Federal Communications Commission FCC 08-107
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Sears Roebuck and Co.
Kmart Corporation
 
Hoffman Estates, Illinois
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File Number EB-07-RC-002
NAL/Acct. No. 200732200001
FRN # 0007050388
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted:  April 9, 2008 Released: April 10, 2008
By the Commission:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (“NAL”), we find that Sears Roebuck and 
Co. (“Sears Roebuck”) and Kmart Corporation (“Kmart”) (collectively “Sears”)1 apparently willfully and 
repeatedly violated Section 15.117(k) of the Commission's Rules (“Rules”)2 by failing to place the required 
Consumer Alert label immediately adjacent to and clearly associated with television receiving equipment 
that contains an analog broadcast television tuner but does not contain a digital broadcast television tuner 
(hereinafter “analog-only tuner”) that it displayed or offered for sale or rent.  We conclude, pursuant to 
Section 503(b) of the Communications Act of 1934, as amended (“Act”),3 that Sears is apparently liable for 
a forfeiture in the amount of one million ninety-six thousand dollars ($1,096,000).4
II. BACKGROUND
2. Congress has established February 17, 2009 as the deadline for the end of analog 
transmissions for full power television stations.  The Commission is statutorily obligated to promote the 
orderly transition to digital television, “a critical step in the evolution of broadcast television.”5 As we 
stated previously, “[w]e are committed to ensuring the rapid completion of that transition in a way that 
delivers the greatest possible benefits to the viewing public.”6 As part of that commitment and in light of 
the upcoming deadline, we recently announced that “it is necessary and appropriate to require retailers to 
provide consumers with information regarding this transition date at the point of sale.”7 We reached this 
  
1 Sears Roebuck and Co. and Kmart Corporation are wholly-owned subsidiaries of Sears Holdings Management 
Corporation.
2 47 C.F.R. § 15.117(k).
3 47 U.S.C. § 503(b).  
4 This amount represents a proposed based forfeiture amount of $320,000 for Sears Roebuck and $776,000 for 
Kmart.  See Attachment B for the calculation of the proposed forfeiture amounts.
5 2002 Biennial Regulatory Review, Report and Order and Notice of Proposed Rulemaking, 18 FCC Rcd 13620, 
13825 ¶ 532 (2003).  
6 Id.
7 Second Periodic Review of the Commission’s Rules and Policies Affecting the Conversion To Digital Television, 
(continued....)
Federal Communications Commission FCC 08-107
2
conclusion after determining that consumer electronics industry efforts had not adequately informed 
consumers how analog-only television equipment purchased now will function when the transition to 
digital broadcasting ends.8  
3. To ensure that consumers do not inadvertently buy analog-only television equipment 
without understanding that such devices will not be capable of receiving off-the-air television reception of 
digital signals after analog broadcasting ends unless connected to a digital-to-analog converter or a digital 
subscription service, we adopted rules requiring anyone that sells, offers for sale, or rents television 
receiving equipment that does not contain a digital television (“DTV”) tuner to display a Consumer Alert 
at the point of sale.9 This requirement also applies to the sale or rent of analog-only television receiving 
equipment via direct mail, catalog, or electronic means (e.g., the Internet).  These requirements are 
contained in Section 15.117(k) of the Rules, which became effective on May 25, 2007.10
4. Section 15.117(k)(3) of the Rules requires that the Consumer Alert contain the following 
language:
The Consumer Alert must be in a size of type large enough to be clear, conspicuous and readily legible, 
consistent with the dimensions of the equipment and the label.  The alert either must be printed on a 
transparent material and affixed to the screen, in a manner that is removable by the consumer and does 
not obscure the picture when displayed for sale, or displayed separately immediately adjacent to each 
television receiver offered for sale and clearly associated with the analog-only model to which it 
pertains.11 In the case of other analog-only video devices that do not include a display (e.g., VCRs, DVD 
players), the Consumer Alert must be in a prominent location on the device, such as on the top or front, or 
displayed separately immediately adjacent to and clearly associated with the analog-only model to which 
it pertains.12  To the extent that any persons display or offer for sale or rent via direct mail, catalog, or 
electronic means analog-only television receiving equipment, they must prominently display the 
Consumer Alert as part of all advertisements or descriptions of such television receiving equipment, in 
  
(...continued from previous page)
Second Report and Order, 22 FCC Rcd 8776 at ¶ 1 (2007) (“Second DTV Periodic Report and Order”).
8 Id. at ¶ 10.
9 Second DTV Periodic Report and Order at ¶ 14.  See 47 C.F.R. § 15.117(k).  In the Second DTV Periodic Report 
and Order, the Commission defined “point of sale” as the “place where televisions are displayed for consumers prior 
to purchase.”  See Second DTV Periodic Report and Order at n.29.
10 Second Periodic Review in the Commission’s Rules and Policies Affecting the Conversion to Digital Television, 
72 Fed. Reg. 28894-01 (May 23, 2007).
11 47 C.F.R. § 15.117(k)(1).
