Federal Communications Commission FCC 07-131 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Extreme Leads, Inc. Apparent Liability for Forfeiture ) ) ) ) ) ) ) ) ) File No. EB-07-TC-2005 NAL/Acct. No. 200732170067 FRN: 0016769630 NOTICE OF APPARENT LIABILITY FOR FORFEITURE Adopted: July 30, 2007 Released: July 31, 2007 By the Commission: I. INTRODUCTION 1. In this Notice of Apparent Liability for Forfeiture (“NAL”)1, we find that Extreme Leads, Inc. (“Extreme Leads”)2 apparently willfully or repeatedly violated section 227 of the Communications Act of 1934, as amended (“Act”), and the Commission’s related rules and orders, by delivering at least 218 unsolicited advertisements to the telephone facsimile machines of at least 132 consumers.3 Based on the facts and circumstances surrounding these apparent violations, we find that Extreme Leads is apparently liable for a forfeiture in the amount of $1,377,000. 1 See 47 U.S.C. § 503(b)(1). The Commission has the authority under this section of the Act to assess a forfeiture against any person who has “willfully or repeatedly failed to comply with any of the provisions of this Act or of any rule, regulation, or order issued by the Commission under this Act ....” See also 47 U.S.C. § 503(b)(5) (stating that the Commission has the authority under this section of the Act to assess a forfeiture penalty against any person who does not hold a license, permit, certificate or other authorization issued by the Commission or an applicant for any of those listed instrumentalities so long as such person (A) is first issued a citation of the violation charged; (B) is given a reasonable opportunity for a personal interview with an official of the Commission, at the field office of the Commission nearest to the person’s place of residence; and (C) subsequently engages in conduct of the type described in the citation). 2 According to publicly available information, Extreme Leads is also doing business as ELI, Inc. (“ELI”). Therefore, all references in this NAL to “Extreme Leads” encompass Extreme Leads as well as ELI. Extreme Leads has offices at 3346 Auburn Rd, Auburn Hills, MI 48326-3310 and 6001 N. Adams Rd, Ste 103, Bloomfield Hills, MI 48304-1575. Marc Carlson, Nick Mancino and Steve Anderson are listed as contact persons for Extreme Leads. Accordingly, all references in this NAL to “Extreme Leads” also encompass the foregoing individuals and all other principals and officers of this entity, as well as the corporate entity itself. 3 See 47 U.S.C. § 227(b)(1)(C); 47 C.F.R. § 64.1200(a)(3); see also Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Report and Order and Third Order on Reconsideration, 21 FCC Rcd 3787 (2006). Federal Communications Commission FCC 07-131 2 II. BACKGROUND 2. Section 227(b)(1)(C) of the Act makes it “unlawful for any person within the United States, or any person outside the United States if the recipient is within the United States . . . to use any telephone facsimile machine, computer, or other device to send, to a telephone facsimile machine, an unsolicited advertisement.”4 The term “unsolicited advertisement” is defined in the Act and the Commission’s rules as “any material advertising the commercial availability or quality of any property, goods, or services which is transmitted to any person without that person’s prior express invitation or permission in writing or otherwise.”5 Under the Commission’s Rules, there is an “established business relationship”6 exception that permits a party to deliver a message to a consumer if the sender has an established business relationship with the recipient and the sender obtained the number of the facsimile machine through the voluntary communication by the recipient, directly to the sender, within the context of the established business relationship, or through a directory, advertisement, or a site on the Internet to which the recipient voluntarily agreed to make available its facsimile number for public distribution.7 3. On June 14, 2006, in