Federal Communications Commission DA 14-487
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Vast Communications, LLC
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File No.:  EB-IHD-14-00014244
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Acct. No.:  201432080030
FRN:  0019239284
ORDER
Adopted:  April 11, 2014                   Released:  April 11, 2014
By the Deputy Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission 
(Commission) has entered into a Consent Decree with Vast Communications, LLC (Vast) regarding 
Vast’s compliance with the Commission’s rules related to the Universal Service Fund (USF).  The USF 
supports several programs designed to ensure that all Americans have access to high-quality, affordable 
communications services.  The USF receives funding for those programs via mandatory contributions
from providers of telecommunications service.  These obligations apply to companies like Vast that 
provide audio bridging service, which is more commonly known as conference calling service.  The 
Commission’s rules require telecommunications providers to register with the Commission, and to submit 
periodic filings—known as Telecommunications Reporting Worksheets (FCC Form 499-As and FCC 
Form 499-Qs)—identifying revenues related to the telecommunications they provide.  The registration 
essentially informs the Commission that the company intends to offer service and may have USF 
contribution obligations, and the reports (FCC Forms 499-A and 499-Q) provide the revenue data used to 
calculate the amount the company owes to the USF, and other regulatory funds. Vast disclosed to the 
Commission that it did not register with the Commission or begin filing its telecommunications reporting 
worksheets until it had provided telecommunications service for nine months.  Pursuant to the Consent 
Decree, the company will make a voluntary contribution and implement a three-year plan to ensure future 
compliance with these requirements.
2. In this Order, we adopt the attached Consent Decree, which is incorporated herein by 
reference. The Consent Decree terminates the Bureau’s investigation into Vast’s compliance with
Sections 52.17, 52.32, 54.706, 54.711, 64.604, and 64.1195 of the Commission’s rules (Rules) governing 
USF contribution and reporting requirements.
2
                                                
1
This investigation, initiated under File No. EB-10-IH-3338, was subsequently assigned File No. EB-IHD-14-
00014244.  Any future correspondence with the FCC concerning this matter should reflect the new case number, 
File No. EB-IHD-14-00014244.
2
47 C.F.R. §§ 52.17, 52.32, 54.706, 54.711, 64.604, 64.1195. The Bureau also investigated possible violations by 
Vast of 47 U.S.C. §§ 214, 225, 229, 251, 254, 1001 and 47 C.F.R. §§ 1.1151–1.1152, 1.1154, 1.1156–1.1159, 
1.20005, 54.706, 63.18.
Federal Communications Commission DA 14-487
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3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find the public interest would be served by adopting the Consent Decree and terminating the 
investigation.
4. In the absence of material new evidence relating to this matter, we conclude the 
investigation raises no substantial or material questions of fact as to whether Vast 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,
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and Sections 0.111 and 0.311 of the Rules,
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the Consent 
Decree attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first-class mail and certified mail, return receipt requested, to Cheng-yi Liu, Counsel for Vast 
Communications, LLC, Fletcher, Heald & Hildreth, P.L.C., 1300 North 17th Street, Suite 1100, 
Arlington, VA 22209.
FEDERAL COMMUNICATIONS COMMISSION
William H. Davenport
Deputy Chief, Enforcement Bureau
                                                
3
47 U.S.C. §§ 154(i), 154(j), 503(b).
4
47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 14-487
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Vast Communications, LLC
)
)
)
)
)
)
File No.:  EB-IHD-14-00014244
Acct. No.:  201432080030
FRN:  0019239284
CONSENT DECREE
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission and Vast 
Communications, LLC, by their authorized representatives, hereby enter into this Consent Decree for the 
purpose of terminating the Enforcement Bureau’s investigation into possible violations of Sections 52.17, 
52.32, 54.706, 54.711, 64.604, and 64.1195 of the Commission’s rules governing Universal Service Fund 
contribution and reporting requirements.
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” means 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 Vast is subject by 
virtue of its business activities.
(f) “Compliance Plan” means the compliance obligations, programs, and procedures 
described in this Consent Decree at paragraph 13.
(g) “Covered Employees” means all employees and agents of Vast who perform, or 
supervise, oversee, or manage the performance of duties that relate to Vast’s 
responsibilities under the Communications Laws and the Federal Regulatory 
Reporting Rules.
(h) “Effective Date” means the date on which the Bureau releases the Adopting Order.
                                                