12 Id.
CONSUMER ALERT
This television receiver has only an analog broadcast tuner and will require a converter box after 
February 17, 2009, to receive over-the-air broadcasts with an antenna because of the Nation’s 
transition to digital broadcasting.  Analog-only TVs should continue to work as before with cable 
and satellite TV services, gaming consoles, VCRs, DVD players, and similar products.  For more 
information, call the Federal Communications Commission at 1-888-225-5322 (TTY: 1-888-835-
5322) or visit the Commission’s digital television website at: www.dtv.gov.
Federal Communications Commission FCC 08-107
3
clear and conspicuous print, and in close proximity to any images or descriptions of such equipment.13  
5. Immediately after the rule became effective, the Commission’s Enforcement Bureau began 
inspecting hundreds of stores throughout the country, as well as dozens of popular retailer websites, and 
observed many models of analog-only television receiving equipment on display without the required 
Consumer Alert labels.  On June 1, 2007, the Enforcement Bureau issued a Citation to Sears Roebuck for 
offering for sale television receiving equipment having an analog-only tuner without displaying the required 
Consumer Alert in close proximity.14 Between June 1, 2007 and June 11, 2007, the Enforcement Bureau 
conducted inspections at numerous stores and, based on those inspections, issued additional Citations to 
Sears Roebuck for violations at its stores.15  On June 7, 2007, the Enforcement Bureau issued a Citation to 
Sears Roebuck for offering for sale on its online retail outlet, www.sears.com, television receiving 
equipment having an analog-only tuner without displaying the required Consumer Alert in close 
proximity.16 On May 31, 2007, the Enforcement Bureau issued a Citation to Kmart for offering for sale 
television receiving equipment having an analog-only tuner without displaying the required Consumer Alert 
in close proximity.17 Between May 31, 2007 and June 11, 2007, the Enforcement Bureau conducted 
inspections at numerous stores and, based on those inspections, issued additional Citations to Kmart for 
violations at its stores.18 On June 7, 2007, the Enforcement Bureau issued a Citation to Kmart for offering 
for sale on its online retail outlet, www.kmart.com, television receiving equipment having an analog-only 
tuner without displaying the required Consumer Alert in close proximity.19 After affording Sears a 
reasonable opportunity to respond to the first Citations issued to Kmart and Sears Roebuck.,20 agents and 
investigators from the Enforcement Bureau began inspecting numerous additional Sears Roebuck and 
Kmart stores on June 12, 2007, in various states and once again observed in twenty-seven Kmart stores, the 
  
13 47 C.F.R. § 15.117(k)(2).
14 Sears, Roebuck & Co, Citation No. C20073248004 (Enf. Bur. Atlanta Office, rel. June 1, 2007).  
15 See Attachment A for a list of the citations issued to Sears Holdings Corporation  (collectively “Citations”).  In 
preparing the Citations, Enforcement Bureau staff relied on publicly available information, including retailer 
websites, to identify the television receiving equipment with analog-only tuners.  Subsequently, Enforcement 
Bureau staff determined that the following Citations referred, in whole or in part, to erroneously identified 
equipment models: Sears Citation No. C20073294008 (Sylvania Model D155SL8); Kmart Citation No. 
C20073228004 (All Models). In light of this evidence, we hereby cancel the relevant portions of the above citations 
with respect to those models.  We also determined that the following Citation issued to K-Mart should have been 
issued to another retailer, and therefore we cancel this Citation as well:  Citation No. C20073290022 (rel. June 5, 
2007). 
16 Sears, Roebuck & Co, Citation No. EB-07-SE-188 (Enf. Bur. Spectrum Enforcement Division, rel. June 7, 2007).  
17 Kmart c/o Sears Holding Corporation, Citation No. C20073240004 (Enf. Bur. Philadelphia Office, rel. May 31, 
2007).  
18 See Attachment A.  All of the violations underlying the Citations occurred before June 12, 2007.
19 Sears, Roebuck & Co, Citation No. EB-07-SE-181 (Enf. Bur. Spectrum Enforcement Division, rel. June 7, 2007).  
20 On June 8, 14, and 22, 2007, Sears Holdings Corporation submitted consolidated responses to the citations issued 
to Kmart and Sears, Roebuck & Co.  See Letter from Mark D. Moloy, Senior Counsel – Vendor Compliance, Law 
Department, Sears Holdings Management Corporation, to William Davenport, Assistant Bureau Chief, and George 
Dillon, Associate Bureau Chief, Enforcement Bureau, Federal Communications Commission, dated June 8, 2007; 
Letter from Mark D. Moloy, Senior Counsel – Vendor Compliance, Law Department, Sears Holdings Management 
Corporation, to William Davenport, Assistant Bureau Chief, and George Dillon, Associate Bureau Chief, 
Enforcement Bureau, Federal Communications Commission, dated June 14, 2007; Letter from Mark D. Moloy, 
Senior Counsel – Vendor Compliance, Law Department, Sears Holdings Management Corporation, to William 
Davenport, Assistant Bureau Chief, and George Dillon, Associate Bureau Chief, Enforcement Bureau, Federal 
Communications Commission, dated June 22, 2007. 