response to one or more consumer complaints alleging that Extreme Leads had faxed unsolicited advertisements, the Commission staff issued a citation8 to Extreme Leads, pursuant to section 503(b)(5) of the Act.9 The staff cited Extreme Leads for using a telephone facsimile machine, computer, or other device, to send unsolicited advertisements to a telephone facsimile machine, in violation of section 227 of the Act and the Commission’s related rules and orders. The citation, which the staff served by certified mail, return receipt requested, warned Extreme Leads that subsequent violations could result in the imposition of monetary forfeitures of up to $11,000 per violation, and included a copy of the consumer complaints that formed the basis of the citation.10 The citation informed Extreme Leads that within 30 days of the date of the citation, it could either request an interview with Commission staff, or could provide a written statement responding to the citation. Extreme Leads did not request an interview or otherwise respond to the citation. 4. Despite the citation’s warning that subsequent violations could result in the imposition of monetary forfeitures, we have received 147 additional consumer complaints indicating that Extreme Leads continued to engage in such conduct after receiving the citation.11 We base our action here 4 47 U.S.C. § 227(b)(1)(C); 47 C.F.R. § 64.1200(a)(3). 5 47 U.S.C. §227(a)(4); 47 C.F.R. §64.1200 (f)(13). 6 An “established business relationship” is defined as a prior or existing relationship formed by a voluntary two-way communication “with or without an exchange of consideration, on the basis of an inquiry, application, purchase or transaction by the business or residential subscriber regarding products or services offered by such person or entity, which relationship has not been previously terminated by either party.” 47 C.F.R. § 64.1200(f)(5). 7 See 47 U.S.C. § 227(b)(1)(C); 47 C.F.R. § 64 (a)(3)(i), (ii). 8 Citation from Kurt A. Schroeder, Deputy Chief, Telecommunications Consumers Division, Enforcement Bureau, File No. EB-06-TC-117, issued to Extreme Leads on June 14, 2006. 9 See 47 U.S.C. § 503(b)(5) (authorizing the Commission to issue citations to persons who do not hold a license, permit, certificate or other authorization issued by the Commission or an applicant for any of those listed instrumentalities for violations of the Act or of the Commission’s rules and orders). 10 Commission staff mailed the citation to ELI, Inc., a.k.a. Extreme Leads, Inc., Attn. Jeffrey Wilson, 3346 Auburn Road, P.O. Box 334, Auburn Hills, MI 48326; Extreme Leads, Inc., Attn. Jeffrey Wilson, 6001 N Adams Rd, Bloomfield Hills, MI 48304; and Extreme Leads, Inc., Attn. Jeffrey Wilson, 30750 Tanglewood Drive, Novi, MI 48377. See n.2, supra. 11 See Appendix for a listing of the consumer complaints against Extreme Leads requesting Commission action. Federal Communications Commission FCC 07-131 3 specifically on complaints filed by 132 consumers establishing that Extreme Leads continued to send 218 unsolicited advertisements to telephone facsimile machines after the date of the citation.12 5. Section 503(b) of the Act authorizes the Commission to assess a forfeiture of up to $11,000 for each violation of the Act or of any rule, regulation, or order issued by the Commission under the Act by a non-common carrier or other entity not specifically designated in section 503 of the Act.13 In exercising such authority, we are to 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.”14 III. DISCUSSION A. Violations of the Commission’s Rules Restricting Unsolicited Facsimile Advertisements 6. We find that Extreme Leads apparently violated section 227 of the Act and the Commission’s related rules and orders by using a telephone facsimile machine, computer, or other device to send at least 218 unsolicited advertisements to the 132 consumers identified in the Appendix. This NAL is based on evidence that these consumers received unsolicited fax advertisements