV accepted payment from the 
dealerships to produce and air several versions of what KTNV-TV called a “Special Report” about the 
liquidation at the dealerships.  The “Special Reports” were formatted in the style of a news report and 
featured a KTNV-TV employee who, in the manner of a television reporter, questioned representatives of 
the dealerships about their ongoing liquidation sales events.  The “Special Reports,” however, were not in 
fact news coverage, but instead paid advertisements.  KTNV-TV broadcast the “Special Reports” twenty-
seven times from May through August 2009.  In its response to the Bureau’s investigation, Journal 
acknowledged the applicability of the Commission’s Sponsorship Identification Laws to the “Special 
Reports,” but argued that the context of the “Special Reports” made clear that the “Special Reports” were 
paid advertisements despite the lack of an explicit disclaimer.
9
  Based on the record, however, the Bureau 
contends that Journal failed to air sponsorship announcements required by the Sponsorship Identification 
Laws for the twenty-seven “Special Reports” broadcast by KTNV-TV.
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.  Journal 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.
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.
                                                     
5
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) (2005 Public Notice). 
6
See Sonshine Family Television, Inc., Notice of Apparent Liability for Forfeiture, 22 FCC Rcd 18686, 18694, para. 
15 (2007), aff’d with reduced forfeiture, Forfeiture Order, 24 FCC Rcd 14830, 14834, para. 12 (2009) (forfeiture 
reduced based on licensee’s history of compliance) (forfeiture paid).
7
See, e.g., 2005 Public Notice at 8594.
8
See Letter from J. Dominic Monahan, Counsel for Valley Broadcasting Company, to Hillary S. DeNigro, Chief, 
Investigations and Hearings Division, FCC Enforcement Bureau (Oct. 7, 2009) (on file in EB-09-IH-1918 and 
EB-IHD-14-00016141).
9
See Letter from Dennis P. Corbett, Esq., Counsel to Journal Broadcast Corporation, to Guy N. Benson, Esq., FCC 
Enforcement Bureau at 5 (Dec. 4, 2013) (on file in EB-09-IH-1918 and EB-IHD-14-00016141); Letter from Dennis 
P. Corbett, Esq., Counsel to Journal Broadcast Corporation, to Guy N. Benson, Esq., FCC Enforcement Bureau at 2 
(Apr. 17, 2014) (on file in EB-09-IH-1918 and EB-IHD-14-00016141).
Federal Communications Commission DA 14-1692
4
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, Journal 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 Journal 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 Journal with respect to Journal’s basic qualifications, including its character 
qualifications, to be a Commission licensee or to hold Commission licenses or authorizations.
10. Section 73.1212 Complaints; Subsequent Investigations.  Nothing in this Consent 
Decree shall prevent the Commission or its delegated authority from adjudicating complaints, other than 
the complaint that formed the basis for the instant Investigation, filed pursuant to Section 73.1212 of the 
Rules against Journal, or its affiliates, for alleged violations of the Sponsorship Identification Laws, the 
Act, the Rules, or for any other type of alleged misconduct, regardless of when such misconduct took 
place.  The Commission’s adjudication of any such complaint 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 Journal with the 
Communications Laws.
11. Admission of Liability.  Journal admits, in express reliance on the provisions of 
paragraph 9 herein, that its actions with respect to the broadcast of the Special Reports referenced in 
paragraph 5 of this Consent Decree violated the Commission’s Sponsorship Identification Laws.
12. Civil Penalty.  Journal will make a payment to the United States Treasury in the amount 
of one hundred fifteen thousand dollars ($115,000) within thirty (30) calendar days after the Effective 
Date.  Journal shall also send electronic notification of payment to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, 
Kenneth M. Scheibel, Jr. at Kenneth.Scheibel@fcc.gov, and to Guy N. Benson at Guy.Benson@fcc.gov
on the date said payment is made.  The payment must be made by check or similar instrument, wire 
transfer, or credit card, and must include the Account Number and FRN referenced above.  Regardless of 
the form of payment, Journal must submit a completed FCC Form 159 (Remittance Advice).
10
  When 
completing the FCC Form 159, Journal should 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 that Journal should follow based on the form of payment it selects:
11
? 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.
                                                     