Federal Communications Commission FCC 08-107
4
Sears Roebuck website, and sixteen Sears Roebuck stores, television receiving equipment with analog-only 
tuners on display without the required Consumer Alert labels.21  
6. Under Section 503(b)(1) of the Act, any person who is determined by the Commission to 
have willfully or repeatedly failed to comply with any provision of the Act or any rule, regulation, or 
order issued by the Commission shall be liable to the United States for a forfeiture penalty.22 Section 
312(f)(1) of the Act defines willful as “the conscious and deliberate commission or omission of [any] act, 
irrespective of any intent to violate” the law.23 The legislative history to Section 312(f)(1) of the Act 
clarifies that this definition of willful applies to both Sections 312 and 503(b) of the Act24 and the 
Commission has so interpreted the term in imposing forfeitures pursuant to Section 503(b).25 The 
Commission may also assess a forfeiture for violations that are merely repeated, and not willful.26
“Repeated” means that the act was committed or omitted more than once, or lasts more than one day.27  
To impose such a forfeiture penalty, the Commission must issue a notice of apparent liability and the 
person against whom the notice has been issued must have an opportunity to show, in writing, why no 
such forfeiture penalty should be imposed.28 The Commission will then issue a forfeiture if it finds by a 
preponderance of the evidence that the person has violated the Act or a Commission rule.29 As we set 
forth below, we conclude under this standard that Sears is apparently liable for forfeiture for its apparent 
willful and repeated violations of Section 15.117(k) of the Commission’s rules.
III. DISCUSSION
7. Based on the evidence before us, we find that Sears apparently willfully and repeatedly 
violated Section 15.117(k) of the Rules by failing to display conspicuously and in close proximity to 
equipment with an analog-only tuner, in clear and conspicuous print, the required Consumer Alert label.  
Specifically, as detailed in Attachment B, agents and investigators from the Enforcement Bureau observed a 
number of different models of television receiving equipment having only an analog-only tuner on display 
in twenty-seven Kmart stores, the Sears Roebuck website, and sixteen Sears Roebuck stores, without the 
required Consumer Alert labels.30 Kmart previously received twenty-three Citations and Sears Roebuck 
previously received twenty Citations for this same type of conduct prior to the agents’ inspections.31  
  
21 See Attachment B for a listing of the stores visited and the models observed at each store.  Enforcement Bureau 
staff determined that these models had analog-only tuners by consulting the manufacturer’s product manuals or, if 
such were unavailable, the models’ technical specifications from Sears Holding Corporation’s website.
22 47 U.S.C. § 503(b)(1)(B); 47 C.F.R. § 1.80(a)(2).  
23 47 U.S.C. § 312(f)(1).
24 H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).
25 See, e.g., Application for Review of Southern California Broadcasting Co., Memorandum Opinion and Order, 6 
FCC Rcd 4387, 4388 (1991) (“Southern California Broadcasting Co.”).
26 See, e.g., Callais Cablevision, Inc., Grand Isle, Louisiana, Notice of Apparent Liability for Monetary Forfeiture, 
16 FCC Rcd 1359, 1362, ¶ 10 (2001) (“Callais Cablevision”) (issuing a Notice of Apparent Liability for, inter alia, 
a cable television operator’s repeated signal leakage). 
27 Southern California Broadcasting Co., 6 FCC Rcd at 4388, ¶ 5; Callais Cablevision, Inc., 16 FCC Rcd at 1362, 
¶ 9.
28 47 U.S.C. § 503(b); 47 C.F.R. § 1.80(f).
29 See, e.g., SBC Communications, Inc., Forfeiture Order, 17 FCC Rcd 7589, 7591, ¶ 4 (2002) (forfeiture paid).
30 Attachment B lists the dates of the Enforcement Bureau inspections, the analog-only models identified in violation 
of Section 15.117(k), as well as the Sears Roebuck and Kmart stores involved.
31 Section 503(b)(5) states that no forfeiture liability shall be determined against any person who does not hold a 
license, permit, certificate, or other authorization issued by the Commission unless, prior to issuance of any Notice 
(continued....)
Federal Communications Commission FCC 08-107
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8. Under Section 503(b)(2)(D) of the Act,32 we may assess an entity that is neither a common 
carrier, broadcast licensee or cable operator a forfeiture of up to $11,000 for each violation or each day of a 
continuing violation, up to a statutory maximum forfeiture of $97,500 for any single continuing violation.  