from Extreme Leads after the Bureau’s citation. The facsimile transmissions advertise mortgage services and other financial services. Further, according to the complaints, the consumers neither had an established business relationship with Extreme Leads nor gave Extreme Leads permission to send the facsimile transmissions.15 The faxes at issue here therefore fall within the definition of an “unsolicited advertisement.”16 Based on the entire record, including the consumer complaints, we conclude that Extreme Leads apparently violated section 227 of the Act and the Commission’s related rules and orders by sending 218 unsolicited advertisements to 132 consumers’ facsimile machines. B. Proposed Forfeiture 7. We find that Extreme Leads is apparently liable for a forfeiture in the amount of $1,377,000. Although the Commission’s Forfeiture Policy Statement does not establish a base forfeiture amount for violating the prohibition against using a telephone facsimile machine to send unsolicited advertisements, the Commission has previously considered $4,500 per unsolicited fax advertisement to be 12 We note that evidence of additional instances of unlawful conduct by Extreme Leads may form the basis of subsequent enforcement action. 13 Section 503(b)(2)(C) provides for forfeitures up to $10,000 for each violation in cases not covered by subparagraph (A) or (B), which address forfeitures for violations by licensees and common carriers, among others. See 47 U.S.C. § 503(b). In accordance with the inflation adjustment requirements contained in the Debt Collection Improvement Act of 1996, Pub. L. 104-134, Sec. 31001, 110 Stat. 1321, the Commission implemented an increase of the maximum statutory forfeiture under section 503(b)(2)(C) to $11,000. See 47 C.F.R. §1.80(b)(3); Amendment of Section 1.80 of the Commission’s Rules and Adjustment of Forfeiture Maxima to Reflect Inflation, 15 FCC Rcd 18221 (2000); see also Amendment of Section 1.80(b) of the Commission’s Rules and Adjustment of Forfeiture Maxima to Reflect Inflation, 19 FCC Rcd 10945 (2004) (this recent amendment of section 1.80(b) to reflect inflation left the forfeiture maximum for this type of violator at $11,000). 14 47 U.S.C. § 503(b)(2)(D); 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, 17100-01 para. 27 (1997) (Forfeiture Policy Statement), recon. denied, 15 FCC Rcd 303 (1999). 15 See, e.g., complaints dated October 30, 2006 and November 1, 2006, from Melvin Freund. All of the complainants involved in this action are listed in the Appendix below. 16 See 47 U.S.C. § 227(a)(4); 47 C.F.R. § 64.1200(f)(13) (definition previously at § 64.1200(f)(10)). Federal Communications Commission FCC 07-131 4 an appropriate base amount.17 We apply that base amount to each of 146 of the apparent violations. In addition, where the consumer requests the company to stop sending facsimile messages, and the company continues to send them, the Commission has previously considered $10,000 per unsolicited fax advertisement the appropriate forfeiture for violations associated with such egregious behavior.18 Here, 38 consumers specifically requested that Extreme Leads cease sending facsimiles. Notwithstanding these requests, an additional 56 facsimiles were sent to these consumers. In nine instances, consumers were unable to request that the company refrain from sending additional unsolicited facsimiles because the telephone number provided by Extreme Leads specifically for removal requests was either invalid, disconnected, or otherwise did not work.19 These consumers received 16 facsimiles. We find such behavior justifies a forfeiture amount higher than the base amount because it circumvents consumer attempts to request that the company stop sending facsimile messages. We believe that assessing a higher forfeiture amount is warranted based on the nature and gravity of the violations and the continued need to ensure compliance with section 227 of the Act and the Commission’s rules and orders. Accordingly, we apply the $10,000 