Federal Communications Commission FCC 11-112 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of 
Laser Technologies 
dba Laser Tech
Apparent Liability for Forfeiture
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File No.: EB-06-TC-2630
NAL/Acct. No. 201132170028
FRN:   0011158425
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted:  July 18, 2011 Released:   July 18, 2011
By the Commission:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (“NAL”), we find that Laser 
Technologies dba Laser Tech1 apparently willfully and repeatedly violated section 227(b)(1)(C) of the 
Communications Act of 1934, as amended (the “Communications Act” or “Act”), and section 
64.1200(a)(3) of the Commission’s rules, by delivering 40 unsolicited advertisements, or “junk faxes,” to 
the telephone facsimile machines of 28 consumers.2 Based on the facts and circumstances surrounding 
these apparent violations, we find that Laser Technologies is apparently liable for a forfeiture in the 
amount of $252,000.  
II. BACKGROUND
2. The Telephone Consumer Protection Act of 1991 (“TCPA”) was enacted by Congress to 
address problems of abusive telemarketing, including junk faxes.3 Unsolicited faxes often impose 
unwanted burdens on the called party, including costs of paper and ink, and making fax machines 
unavailable for legitimate business messages.  Section 227(b)(1)(C) of the Act thus 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  
  
1 According to publicly available information, Laser Technologies is also doing business as Laser Tech.  Therefore, 
all references in this NAL to “Laser Technologies” also encompass “Laser Tech.”  Laser Technologies has offices at 
11693 San Vincente Boulevard, Suite 388, Los Angeles, CA 90049.  Pablo Ciolfi, owner and CEO, is listed as the 
contact person for Laser Technologies.  Accordingly, all references in this NAL to Laser Technologies also 
encompass the foregoing individual and all other principals and officers of this entity, as well as the corporate entity 
itself.  
2 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).  
3 Telephone Consumer Protection Act of 1991, Pub. L. No. 102-243, 105 Stat. 2394, codified at 47 U.S.C. § 227. 
See also Junk Fax Prevention Act of 2005, Pub. L. No. 109-21, 119 Stat. 359 (2005). 
4 47 U.S.C. § 227(b)(1)(C).  The prohibition is subject to certain exceptions, such as if the sender has an “established 
business relationship” (“EBR”) with the recipient; and the sender obtained the facsimile number from the recipient 
(continued....)
Federal Communications Commission FCC 11-112 
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3. On December 28, 2006, in response to a consumer complaint alleging that Laser 
Technologies had faxed an unsolicited advertisement, the Enforcement Bureau (“Bureau”) issued a 
citation to Laser Technologies, pursuant to section 503(b)(5) of the Act.5 The Bureau cited Laser 
Technologies for using a telephone facsimile machine, computer, or other device, to send an unsolicited 
advertisement for ink and toner supplies to a telephone facsimile machine, in violation of section 
227(b)(1)(C) of the Act and section 63.1200(a)(3) of the Commission’s rules. 6 The citation informed 
Laser Technologies that within 30 days of the date of the citation, it could either request an interview with 
Commission staff, or provide a written statement responding to the citation.  Laser Technologies did not 
respond.  
4. Despite the citation’s warning that subsequent violations could result in the imposition of 
monetary forfeitures, we have received additional consumer complaints indicating that Laser 
Technologies continued to send unsolicited facsimiles after the date of the citation.7  Specifically this 
NAL is based on complaints filed by 28 consumers establishing that Laser Technologies continued to 
send 40 unsolicited advertisements to telephone facsimile machines between July 20, 2010 and January 
26, 2011.8
III. DISCUSSION
A. Apparent Violations of Section 227(b)(1)(C) of the Act and the  
Commission’s Rules Restricting Unsolicited Facsimile Advertisements 
5. Each of the consumers listed in the Appendix has provided evidence that Laser 
Technologies used a telephone facsimile machine, computer, or other device to send the consumer at least 
one unsolicited advertisement.  The facsimile transmissions at issue advertise ink and toner supplies.  The 
faxes therefore fall within the definition of an “unsolicited advertisement.” 9 Further, according to the 
complaints, the consumers did not have an established business relationship with Laser Technologies, and 
the complainants did not give Laser Technologies permission to send the facsimile transmissions.  We 
conclude that Laser Technologies apparently violated section 227(b)(1)(C) of the Act and section 
64.1200(a)(3) of the Commission’s rules by sending 40 unsolicited advertisements to 28 consumers’ 
facsimile machines.