In exercising such authority, we must 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.”33  
9. The Commission’s Forfeiture Policy Statement34 and Section 1.80 of the Rules do not 
establish a specific base forfeiture for violation of the analog-only tuner labeling requirements.  In adopting 
the Consumer Alert labeling requirements, the Commission stated that “[a]ccurate communication of this 
impending change is a highly material disclosure for consumers contemplating the purchase of a 
television.” 35 We also noted that it is a matter of public safety for consumers who rely on analog-only 
televisions to obtain critical emergency information.36  
10. Similar issues arose regarding labeling requirements for wireless hearing aid-compatible 
handsets.  In those cases, the Enforcement Bureau established a base forfeiture amount of $8,000 per 
handset model that failed to comply with the labeling requirements.37 The labeling requirements for 
  
(...continued from previous page)
of Apparent Liability, such person is “(A) sent 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 which 
is nearest to such person’s place of residence; and (C) subsequently engages in conduct of the type described in such 
citation.”  47 U.S.C. § 503(b)(5).  The apparent violations discussed in this NAL are subject to forfeiture because we 
afforded Sears a reasonable opportunity for a personal interview or to submit a written response to its first Citation 
before conducting a second round of inspections that would count towards potential forfeiture liability.  See supra 
para. 5 and notes 14, 17.  To the extent that the television receiving models involved in this NAL differ from those 
listed in the Citations, no additional citations are necessary because the more recent apparent violations are “conduct 
of the type described” in the earlier Citations – violations of Section 15.117(k).  See HighTech CB Shop, Forfeiture 
Order, 20 FCC Rcd 12514, 12516 ¶ 9 (Enf. Bur. South Central Region 2005), recon. denied, 20 FCC Rcd 19269 
(Enf. Bur. 2005).  In any event, the requirements of Section 503(b)(5) do not apply to Sears Roebuck, Kmart, or 
Sears Holding Corporation, which are Commission licensees and therefore subject to forfeiture under Section 
503(b)(2) of the Act without first receiving notice via a citation.  See, e.g., Stations KB92013, WPAI989, and 
WPAW266, licensed to Sears Roebuck, Kmart, and Sears Holding Corporation, respectively, in the 
Industrial/Business Pool Private Land Mobile Service.
32 47 U.S.C. § 503(b)(2)(D).  The Commission twice amended Section 1.80(b)(3) of the Rules, 47 C.F.R. § 
1.80(b)(3), to increase the maximum forfeiture amounts, in accordance with the inflation adjustment requirements 
contained in the Debt Collection Improvement Act of 1996, 28 U.S.C. § 2461.  See Amendment of Section 1.80 of 
the Commission’s Rules and Adjustment of Forfeiture Maxima to Reflect Inflation, Order, 15 FCC Rcd 18221 (2000) 
(adjusting the maximum statutory amounts from $10,000/$75,000 to $11,000/$87,500); Amendment of Section 1.80 
of the Commission’s Rules and Adjustment of Forfeiture Maxima to Reflect Inflation, Order, 19 FCC Rcd 10945 
(2004) (adjusting the maximum statutory amounts from $11,000/$87,500 to $11,000/$97,500).
33 47 U.S.C. § 503(b)(2)(E).  See also 47 C.F.R. § 1.80(b)(4), Note to paragraph (b)(4): Section II. Adjustment 
Criteria for Section 503 Forfeitures.
34 See 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, 17115 (1997), recon. denied, 15 FCC Rcd 303 (1999) 
(“Forfeiture Policy Statement”).
35 Second DTV Periodic Report and Order at ¶ 12.
36 Id.  See also 47 C.F.R. §§ 11.1-11.61, 79.2.
37 See Pine Telephone Inc., Notice of Apparent Liability, 22 FCC Rcd 9205, 9210 (Enf. Bur., Spectrum Enf. Div. 
2007) subsequent history omitted; IT&E Overseas, Inc., Notice of Apparent Liability, 22 FCC Rcd 7660, 7665 (Enf. 
Bur., Spectrum Enf. Div. 2007).
.
Federal Communications Commission FCC 08-107
6
wireless hearing aid-compatible handsets and the analog-only tuner labeling requirements both serve the 
important goal of ensuring that consumers have access to necessary information.  In light of the 
similarities in these labeling requirements, we conclude that a $8,000 base forfeiture amount per unlabeled 
model or device in each store where Bureau agents and investigators observed a violation is appropriate for 
apparent violations of Section 15.117(k).38  
11. We find that, beginning on June 12, 2007, as detailed in Attachment B, even after receiving 
the Citations warning of violations in its stores across the country, numerous different models of equipment 
with an analog-only tuner were displayed in twenty-seven Kmart stores, the Sears Roebuck website, and 
sixteen Sears Roebuck stores without the required Consumer Alert label.  As a result, Sears continued to 
market television receiving equipment to consumers without adequately warning that the equipment 
contained an analog-only television receiver.  Those consumers may not learn of their equipment’s 
limitations until the analog-only devices cease to receive over-the-air television signals, long after any 
period for returning the equipment has expired.  This scenario is precisely the outcome that our rule was 
intended to prevent.39 Applying the analysis set forth above to the facts of this case, we conclude that Sears 
Roebuck is apparently liable for a $320,000 base forfeiture and Kmart is apparently liable for a $776,000 
base forfeiture.40
IV. ORDERING CLAUSES
12. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, and Section 1.80 of the Commission's Rules, Sears Roebuck and Co. is hereby 
NOTIFIED of this APPARENT LIABILITY FOR A FORFEITURE in the amount of three hundred 
twenty thousand dollars ($320,000) for violations of Section 15.117(k) of the Rules.41
13. IT IS FURTHER ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, and Section 1.80 of the Commission's Rules, Kmart Corporation is hereby 
NOTIFIED of this APPARENT LIABILITY FOR A FORFEITURE in the amount of seven hundred 
seventy six thousand dollars ($776,000) for violations of Section 15.117(k) of the Rules.42
14. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Commission's Rules 
within thirty days of the release date of this Notice of Apparent Liability for Forfeiture, Sears Roebuck and 
Co. and Kmart Corporation SHALL PAY the full amount of their proposed forfeitures or SHALL FILE a 
written statement seeking reduction or cancellation of the proposed forfeiture.