amount to each of these 72 apparent violations where the consumer requested or attempted to request that Extreme Leads discontinue its faxing. Thus, a total forfeiture of $1,377,000 is proposed. Extreme Leads will have the opportunity to submit evidence and arguments in response to this NAL to show that no forfeiture should be imposed or that some lesser amount should be assessed.20 IV. CONCLUSION AND ORDERING CLAUSES 8. We have determined that Extreme Leads, Inc. apparently violated section 227 of the Act and the Commission’s related rules and orders by using a telephone facsimile machine, computer, or other device to send at least 218 unsolicited advertisements to the 132 consumers identified in the Appendix. We have further determined that Extreme Leads, Inc. is apparently liable for a forfeiture in the amount of $1,377,000. 9. Accordingly, IT IS ORDERED, pursuant to section 503(b) of the Act, 47 U.S.C. § 503(b), and section 1.80 of the Rules, 47 C.F.R. § 1.80, that Extreme Leads, Inc. is hereby NOTIFIED of this APPARENT LIABILITY FOR A FORFEITURE in the amount of $1,377,000 for willful or repeated violations of section 227(b)(1)(C) of the Communications Act, 47 U.S.C. § 227(b)(1)(C), sections 64.1200(a)(3) of the Commission’s rules, 47 C.F.R. § 64.1200(a)(3), and the related orders described in the paragraphs above. 17 See Get-Aways, Inc., Notice of Apparent Liability For Forfeiture, 15 FCC Rcd 1805 (1999); Get-Aways, Inc., Forfeiture Order, 15 FCC Rcd 4843 (2000); see also US Notary, Inc., Notice of Apparent Liability for Forfeiture, 15 Rcd 16999 (2000); US Notary, Inc., Forfeiture Order, 16 FCC Rcd 18398 (2001); Tri-Star Marketing, Inc., Notice of Apparent Liability For Forfeiture, 15 FCC Rcd 11295 (2000); Tri-Star Marketing, Inc., Forfeiture Order, 15 FCC Rcd 23198 (2000). 18 See Carolina Liquidators, Inc., Notice of Apparent Liability for Forfeiture, 15 FCC 16,837, 16,842 (2000); 21st Century Fax(es) Ltd., AKA 20th Century Fax(es), Notice of Apparent Liability for Forfeiture, 15 FCC Rcd 24,406, 24,411 (2000). 19 See, e.g., complaint dated August 1, 2006, from Howard M. Greene (stating that calling the opt-out number resulted in a recording indicating that the “the number is not in service.”); complaint dated September 18, 2006, from John E. Turner (stating that “neither [removal] number connected to anything”); complaint dated September 26, 2006, from Gwyn Reed (stating that calling the fax removal number resulted in the following voice message recording: “52-4. Number is invalid or number has been blocked you’re your area code.”); complaint received September 25, 2006, from Dale I. Meyer (stating that all “stop” numbers are “disconnected or non-working.”); complaint received October 23, 2006, from Phillip W. Watson (stating that “[o]f the 5 different opt-out numbers on these faxes, none worked for me.”). The complainants involved in these actions are listed in the Appendix below. 20 See 47 U.S.C. § 503(b)(4)(C); 47 C.F.R. § 1.80(f)(3). Federal Communications Commission FCC 07-131 5 10. IT IS FURTHER ORDERED THAT, pursuant to section 1.80 of the Commission’s rules,21 within thirty (30) days of the release date of this Notice of Apparent Liability for Forfeiture, Extreme Leads, Inc. SHALL PAY the full amount of the proposed forfeiture or SHALL FILE a written statement seeking reduction or cancellation of the proposed forfeiture. 11. Payment by check or money order, payable to the order of the “Federal Communications Commission,” may be mailed to Forfeiture Collection Section, Finance Branch, Federal Communications Commission, P.O. Box 358340, Pittsburgh, PA 15251. Payment by overnight mail may be sent to Mellon Client Service Center, 500 Ross Street, Room 670, Pittsburgh, PA 15262-0001, Attn: FCC Module Supervisor. Payment by wire transfer may be made to: ABA Number 043000261, receiving bank Mellon Bank, and account number 911-6229. The payment should note NAL/Acct. No. 200732170067. 