  
(...continued from previous page)
through voluntary communication in the context of an EBR, or from a directory, advertisement, or site on the 
Internet to which the recipient voluntarily agreed to make available its facsimile number for public distribution.  In 
addition, the unsolicited ad must notify the recipient of how to opt out of receiving future such ads, subject to certain 
requirements.  The Commission has adopted implementing rules.  See 47 C.F.R. § 64.1200(a)(3).  See also Junk Fax 
Prevention Act, Report and Order,, 21 FCC Rcd 3787, 3793-96 (2006), modified on other grounds, 23 FCC Rcd 
15059 (2008).
5 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 who are not applicants for any of those listed 
instrumentalities for violations of the Act or of the Commission’s rules and orders).
6 Citation from Kurt A. Schroeder, Deputy Chief, Telecommunications Consumers Division, Enforcement Bureau, 
File No. EB-06-TC-2630, issued to Laser Technologies on December 28, 2006. 
7 See Appendix for a listing of the consumer complaints against Laser Technologies requesting Commission action.
8 We note that evidence of additional instances of unlawful conduct by Laser Technologies may form the basis of 
subsequent enforcement action.
9 See 47 U.S.C. § 227(a)(5); 47 C.F.R. § 64.1200(f)(13). The term “unsolicited advertisement” means “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.”  Id.
Federal Communications Commission FCC 11-112 
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B. Proposed Forfeiture
6. After we have first issued a citation to an entity, as we have in this case, section 503(b) of 
the Act authorizes the Commission to propose a forfeiture for each subsequent violation of the Act, or of 
any rule, regulation, or order issued by the Commission under the Act.10 Section 503(b)(2)(E) mandates 
that, “[i]n determining the amount of such a forfeiture penalty, the Commission or its designee shall 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.”11 Our forfeiture guidelines set forth the base amount for penalties for certain kinds 
of violations, and identify criteria, consistent with the section 503(b)(2)(E) factors, that may influence 
whether we adjust the base amount downward or upward.12 For example, we may adjust a penalty 
upward for “[e]gregious misconduct,” or where the subject of an enforcement action has engaged in a 
“[r]epeated or continuous violation.”13 Currently, the maximum penalty that the Commission may impose 
against an entity such as Laser Technologies is $16,000 per violation.14
7. The Commission has generally considered $4,500 per unsolicited fax advertisement to be 
an appropriate base amount for violating the prohibition against sending them.15 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 such egregious violations.16 Consistent with this approach, we apply the $4,500 
base forfeiture to 36 of the apparent violations at issue in this NAL, and a $10,000 forfeiture for four of 
the apparent violations in this NAL where the consumer received a facsimile from Laser Technologies 
after specifically requesting that Laser Technologies cease sending them.  Based on the application of 
these standards, the total forfeiture proposed in this case would be $202,000. 
8. Recently, we have begun to impose upward adjustments for multiple, repeated violations 
of our junk fax rules.  For example, in another NAL we issued recently against a company that had 
  
10 47 U.S.C. § 503(b)(5).
11 47 U.S.C. § 503(b)(2)(E). 
12 47 C.F.R. § 1.80(b)(4) note.  The absence of a particular type of violation from the forfeiture guidelines must “not 
be taken to mean that the violation is unimportant or nonexistent,” and “the Commission retains discretion to impose 
forfeitures for other violations.”  Commission’s Forfeiture Policy Statement, Report & Order, 12 FCC Rcd 17,087, 
17,110 (1997).
13 47 C.F.R. § 1.80(b)(4) note.  
14 47 U.S.C. § 503(b)(2)(C).  Section 503(b)(2)(C) provides for forfeitures of up to $10,000 for each violation in 
cases, as in the instant case, where the violation does not involve a Commission licensee, common carriers, among 
others.  See 47 U.S.C. § 503(b)(2)(C).  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) first to $11,000 and more 
recently to $16,000.  See 47 C.F.R. §1.80(b)(3).  See also Amendment of Section 1.80(b) of the Commission’s Rules, 
Adjustment of Forfeiture Maxima to Reflect Inflation, 23 FCC Rcd 9845 (2008) (amendment of section 1.80(b) to 
reflect an increase in the maximum forfeiture for this type of violator to $16,000). 