15. Payment of the forfeiture must be made by check or similar instrument, payable to the 
order of the Federal Communications Commission.  The payment must include the NAL/Account 
Number and FRN Number referenced above.  Payment by check or money order may be mailed to 
Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.  Payment by 
overnight mail may be sent to U.S. Bank – Government Lockbox #979088, SL-MO-C2-GL, 1005 
Convention Plaza, St. Louis, MO 63101.  Payment[s] by wire transfer may be made to ABA Number 
  
38 We caution Sears Roebuck and Kmart and other retailers that future cases involving repeat offenders may result in 
the imposition of forfeitures on a continuing violation basis.
39 “After the transition, absent a label requirement, even cable and satellite subscribers might be surprised to find 
that they cannot receive television broadcasts over-the-air on an analog-only television purchased today if they 
choose to discontinue subscription service or their cable or satellite service is terminated by disaster, service 
disruption, or for non-payment of their bills.”  Second DTV Periodic Report and Order at ¶ 12.
40 See Attachment B regarding the calculation of the proposed forfeiture amounts.  
41 47 U.S.C. § 503(b), 47 C.F.R. §§ 1.80, 15.117(k).
42 47 U.S.C. § 503(b), 47 C.F.R. §§ 1.80, 15.117(k).
Federal Communications Commission FCC 08-107
7
021030004, receiving bank TREAS/NYC, and account number 27000001.  For payment by credit card, 
an FCC Form 159 (Remittance Advice) must be submitted. When completing the FCC Form 159, enter 
the NAL/Account number in block number 23A (call sign/other ID), and enter the letters “FORF” in 
block number 24A (payment type code).  Requests for full payment under an installment plan should be 
sent to: Chief Financial Officer -- Financial Operations, 445 12th Street, S.W., Room 1-A625, 
Washington, D.C. 20554.  Please contact the Financial Operations Group Help Desk at 1-877-480-3201 
or Email: ARINQUIRIES@fcc.gov with any questions regarding payment procedures. 
16. The response, if any, must be mailed to Federal Communications Commission, 
Enforcement Bureau, and must include the NAL/Acct. No. referenced in the caption.  
17. 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 ("GAAP"); 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.  
18. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by Certified Mail, Return Receipt Requested, and regular mail, to Mark D. Molay, 
Senior Counsel – Vendor Compliance, Sears Holdings Management Corporation, at his address of record, 
and to David Hilliard, Wily Rein LLP, Counsel for Sears Roebuck and Co. and Kmart Corporation, at his 
address of record.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
Federal Communications Commission FCC 08-107
8
Attachment A
CITATIONS
Sears, Roebuck & Co.
Store #-
Location
Citation No. Release Date
Tampa, FL C20073270002 May 31, 2007
Miami, FL C20073260004 May 31, 2007
San Diego, CA C20073294008 June 1, 2007
#1685 Duluth, GA C20073248004 June 1, 2007
Houston, TX C20073254003 June 1, 2007
#1019 Pleasanton, 
CA
C20073296007 June 5, 2007
Tacoma, WA C20073298013 June 5, 2007
#1354 Willow 
Grove, PA
C20073240011 June 6, 2007
Tukwila, WA C20073298017 June 8, 2007
Anchorage, AK C20073278003 June 8, 2007
Ellicot City, MD C20073234007 June 8, 2007
#1834 North 
Wales, PA
C20073240019 June 11, 2007
Peabody, MA C20073226005 June 11, 2007
Richardson, TX C20073250013 June 11, 2007
#1248 Hayward, 
CA
C20073296014 June 12, 2007
#1874 Burlington, 
NJ
C20073240030 June 12, 2007
#1615 Chesapeake, 
VA
C20073264008 June 12, 2007
New Hyde Park, 
NY
C20073238020 June 14, 2007
Valley Stream, NY C20073238024 June 14, 2007
www.sears.com EB-07-SE-188 June 7, 2007
Kmart
Store #-
Location
Citation No. Release Date
#3187 Langhorne, 
PA
C200732440004 May 31, 2007
#12127601 New 
York, NY
C20073238013 May 31, 2007
#3117 Willow 
Grove, PA
C20073240005 June 1, 2007
Tampa, FL C20073270006 June 1, 2007
Miami, FL C20073260002 June 1, 2007
#3742 Chesapeake, 
VA
C20073264004 June 1, 2007
Federal Communications Commission FCC 08-107
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#4988 Norfolk, VA C20073264003 June 1, 2007
Seattle, WA C20073298010 June 4, 2007
Batavia, NY C20073228001 June 4, 2007
Ocala, FL C20073270008 June 4, 2007
LaHabra, CA C20073290022 June 5, 2007
#3207 Farmington, 
MI
C20073236003 June 5, 2007
#3159 Farmington, 
MI
C20073236004 June 5, 2007
#4451 Doraville, 
GA
C20073248010 June 6, 2007
Depew, NY C20073228004 June 7, 2007
Denver, CO C20073280009 June 8, 2007
San Diego, CA C20073294015 June 11, 2007
Kapolei, HI C20073286005 June 11, 2007
#3077 Burlington, 
NJ
C20073240028 June 12, 2007
#3596 
Pleasantiville, NJ
C20073240026 June 12, 2007
San Leandro, CA C20073296018 June 15, 2007
Hayward, CA C20073296017 June 15, 2007
www.kmart.com EB-07-SE-181 June 7, 2007
Federal Communications Commission FCC 08-107
10
Attachment B
PROPOSED FORFEITURE AMOUNTS
Sears, Roebuck & Co.