12. The response, if any, must be mailed both to the Office of the Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, ATTN: Enforcement Bureau – Telecommunications Consumers Division, and to Colleen Heitkamp, Chief, Telecommunications Consumers Division, Enforcement Bureau, Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, and must include the NAL/Acct. No. referenced in the caption. 13. The Commission will not consider reducing or canceling a forfeiture in response to a claim of inability to pay unless the petitioner submits: (1) federal tax returns for the most recent three- year period; (2) financial statements prepared according to generally accepted accounting practices; or (3) some other reliable and objective documentation that accurately reflects the petitioner’s current financial status. Any claim of inability to pay must specifically identify the basis for the claim by reference to the financial documentation submitted. 14. Requests for payment of the full amount of this Notice of Apparent Liability for Forfeiture under an installment plan should be sent to: Chief, Revenue and Receivables Operations Group, 445 12th Street, SW, Washington, DC 20554.22 15. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for Forfeiture shall be sent by Certified Mail Return Receipt Requested to Extreme Leads, Inc., Attention: Marc Carlson, Nick Mancino and Steve Anderson, 3346 Auburn Rd, Auburn Hills, MI 48326-3310 and 6001 N. Adams Rd, Ste 103, Bloomfield Hills, MI 48304-1575. FEDERAL COMMUNICATIONS COMMISSION Marlene H. Dortch Secretary 21 47 C.F.R. § 1.80. 22 47 C.F.R. § 1.1914. Federal Communications Commission FCC 07-131 6 APPENDIX Complainant sent facsimile solicitations Violation Date(s) Alfred K. Kornel 10/3/2006 Allen Hart 9/21/2006 Allen S. Greene 8/9/2006 Allen S. Greene 8/10/2006 Allen S. Greene 8/30/2006 Allen S. Greene 9/5/2006 Allen S. Greene 9/11/2006 Allen S. Greene 9/20/2006 Allen S. Greene 10/3/2006 Allen S. Greene 10/12/2006 Allyn Taylor 10/3/2006 Anthony J. Papania 10/31/2006 Ben J. Hofmeister 8/17/2006 Ben J. Hofmeister 8/23/2006 Ben J. Hofmeister 8/30/2006 Berry & Rita Shelton 9/13/2006 Bob Mitchell 10/2/2006 Bob Pianka 8/2/2006 Burt Hoffman 7/31/2006 Burt Hoffman 8/2/2006 Cecilia Elguera 10/19/2006 David A. Hawkins 10/31/2006 David A. Hawkins 11/8/2006 David G Kanter 9/19/2006 David Gamble 10/11/2006 David L. Everson 8/28/2006 David L. Everson 9/7/2006 David Solinske 8/1/2006 David Solinske 8/15/2006 David Wisniewski 9/11/2006 Dawn D Colwell 7/31/2006 Donald E. Cullman 8/24/2006 Donald F. Vogt 11/7/2006 Eleanor Robbins 8/2/2006 Eleanor Robbins 8/7/2006 Frank Chickey 8/17/2006 Frank Chickey 8/31/2006 Franklin D. Self 9/11/2006 Geoffrey L. Denempont 8/2/2006 George Welles 8/3/2006 Glen L. Kapitawovich 8/7/2006 Graham Ginsberg 8/9/2006 Gwendolyn Warrick 8/16/2006 Jaime Lewis 8/1/2006 James L. Goines 8/2/2006 Jason P. Sheaffer 7/31/2006 Federal Communications Commission FCC 07-131 7 Complainant sent facsimile solicitations Violation Date(s) Jerrold Feigenbaum 9/21/2006 Jerrold Feigenbaum 9/25/2006 Jerrold Feigenbaum 9/26/2006 Jerrold Feigenbaum 9/27/2006 Jerrold Feigenbaum 10/2/2006 Jerrold Feigenbaum 10/3/2006 Jerry Mandel 9/5/2006 Jessyca L. Howell 9/13/2006-9/27/2006 Jessyca L. Howell 9/13/2006-9/27/2006 Jessyca L. Howell 9/13/2006-9/27/2006 Jim Pelletier 10/10/2006 Jim Pelletier 10/18/2006 Joanne M. Carbana 8/23/2006 Joe Carson 8/3/2006 Joe Carson 9/14/2006 John Alexander 9/13/2006 Jon Roberts 8/16/2006 Jon Roberts 8/17/2006 Jonathan Bernon 8/16/2006 Jonathan Bernon 8/22/2006 Jonathan Bernon 8/22/2006 Jonathan Bernon 8/29/2006 Jonathan Bernon 9/7/2006 Joseph Blumenthal 8/1/2006 Julia B. Norman 10/5/2006 Julia B. Norman 10/11/2006 Kathryn L. Nelson 8/16/2006 Kathryn L. Nelson 8/18/2006 Kathryn L. Nelson 8/21/2006 Kathryn L. Nelson 8/30/2006 Kathryn L. Nelson 9/11/2006 Kathryn L. Nelson 9/21/2006 Kathryn L. Nelson 9/26/2006 Kenny Stewart 10/19/2006 Kristen A. Henderson 8/1/2006 Laura Lillie 10/10/2006 Linda B Evans 8/15/2006 Linda Brown 10/2/2006 Linda Edelmann 9/28/2006 Linda Edelmann 