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 JOINT  STATEMENT  OF  COMMISSIONERS  MICHAEL  J.  COPPS  AND  JONATHAN  S.  ADELSTEIN 
 CONCURRING  IN  PART  AND  DISSENTING  IN  PART 


 Re:  High  I-  Q  Radio,  Inc.,  Noncommercial  Educational  FM  Station  KOLI(  FM),  Electra,  Texas,  Memorandum  Opinion  and  Order 


 This  case  is  replete  with  violations  of  Commission  rules,  including  the  unauthorized  commencement  of  commercial  operations  for  a  noncommercial  permittee;  an  unauthorized  transfer  of  control  of  the  station;  and 
 failure  to  file  required  documents  with  the  Commission.  We  concur  in  these  findings. 
 Each  of  these  violations  would  ordinarily  be  subject  to  a  fine  or  further  enforcement  action.  Yet,  the  Order  concludes  that  no  further  action  is  warranted  on  some  violations,  and  that  the  lengthy  delay  in  this  case 
 prevents  the  Commission  from  fining  the  parties  for  other  violations  because  the  statute  of  limitations  has  expired.  So  ultimately,  Cumulus,  the  entity  that  prematurely  assumed  control  of  the  station,  walks  away  with 
 a  minor  warning,  all  necessary  FCC  authorizations  and  a  clean  slate. 
 Because  we  are  not  convinced  that  this  case  raises  no  major  questions  for  further  inquiry,  we  dissent  in  part. 
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