1.  June 12, 2007, Sears Store # 1108, Temecula, CA.  
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV 6720FDG/F $8,000
Toshiba TV MD 20F51 $8,000
Toshiba TV MD13Q42 $8,000
Haier America TV HTN20R15 $8,000
Audiovox TV VE-720 $8,000
Sony TV ICF-DVD57TV $8,000
Sony TV ICF- CD555TV $8,000
Toshiba TV 14AF45 $8,000
SUBTOTAL $64,000
2. June 12, 2007, Sears Store, Wasilla, AK
Manufacturer Device Model #
Forfeiture 
Amount
Sony TV KV20FS120 $8,000
Sylvania TV 6424TFS $8,000
Sylvania TV 6419TG $8,000
Sylvania TV 6413TG $8,000
Toshiba TV 14AF45 $8,000
Sony DVD/VCR RDR-VX530 $8,000
Samsung DVD/VCR DVD-R330 $8,000
Toshiba TV/DVD MD13Q42 $8,000
Sylvania TV/VCR 6313CE $8,000
Sylvania TV/DVD/VCR 6720FDG $8,000
SUBTOTAL $80,000
3. June 12, 2007, Sears Store # 1098, Clovis, CA
Manufacturer Device Model #
Forfeiture 
Amount
Sony TV KV20FS120 $8,000
SUBTOTAL $8,000
Federal Communications Commission FCC 08-107
11
4. June 12, 2007, Sears Store, Cheyenne, WY
Manufacturer Device Model #
Forfeiture 
Amount
Panasonic DVD Recorder DMR-ES15 $8,000
SUBTOTAL $8,000
5. June 13, 2007, Sears Store, Baltimore, MD
Manufacturer Device Model #
Forfeiture 
Amount
Disney Princess 13” TV DT1350-P $8,000
SUBTOTAL $8,000
6. June 13, 2007, Sears Store #1224, Harrisburg, PA
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV/DVD/VCR 6724FDG $8,000
SUBTOTAL $8,000
7. June 13, 2007, Sears Store #1646, Charlotte, NC  
Manufacturer Device Model #
Forfeiture 
Amount
Samsung DVD Recorder DVD-VR330 $8,000
SUBTOTAL $8,000
8. June 14, 2007, Sears Store #1057, Dallas, TX
Manufacturer Device Model #
Forfeiture 
Amount
Sony DVD/VCR combo SLV-D360P $8,000
Samsung DVD/VCR combo DVD-VR330 $8,000
Philips
LCD HDTV monitor 
with NTSC tuner 23PF5320/28
$8,000
SUBTOTAL $24,000
9. June 14, 2007, Sears Store, St. Peters, MO
Manufacturer Device Model #
Forfeiture 
Amount
Philips LCD HDTV 
MONITOR 23PF5320/28
$8,000
SUBTOTAL $8,000
10. June 14, 2007, Sears Store #3231, Escanaba, MI
Manufacturer Device Model #
Forfeiture 
Amount
Philips 23” LCD TV 23PF5320/28 $8,000
Federal Communications Commission FCC 08-107
12
SUBTOTAL $8,000
11. June 14, 2007, Sears Store # 6909, San Bruno, CA
Manufacturer Device Model #
Forfeiture 
Amount
Panasonic DVDR DMR-ES15 $8,000
Sylvania TV 6424TFS $8,000
SUBTOTAL $16,000
12. June 14, 2007, Store #1335 Greensboro, NC 
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV set 6313CG $8,000
Sylvania TV set 6513DG $8,000
SUBTOTAL $16,000
13. June 15, 2007, Sears Store #1728, Tuscon, AZ
Manufacturer Device Model #
Forfeiture 
Amount
Memcorp - Disney 
Electronics TV
DT1350-C $8,000
SUBTOTAL $8,000
14. July 2, 2007, Sears Store #2446, Mission, KS
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV/DVD/VCR 6720FDG $8,000
SUBTOTAL $8,000
15. July 2, 2007, Sears Store #2398, Longmont, CO
Manufacturer Device Model #
Forfeiture 
Amount
Toshiba DVD/VCR D-VR5SU $8,000
Panasonic DVD DMR-ES15 $8,000
SUBTOTAL $16,000
16. July 11, 2007, Sears Store # 1485, Orange Park, FL
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania 19” TV 6419TG $8,000
Toshiba 24” TV/DVD/VCR MW24F52 $8,000
SUBTOTAL $16,000
Federal Communications Commission FCC 08-107
13
17. June 14, 2007, Sears website, www.sears.com
Manufacturer Device Model #
Forfeiture 
Amount