1
47 C.F.R. §§ 52.17, 52.32, 54.706, 54.711, 64.604, 64.1195.
Federal Communications Commission DA 14-487
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(i) “Federal Regulatory Reporting Rules” mean Sections 52.17, 52.32, 54.706, 54.711,
64.604, and 64.1195 of the Rules and other provisions of the Act, the Rules, and 
Commission orders governing related federal regulatory reporting obligations.
(j) “Investigation” means the investigation commenced by the Bureau’s February 13,
2012, letter of inquiry
2
regarding whether the Company violated the Federal 
Regulatory Reporting Rules, among other Communications Laws.
(k) “Operating Procedures” mean the standard, internal operating procedures, and 
compliance policies established by Vast to implement the Compliance Plan.
(l) “Parties” mean Vast Communications, LLC and the Bureau, each of which is a 
“Party.”
(m) “Rules” mean the Commission’s regulations found in Title 47 of the Code of Federal 
Regulations.
(n) “Telecommunications,” “Telecommunications Carrier,” “Telecommunications 
Service” have the meanings set forth in Sections 3(50), 3(51), and 3(53) of the Act, 
47 U.S.C. §§ 153(50), 153(51), 153(53).
(o) “USF” means the Universal Service Fund.
(p) “Vast” or “Company” means Vast Communications, LLC and its affiliates, 
subsidiaries, predecessors-in-interest, and successors-in-interest.
II. BACKGROUND
3. Section 64.1195 of the Rules requires telecommunications carriers that will provide 
interstate telecommunications service to file registration information with the Commission on FCC Form 
499-A.
3
Sections 52.17, 52.32, 54.706, 54.711, and 64.604 of the Rules also require such carriers whose 
USF contribution obligation for a given calendar year is $10,000 or more to file FCC Form 499-Qs, 
which are quarterly telecommunication service reporting worksheets.
4
4. On June 30, 2008, the Commission clarified that audio bridging services are
“telecommunications” under the Act, and that audio bridging service providers are required to contribute 
directly to the USF.
5
The Commission directed audio bridging service providers to comply prospectively 
with the registration and reporting requirements discussed in paragraph 3 above.
6
                                                
2
Letter from Theresa Z. Cavanaugh, Chief, Investigations & Hearings Division, FCC Enforcement Bureau, to 
Cheng-yi Liu, Partner, Counsel for Vast Communications, LLC, Law Offices of Thomas K. Crowe P.C. (Feb. 13, 
2012) (on file in EB-IHD-14-00014244) (LOI).
3
47 C.F.R. § 64.1195.
4
47 U.S.C. § 254(d); 47 C.F.R. §§ 52.17, 52.32, 54.706, 54.711, 64.604.
5
Request for Review by InterCall, Inc. of Decision of Universal Service Administrator, 23 FCC Rcd 10731 (2008)
(InterCall Order), recon. denied, 27 FCC Rcd 898 (2012) (InterCall Reconsideration Order), petition for review 
dismissed in part and denied in part sub nom. Conference Group, LLC v. FCC, 720 F.3d 957 (D.C. Cir. 2013).
6
InterCall Order, 23 FCC Rcd at 10738, para. 24.
Federal Communications Commission DA 14-487
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5. Vast is a California-based corporation that has provided audio bridging 
telecommunications services since February 2009.
7
  Vast’s services allow customers to participate in 
teleconferencing calls by dialing toll-free numbers and entering access codes.
8
In April 2010, Vast self-
disclosed to the Bureau that it failed to comply with certain of its regulatory obligations because it had 
been unaware of the InterCall Order.
9
  Upon learning of that order, Vast conferred with counsel and took 
remedial action to become compliant with the Commission’s Rules and regulations.
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6. The Bureau issued a letter of inquiry (LOI) to Vast requesting information about Vast’s 
failure to comply with its regulatory obligations.
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  Vast responded to the LOI
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and later submitted 
supplemental responses to update the record.
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7. As of the Effective Date, Vast has paid all invoiced amounts to the USF, 
Telecommunications Relay Fund, cost recovery mechanisms for the North American Numbering Plan and 
Local Number Portability administration, and all invoiced regulatory fees.
III. TERMS OF AGREEMENT
8. Adopting Order.  The Parties agree that the provisions of this Consent Decree shall be 
subject to final approval by the Bureau by incorporation of such provisions by reference in the Adopting 
Order.
9. Jurisdiction.  Vast 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.
10. 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.
                                                