10
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
11
If Journal 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 14-1692
5
? 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.
13. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Journal 
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 Journal 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 Identification Laws prior to assuming his/her duties and shall commit to ensuring 
compliance with respect to the Sponsorship Identification Laws.
14. Compliance Plan.  Journal agrees that it shall, by the dates specified in this paragraph,
including its subparts, 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 Identification Laws, Journal shall implement the following procedures:
(a) Operating Procedures.  Within sixty (60) calendar days after the Effective Date, 
Journal shall establish Operating Procedures that all Covered Employees must 
follow to help ensure Journal’s compliance with the Sponsorship Identification 
Laws.  Journal’s Operating Procedures shall include company-wide internal 
procedures and policies specifically designed to ensure that Journal discloses the 
sponsorship status and the sponsor of broadcasts that are aired in exchange for 
valuable Consideration or otherwise require sponsorship identification, consistent 
with the Sponsorship Identification Laws.  Journal also shall develop a 
Compliance Checklist that describes the steps that a Covered Employee must 
follow to ensure compliance with the Sponsorship Identification Laws.  At a 
minimum, the Compliance Checklist shall require a multi-level review of 
Sponsored Broadcasts that air over the Station, meaning that all scripts of such
Sponsored Broadcasts shall be reviewed prior to broadcast for compliance with 
the Sponsorship Identification Laws by at least two Station employees, one of 
whom shall be a supervisory-level employee or employee specially trained in 
Sponsorship Identification Laws compliance, provided, however, that a multi-
level review shall not be required of Sponsored Broadcasts embedded in network 
or syndicated programming.
(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 Identification Laws and set forth the 
Operating Procedures that Covered Employees shall follow to help ensure 
Journal’s compliance with the Communications Laws.  Journal shall periodically 
review and revise the Compliance Manual as necessary to ensure that the 
information set forth therein remains current and complete.  Journal shall 
distribute any revisions to the Compliance Manual promptly to all Covered 
Employees.
(c) Compliance Training Program.  Journal shall establish and implement a
Compliance Training Program on compliance by Covered Employees with the 
Sponsorship Identification Laws and the Operating Procedures.  As part of the 
Compliance Training Program, Covered Employees shall be advised of Journal’s 
Federal Communications Commission DA 14-1692
6
obligation to report any noncompliance with the Sponsorship Identification Laws
as described under paragraph 16 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.  Any person who becomes a 
Covered Employee at any time after the initial Compliance Training Program is 
conducted  shall be trained within thirty (30) calendar days after the date such 
person becomes a Covered Employee.  Journal 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.
(d) Hotline.  The Compliance Officer shall maintain a hotline for Covered 
Employees to call the Compliance Officer to obtain advice on compliance with 
the Compliance Plan and report violations of the Compliance Plan.
(e) Contractual Agreements. Journal will ensure that all contractual agreements 
with respect to Covered Employees shall include a contractual clause requiring 
compliance with the Sponsorship Identification Laws.
(f) Commitment to Due Diligence for the Identification of Program Sponsors 
and the Airing of Sponsored Content.  Journal commits to diligently identify 
program sponsors and to broadcast compliant announcements, where required, to 
avoid violations of the Sponsorship Identification Laws.
(g) Sponsor Education.  Journal 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 the 
sponsor’s approval and eventual broadcast.  To that end, Journal will summarize 
the Sponsorship Identification Laws for each client prior to accepting any 
contract to air messages and/or programming over the Station and preparing the 
message and/or programming for the sponsor’s review.
(h) Annual Report.  The Compliance Officer shall submit reports to Journal’s Board 
of Directors concerning Journal’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.
15. Compliance Reports.  Journal shall file Compliance Reports with the Commission 
ninety (90) calendar 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 Journal’s efforts 
during the relevant period to comply with the terms and conditions of this 
Consent Decree and the Sponsorship Identification Laws.  In addition, each 
Compliance Report shall include a certification by the Compliance Officer, as an 
agent of and on behalf of Journal, stating that the Compliance Officer has 
personal knowledge that Journal:  (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 16.
(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 
Federal Communications Commission DA 14-1692
7
the Rules
12
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 Journal, 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 Journal 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 Journal 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, SW, Washington, DC 20554, with a copy 
submitted electronically to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, Kenneth M. 
Scheibel, Jr. at Kenneth.Scheibel@fcc.gov, and Guy N. Benson at 
Guy.Benson@fcc.gov.
16. Reporting Noncompliance.  Journal shall report any noncompliance with the 
Sponsorship Identification Laws at the Station, 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 Journal 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 Journal 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, SW, 
Washington, DC 20554, with a copy submitted electronically to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, 
Kenneth M. Scheibel, Jr. at Kenneth.Scheibel@fcc.gov, and Guy N. Benson at Guy.Benson@fcc.gov.
17. FCC Enforcement Actions.  If, as a result of a possible future violation of the 
Sponsorship Identification Laws at the Station, Journal receives a Notice of Apparent Liability or similar 
Bureau document proposing a forfeiture, or contemplating license non-renewal or revocation, Journal 
shall: 
(a) suspend each employee accused of violating the Sponsorship Identification Laws 
and undertake an investigation of each such incident; 
(b) require that each such employee receive remedial training on the Sponsorship 
Identification 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; and
(c) take disciplinary action, up to and including termination, against each employee 
who is materially involved in the violation of the Sponsorship Identification 
Laws, if such violation results in a final adjudication by the Commission that 
Journal violated the Sponsorship Identification Laws or in other circumstances as 
determined appropriate by Journal.
18. Termination Date.  Unless stated otherwise, the requirements set forth in paragraphs 13–
17 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
19. Waivers.  Journal 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 
                                                     
12
47 C.F.R. § 1.16.
Federal Communications Commission DA 14-1692
8
Decree and the Adopting Order, provided the Bureau issues an Adopting Order as defined herein.  Journal 
shall retain the right to challenge Commission interpretation of the Consent Decree or any terms 
contained herein.  If any Party (or the United States on behalf of the Commission) brings a judicial action 
to enforce the terms of the Adopting Order, neither Journal nor the Commission shall contest the validity 
of the Consent Decree or the Adopting Order, and Journal shall waive any statutory right to a trial de 
novo.  Journal hereby agrees to waive any claims it may have under the Equal Access to Justice Act
13
relating to the matters addressed in this Consent Decree.
20. 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.  
21. 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 Journal does not expressly 
consent) that provision will be superseded by such Rule or Commission order.
22. Successors and Assigns.  Journal agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees. 
23. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.
24. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of all Parties.
25. 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.
26. Authorized Representative.  Each Party represents and warrants to the other Parties that 
it has full power and authority to enter into this Consent Decree.  Each person signing this Consent 
Decree on behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this 
Consent Decree and to bind the Party to its terms and conditions.
                                                     
13
5 U.S.C. § 504; 47 C.F.R. § 1.1501 et seq.
Federal Communications Commission DA 14-1692
9
27. 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
___________________________
Travis LeBlanc
Chief
Enforcement Bureau
___________________________
Date
JOURNAL BROADCAST CORPORATION
_____________________________
Steven J. Smith
Vice President
_____________________________
Date