Philips TV 23PF5320/28 $8,000
Spectra TV 507-BWR $8,000
SUBTOTAL $16,000
Sears, Roebuck, & Co. Total Proposed Forfeiture:  $320,000
Federal Communications Commission FCC 08-107
14
Kmart
1. June 12, 2007, Kmart Store #9394, Fajardo, PR
Manufacturer Device Model #
Forfeiture 
Amount
Memorex DVD/VCR MVD 4543 $8,000
Sylvania DVD/VCR DVC 841G $8,000
RCA DVD/VCR DCR 6355N $8,000
Toshiba DVD/VCR SD-V394 $8,000
Sony DVD/VCR SLV-D370P $8,000
SUBTOTAL $40,000
2. June 12, 2007, Kmart Store, 15909 Manchester Road, Ballwin, MO
Manufacturer Device Model #
Forfeiture 
Amount
Memorex DVD/VCR MVD4543 $8,000
Magnavox TV 20MF605T $8,000
Sylvania LCD TV 6620LCT $8,000
Toshiba TV/DVD MD20F52 $8,000
SUBTOTAL $32,000
3. June 12, 2007, Kmart Store, 6650 Manchester Street, St. Louis, MO
Manufacturer Device Model #
Forfeiture 
Amount
Sony DVD/VCR SLV-D370P $8,000
RCA TV 20F512T $8,000
SUBTOTAL $16,000
4. June 12, 2007, Kmart Store #3833, Iron Mountain, MI 
Manufacturer Device Model #
Forfeiture 
Amount
DN Princess 13” TV DT 1350-P $8,000
Pooh 13” TV DT 1350-RWP $8,000
SUBTOTAL $16,000
5. June 12, 2007, Kmart Store, Clovis, CA 
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV C6419TE $8,000
Memorex TV
MT0550 / 
MT0500
$8,000
Sharp TV LC15SH $8,000
SUBTOTAL $24,000
Federal Communications Commission FCC 08-107
15
6. June 12, 2007, Kmart Store #4244, Knoxville, TN 
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV/DVD 6520FDG $8,000
Sylvania TV/DVD 6513DG $8,000
Sylvania TV 6420FB $8,000
SUBTOTAL $24,000
7. June 12, 2007, Kmart Store, Cheyenne, WY 
Manufacturer Device Model #
Forfeiture 
Amount
Memorex
DVD/CD/VCD/MP3/Photo 
CD Player and Video 
Cassette Recorder MVD4543
$8,000
SUBTOTAL $8,000
8. June 13, 2007, Kmart Store #4137, Charlotte, NC
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV set 6427TF $8,000
Sylvania TV set 6432TF $8,000
Sylvania TV set 6424TFS $8,000
SUBTOTAL $24,000
9. June 13, 2007, Kmart Store, 5100 Sinclair Lane, Baltimore, MD
Manufacturer Device Model #
Forfeiture 
Amount
Disney Princess 13” Color TV DT1350-P $8,000
RCA 20” Stereo TV 20V500T $8,000
Sylvania 13” TV/DVD 6513DG $8,000
SUBTOTAL $24,000
10. June 13, 2007, Kmart Store #3028, Feasterville, PA
Manufacturer Device Model #
Forfeiture 
Amount
Memorex DVD/VCR MVD4543 $8,000
Disney TV DT1350-P $8,000
Magnavox TV 14MS2331/17 $8,000
RCA TV 13V420T $8,000
Sylvania TV 6419TG $8,000
Olevia TV LT23HVX $8,000
SUBTOTAL $48,000
11. June 13, 2007, Kmart Store #4479, Harrisburg, PA
Manufacturer Device Model #
Forfeiture 
Amount
Federal Communications Commission FCC 08-107
16
Disney TV DT1350-RWP $8,000
SUBTOTAL $8,000
12. June 13, 2007, Kmart Store, Casa Grande, AZ
Manufacturer Device Model #
Forfeiture 
Amount
Magnavox TV MS2331 $8,000
RCA TV 13V420T $8,000
Memcorp (Disney 
Electronics) TV
DT1350-C $8,000
SUBTOTAL $24,000
13. June 13, 2007, Kmart Store (Baseline Road), Phoenix, AZ 
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV 6620LCT $8,000
SUBTOTAL $8,000
14. June 14, 2007, Kmart Store #4248, Staten Island, NY
Manufacturer Device Model #
Forfeiture 
Amount
Magnavox TV 20MF605T/17 $8,000
SUBTOTAL $8,000
15. June 14, 2007, Kmart Store # 4308, Birmingham, AL 
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV 6413TG $8,000
Sylvania TV/VCR 6313CE $8,000