7
Letter from Cheng-yi Liu, Counsel for Vast Communications, LLC to Michele Levy Berlove, Acting Assistant 
Division Chief, Investigations & Hearings Division, FCC Enforcement Bureau (Apr. 30, 2010) (on file in EB-14-
IHD-00014244).
8
Id.
9
Id.
10
Id. at 2.
11
Supra note 2.
12
Letter from Cheng-yi Liu, Counsel for Vast Communications, LLC, to Marlene H. Dortch, Secretary, FCC 
(Mar. 12, 2012) (on file in EB-14-IHD-00014244).
13
Letter from Cheng-yi Liu, Counsel for Vast Communications, LLC, to Marlene H. Dortch, Secretary, FCC 
(Mar. 30, 2012); Letter from Cheng-yi Liu, Counsel for Vast Communications, LLC, to Marlene H. Dortch, 
Secretary, FCC (June 24, 2013); Letter from Cheng-yi Liu, Counsel for Vast Communications, LLC, to Marlene H. 
Dortch, Secretary, FCC (Oct. 22, 2013) (on file in EB-14-IHD-00014244).
Federal Communications Commission DA 14-487
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11. 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 termination of the Investigation, Vast 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 Vast 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 this 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 Vast with respect to the Company’s basic qualifications, including its character 
qualifications, to be a Commission licensee or hold Commission licenses or authorizations.
12. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, the 
Company 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 the Company 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 Federal Regulatory Reporting Rules prior to assuming 
his/her duties.
13. Compliance Plan.  For purposes of settling the matters set forth herein, the Company
agrees that it shall, within sixty (60) calendar days after 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 Federal Regulatory Reporting Rules, 
Vast shall implement the following procedures:
(a) Operating Procedures.  Within sixty (60) calendar days after the Effective Date, Vast
shall establish Operating Procedures that all Covered Employees must follow to help 
ensure the Company’s compliance with the Federal Regulatory Reporting Rules.  The 
Company’s Operating Procedures shall include internal procedures and policies 
specifically designed to ensure that the Company complies with the Federal Regulatory 
Reporting Rules. The Company shall also develop a Compliance Checklist that 
describes the steps a Covered Employee must follow to ensure compliance with the 
Federal Regulatory Reporting Rules.
(b) Compliance Manual.  Within sixty (60) calendar days after the Effective Date, the 
Compliance Officer shall develop and distribute a Compliance Manual to all Covered 
Employees.  The Compliance Manual shall explain the Federal Regulatory Reporting 
Rules and set forth the Operating Procedures that Covered Employees shall follow to 
help ensure Vast’s compliance with the Federal Regulatory Reporting Rules.  The 
Company shall periodically review and revise the Compliance Manual as necessary to 
ensure that the information set forth therein remains current and accurate.  Vast shall 
distribute any revisions to the Compliance Manual promptly to all Covered Employees.
(c) Compliance Training Program.  The Company shall establish and implement a 
Compliance Training Program on compliance with the Federal Regulatory Reporting 
Rules and the Operating Procedures.  As part of the Compliance Training Program, 
Covered Employees shall be advised of the Company’s obligation to report any 
noncompliance with the Federal Regulatory Reporting Rules under paragraph 14 of 
Federal Communications Commission DA 14-487
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this Consent Decree and shall be instructed on how to disclose noncompliance to the 
Compliance Officer.  All Covered Employees shall be trained pursuant to the 
Compliance Training Program within sixty (60) calendar days after the Effective Date.  
Any person who becomes a Covered Employee at any time after the Initial Training 
Program shall be trained within thirty (30) calendar days after the date such person 
becomes a Covered Employee.  Vast shall conduct 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.
14. Reporting Noncompliance.  Vast shall report any noncompliance with the Federal 
Regulatory Reporting Rules and with the terms and conditions of this Consent Decree within fifteen (15) 
calendar days after discovery of such noncompliance.  Such reports shall include a detailed explanation of 
(i) each instance of noncompliance; (ii) the steps that the Company 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 the 
Company 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 3-C330, 445 12th Street, S.W. Washington, D.C. 
20554, with a copy submitted electronically to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov, 
William A. Kehoe at William.Kehoe@fcc.gov, and Joy M. Ragsdale at Joy.Ragsdale@fcc.gov.
15. Compliance Reports.  Vast 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 Vast’s efforts during 
the relevant period to comply with the terms and conditions of this Consent Decree 
and the Federal Regulatory Reporting Rules.  In addition, each Compliance Report 
shall include a certification by the Compliance Officer, as an agent of and on behalf 
of the Company, stating that the Compliance Officer has personal knowledge that the 
Company (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 14 of this 
Consent Decree.
(b) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and shall comply with Section 1.16 of the 
Rules and be subscribed to as true under penalty of perjury in substantially the form 
set forth therein.
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(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Vast, 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 the Company has taken or will take to remedy 
such noncompliance, including the schedule on which proposed remedial actions will 
be taken; and (iii) the steps that Vast has taken or will take to prevent the recurrence
of any such noncompliance, including the schedule on which such preventive action 
will be taken.
                                                