10/3/2006 Linda Edelmann 10/5/2006 Linda Edelmann 10/24/2006 Linda Edelmann 11/7/2006 M R Terelmes 8/10/2006 Mark D. Roberts 10/16/2006 Mark D. Roberts 10/25/2006 Mark Kotyuk 10/5/2006 Mary Johnson 9/21/2006 Mary Johnson 9/25/2006 Federal Communications Commission FCC 07-131 8 Complainant sent facsimile solicitations Violation Date(s) Mary Johnson 9/26/2006 Mary Johnson 9/27/2006 Mary Johnson 9/27/2006 Megan Seaborn 8/21/2006 Melvin Freund 10/30/2006 Melvin Freund 11/1/2006 Michael D. Bloom 10/9/2006 Nancy E. Bockstael 8/24/2006 Nancy E. Bockstael 9/6/2006 Nancy E. Bockstael 9/18/2006 Nancy Miller Springman 10/17/2006 Nancy Overson 9/5/2006 Nicole McMahan 8/10/2006 Nicole McMahan 10/18/2006 Paul K Hemmer 8/17/2006 Rhonda Stuteman 10/23/2006 Rich Heinrich 9/26/2006 Richard C. Lambert 9/26/2006 Richard Holloway 10/9/06 Richard M. Lucas 8/2/2006 Richard M. Lucas 8/8/2006 Richard M. Lucas 10/16/2006 Rita M. Gloner 8/21/2006 Rita M. Gloner 8/23/2006 Robert A. Cosgrove 10/26/2006 Robert A. Cosgrove 10/31/2006 Robert C Bigrigg 8/16/2006 Robert C Bigrigg 8/24/2006 Robert L King 8/21/2006 Robert Mahoney 8/17/2006 Robert T Evans 8/2/2006 Robert T. Plumb 9/13/2006 Ron Kielb 8/21/2006 Ronald Pearlman 8/17/2006 Russell Owen 10/3/2006 Russell Owen 10/3/2006 S. John Chander 8/10/2006 S. John Chander 8/14/2006 Sandra S. Bockes 10/12/2006 Sandra S. Bockes 10/30/2006 Santo Casella 8/22/2006 Stephen Guss 8/28/2006 Steven L Turco 8/28/2006 Sulu Demirpolat 8/22/2006 Susan Knopfle 8/31/2006 Susan Knopfle 9/7/2006 Suzanne M. Ishi 8/28/2006 Thomas G. Kamp 9/25/2006 Thomas Hennessey 8/2/2006 Federal Communications Commission FCC 07-131 9 Complainant sent facsimile solicitations Violation Date(s) Van Wood 10/26/2006 William J. Coulston 9/26/2006 Complainant sent facsimile solicitations after requesting no more be sent Violation Date(s) Alicia C. Underwood-Zollar 8/24/2006 Bradley D. Roth 8/23/2006 David L. Patton 9/26/2006 Delight C. Brown 10/3/2006 Diana C. Bolivar 8/2006 Eileen Mouly 9/5/2006 Eileen Mouly 9/27/2006 Eleanor Robbins 8/8/2006 Evelyn Berg 8/1/2006 Evelyn Giso 9/13/2006 Fatmi Anders 7/31/2006 Fatmi Anders 8/2/2006 Fatmi Anders 8/31/2006 Fatmi Anders 9/7/2006 Fatmi Anders 9/20/2006 Fatmi Anders 10/3/2006 Geoffrey L. Denempont 8/7/2006 Glen L. Kapitawovich 9/26/2006 Glen L. Kapitawovich 10/4/2006 Glen L. Kapitawovich 10/5/2006 Harold B. Smith 10/11/2006 James Robert Myers, Jr. 10/23/2006 James T. Valley 8/30/2006 Jeni K. Manago 8/2/2006 Jeni K. Manago 8/9/2006 Jeremy Dealke 9/13/2006 Jill B. Grossman 9/28/2006 Jill B. Grossman 9/27/2006 Jim P. Willingham 9/11/2006 John Fulford 9/6/2006 Kandie Press 9/20/2006 Karen L. Bays 8/28/2006 Linda C. Wierbza 7/31/2006 Linda C. Wierbza 8/2/2006 Luanne M. O'Keefe 8/29/2006 Mark M. Warner 11/9/2006 Mark M. Warner 11/9/2006 Mike Witkowski 9/26/2006 Federal Communications Commission FCC 07-131 10 Complainant sent facsimile solicitations after requesting no more be sent Violation Date(s) Nancy Sweetman 8/30/2006 Natural Resources Consulting, Inc 8/2/2006 Natural Resources Consulting, Inc 8/3/2006 Natural Resources Consulting, Inc 8/8/2006 Natural Resources Consulting, Inc 8/28/2006 Oshunrire Naomi O James 8/31/2006 Oshunrire Naomi O James 9/11/2006 Pedro F. Mora 9/20/2006 Ramesh Keswani 10/26/2006 Richard Braunstein 8/28/2006 Richard Braunstein 9/6/2006 Robert Steele 10/2/2006 Roger Easterling 10/2/2006 Roy G. Saltman 7/31/2006 Stephen Antisdel 8/22/2006 Stephen Antisdel 10/2/2006 Tiffany Keller 8/21/2006 William H. Seigel 10/23/2006 Complainant actively attempted to request that no more facsimile solicitations be sent Violation Date(s) Allan Lippman 8/31/2006 Dale I. Meyer 9/6/2006 Gwyn Reed 9/13/2006 Howard M. Greene 7/31/2006 Howard M. Greene 8/1/2006 Joan A. Pope 10/12/2006 John E Turner 9/11/2006 John E Turner 9/18/2006 Mark E. Logan 8/1/2006 Pamela E. Morrell 8/23/2006 Pamela E. Morrell 9/7/2006 Phillip W. Watson 8/17/2006 Phillip W. Watson 8/24/2006 Phillip W. Watson 8/28/2006 Phillip W. Watson 8/31/2006 Phillip W. Watson 9/14/2006