Sylvania DVR DVR90DF $8,000
Sylvania TV/DVD 6513DG $8,000
RCA TV 13V420T $8,000
RCA TV 24V511T $8,000
Magnavox TV 14MS2331 $8,000
Memorex TV MT0500 $8,000
SUBTOTAL $64,000
16. June 14, 2007, Kmart Store, Riverside, CA
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV 6313CD $8,000
Maganavox VCR/DVD 20MF605T $8,000
Memcorp - Disney 
Electronics TV
DT1350-P $8,000
Memorex TV MVD4543 $8,000
SUBTOTAL $32,000
Federal Communications Commission FCC 08-107
17
17. June 14, 2007, Kmart Store #9065, Escanaba, MI 
Manufacturer Device Model #
Forfeiture 
Amount
DN Princess 13” TV DT 1350-P $8,000
Pooh 13” TV DT 1350-RWP $8,000
SUBTOTAL $16,000
18. June 14, 2007, Kmart Store #3179, Orlando, FL 
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV/DVD 6513DG $8,000
Memorex TV/DVD/CD MVD1402 $8,000
Sylvania TV 6424TF $8,000
Toshiba TV/DVD MD20F52 $8,000
RCA TV 13V420T $8,000
Magnavox FLT Stereo TV 14MS2331 $8,000
Sylvania TV 6419TG $8,000
Magnavox TV 20MT133S $8,000
Sylvania TV 6424TFS $8,000
RCA TV 20V500T $8,000
Sylvania TV 6413TG $8,000
RCA TV E13320 $8,000
Disney Classic TV TV
Princess 13-
DT135OC
$8,000
SUBTOTAL $104,000
19. June 14, 2007, Kmart Store, San Mateo, CA
Manufacturer Device Model #
Forfeiture 
Amount
Memorex TV MT0550/MT0500 $8,000
Disney/Memorex TV D1350 P $8,000
Magnavox TV 20MS2331/17 $8,000
Magnavox TV 15MF605T $8,000
SUBTOTAL $32,000
20. June 15, 2007, Kmart Store, Sierra Vista, AZ
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV 6620LDT $8,000
Magnavox TV 20MF500T $8,000
Memcorp - Disney 
Electronics TV
DT1350-C $8,000
SUBTOTAL $24,000
Federal Communications Commission FCC 08-107
18
21. June 15, 2007, Kmart Store #4844, San Juan, PR
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV 6319CE $8,000
Symphonic TV SC724FDF $8,000
Sylvania DVD/VCR DVC 840F $8,000
Sylvania DVD/VCR DVC 841G $8,000
Memorex DVD/VCR MVD4543 $8,000
RCA DVD/VCR DRC6355N $8,000
SUBTOTAL $48,000
22. On July 5, 2007, Kmart Store # 4220, Kansas City, MO
Manufacturer Device Model #
Forfeiture 
Amount
RCA TV 20V500T $8,000
Magnavox TV 20MT133S $8,000
SUBTOTAL $16,000
23. July 9, 2007, Kmart Store #4427, Independence, MO
Manufacturer Device Model #
Forfeiture 
Amount
RCA TV 20F512T $8,000
RCA TV 24V511T $8,000
Disney TV DT1350-P $8,000
Magnavox TV 20MF500T $8,000
SUBTOTAL $32,000
24. July 10, 2007, Kmart Store #9936, Independence, MO
Manufacturer Device Model #
Forfeiture 
Amount
Sony DVD/VCR SLV-D370P $8,000
Sylvania TV 6620LCT $8,000
RCA TV 13V420T $8,000
SUBTOTAL $24,000
25. July 10, 2007, Kmart  Store # 4157,  Kansas City, MO
Manufacturer Device Model #
Forfeiture 
Amount
Sylvania TV 6620LCT $8,000
Magnavox TV 14MS2331 $8,000
RCA TV 20V500T $8,000
Sylvania TV 6620LE $8,000
RCA TV E13320 $8,000
SUBTOTAL $40,000
Federal Communications Commission FCC 08-107
19
26. July 12, 2007, Kmart Store, El Centro CA 
Manufacturer Device Model #
Forfeiture 
Amount
Sony DVD/VCR SLVD370P $8,000
RCA DVD/VCR DRC6355N $8,000
Trutech TV KLV3170 $8,000
SUBTOTAL $24,000
27. July 14, 2007, Kmart Store #3641, Manahawkin, NJ 
Manufacturer Device Model #
Forfeiture 
Amount
Disney TV DT1350-P $8,000
RCA TV 20F512T $8,000
SUBTOTAL $16,000
Kmart Total Proposed Forfeiture:  $776,000
SEARS HOLDING CORPORATION TOTAL PROPOSED 
FORFEITURE:  $1,096,000