14
47 C.F.R. § 1.16.
Federal Communications Commission DA 14-487
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(d) All Compliance Reports shall be submitted to the Chief, Investigations & Hearings 
Division, Enforcement Bureau, Federal Communications Commission, Room
4-C330, 445 12th Street, S.W., Washington, D.C. 20554, with a copy submitted 
electronically to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov, William A.
Kehoe at William.Kehoe@fcc.gov, and Joy M. Ragsdale at Joy.Ragsdale@fcc.gov.
16. Termination Date.  Unless stated otherwise, the obligations set forth in paragraphs 12
through 15 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
17. Section 208 Complaints; Subsequent Investigations.  Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
Section 208 of the Act
15
against Vast or its affiliates for alleged violations of the Act, 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 Vast with the Communications Laws.
18. Voluntary Contribution.  Vast agrees that it will make a voluntary contribution to the 
United States Treasury in the amount of Ninety Thousand Dollars ($90,000) (Voluntary Contribution).  
Such Voluntary Contribution shall be made in installments (each an Installment Payment).  The first 
Installment Payment in the amount of Ten Thousand Dollars ($10,000) is due on May 1, 2014.  
Thereafter, an Installment Payment of Four Thousand Dollars ($4,000) is due and payable on the first day 
of each consecutive succeeding month for nineteen months.  The balance of the Voluntary Contribution in 
the amount of Four Thousand Dollars ($4,000) is due and payable on January 1, 2016 (Maturity Date).  
Vast acknowledges and agrees that upon execution of this Consent Decree, the Voluntary Contribution 
and each Installment Payment shall become a “Claim” or “Debt” as defined in 31 U.S.C. § 3701(b)(1).
16
  
Upon an Event of Default (as defined below), all procedures for collection as permitted by law may, at the 
Commission’s discretion, be initiated.  In addition, Vast agrees that it will make the first and all 
subsequent Installment Payments in United States Dollars without further demand or notice by the dates 
specified above.  Vast shall also send electronic notification of payment to Theresa Z. Cavanaugh at 
Terry.Cavanaugh@fcc.gov, William A. Kehoe at William.Kehoe@fcc.gov, and Joy M. Ragsdale at 
Joy.Ragsdale@fcc.gov on the date said Installment Payments are made.
19. Installment Payments must be made by check or similar instrument, wire transfer, or 
credit card, and must include the Account Number and FRN referenced in the caption to the Adopting 
Order.  Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice) must be 
submitted.
17
  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:
? 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.
                                                
15
47 U.S.C. § 208.
16
Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996).
17
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
Federal Communications Commission DA 14-487
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? 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.
Questions regarding payment procedure should be addressed to the Financial Operations Group Help 
Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
20. Event of Default.  Vast agrees that an Event of Default shall occur upon the failure by 
the Company to pay the full amount of any Installment Payment on or before the due dates specified in 
this Consent Decree.
21. Interest, Charges for Collection, and Acceleration of Maturity Date.  After an Event 
of Default has occurred under this Consent Decree, the then unpaid amount of the Voluntary Contribution 
shall accrue interest, computed using the U.S. Prime Rate in effect on the date of the Event of Default 
plus 4.75 percent, from the date of the Event of Default until payment in full.  Upon an Event of Default, 
the then unpaid amount of the Voluntary Contribution, together with interest, as aforesaid, any penalties 
permitted and/or required by the law, including but not limited to 31 U.S.C. § 3717 and administrative 
charge(s), plus the costs of collection, litigation, and attorneys’ fees, shall become immediately due and 
payable, without notice, presentment, demand, protest, or notice of protest of any kind, all of which are 
waived by Vast.
22. Waivers.  Vast 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 in this Consent 
Decree.  Vast 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 Vast nor the Commission shall contest 
the validity of the Consent Decree or the Adopting Order, and Vast shall waive any statutory right to a 
trial de novo.  Vast hereby agrees to waive any claims it may otherwise have under the Equal Access to 
Justice Act
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relating to the matters addressed in this Consent Decree.
23. 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.
24. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent rule or order adopted by the Commission (except an order 
specifically intended to revise the terms of this Consent Decree to which the Company does not expressly 
consent) that provision will be superseded by such Commission rule or order.
25. Successors and Assigns.  The Company agrees that the provisions of this Consent 
Decree shall be binding on its successors, assigns, and transferees.
                                                
18
5 U.S.C. § 504; 47 C.F.R. Part 1, Subpart K.
Federal Communications Commission DA 14-487
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26. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.  The Parties further 
agree that this Consent Decree does not constitute either an adjudication on the merits or a factual or legal 
finding or determination regarding any compliance or noncompliance with the Communications Laws.
27. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
28. 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.
29. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree. Each Party 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.
30. Counterparts.  This Consent Decree may be signed in counterpart (including by 
facsimile).  Each counterpart, when executed and delivered, shall be an original, and all of the
counterparts together shall constitute one and the same fully executed instrument.
________________________________
Theresa Z. Cavanaugh
Chief
Investigations and Hearings Division
Enforcement Bureau
________________________________
Date
________________________________
Theodore F. Heieck
President
Vast Communications, LLC
________________________________
Date