15 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 FCC 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).
16  See Carolina Liquidators, Inc., Notice of Apparent Liability for Forfeiture, 15 FCC Rcd 16,837, 16,842 (2000); 
21st Century Fax(es) Ltd., AKA 20th Century Fax(es), 15 FCC Rcd 24,406, 24,411 (2000).
Federal Communications Commission FCC 11-112 
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engaged in a total of 104 apparent violations, we proposed an upward adjustment of $150,000;17 in a 
second NAL we issued against another company that had engaged in a total of sixty-two apparent 
violations, we proposed an upward adjustment of $75,000.18 We proposed these upward adjustments 
because we concluded that application of our base forfeitures “has failed to deter the more persistent 
wrongdoers,” and thus that “different and harsher penalties than we have imposed in the past are 
appropriate for entities who engage in a significant number of violations.”19
9. Based on the number of Laser Tech’s apparent violations – 40 – we propose an upward 
adjustment of $50,000, for a total proposed forfeiture of $252,000.  ($202,000 + $50,000 = $252,000).  
The primary basis for the upward adjustment is Laser Tech’s repeated violations; as indicated above, the 
forfeiture guidelines explicitly identify “repeated or continuous violation” among the criteria for adjusting 
a forfeiture upward.20 The magnitude of the adjustment is proportionate to the number of Laser Tech’s 
violations, and to the adjustments we applied in recent enforcement actions relative to the number of 
violations involved in those actions.   
IV. CONCLUSION 
10. We have determined that Laser Technologies apparently violated section 227(b)(1)(C) of 
the Act and section 64.1200(a)(3) of the Commission’s rules, by using a telephone facsimile machine, 
computer, or other device to send 40 unsolicited advertisements to the 28 consumers identified in the 
Appendix.  We have further determined that Laser Technologies is apparently liable for a forfeiture in the 
amount of $252,000.
V. ORDERING CLAUSES
11. Accordingly, IT IS ORDERED, pursuant to section 503(b) of the Communications Act 
of 1934, as amended, 47 U.S.C. § 503(b), and section 1.80 of the Commission’s rules, 47 C.F.R. § 1.80,  
that Laser Technologies is hereby NOTIFIED of this APPARENT LIABILITY FOR A 
FORFEITURE in the amount of $252,000 for willful and repeated violations of section 227(b)(1)(C) of 
the Communications Act, 47 U.S.C. § 227(b)(1)(C), and section 64.1200(a)(3) of the Commission’s rules, 
47 C.F.R. § 64.1200(a)(3).
  
17 See Presidential Who’s Who, Notice of Apparent Liability for Forfeiture, FCC 11-95 (June 13, 
2011)(“Presidential Who’s Who NAL”).
18 See The Street Map Company, Notice of Apparent Liability for Forfeiture, FCC 11-85 (June 1, 2011)(“ Street Map 
NAL”).
19 Id. at 4-5.
20 The upward adjustment of $50,000 amounts to approximately $1,400 for each of 36 of the violations at issue in 
this NAL that are not already subject to upward adjustment (i.e., all of the violations except the four for which we 
assess a $10,000 penalty).  The combination of the base forfeiture and the upward adjustment for each of the 36 
violations is therefore approximately $5,900.  This is in the range of the approximate $6,000 per-violation forfeiture 
we proposed in the Street Map NAL, which involved a number of apparent junk fax violations subject to upward 
adjustment (49) that is similar to the number involved here.  The upward adjustment in both the instant NAL and the 
Street Map NAL is, appropriately, less than that we proposed in the recent Presidential Who’s Who NAL, which, as 
indicated in the text, involved a considerably higher number of violations.  Our approach in these cases indicates 
that we will tailor the adjustment to the facts of each case, taking into account our obligations under section 
503(b)(2)(E) of the Act.  In this respect, we may apply a higher forfeiture amount, such as the $16,000 statutory 
maximum per-violation forfeiture, if the facts of a particular case warrant.
Federal Communications Commission FCC 11-112 
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12. 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, Laser 
Technologies SHALL PAY the full amount of the proposed forfeiture or SHALL FILE a written 
statement seeking reduction or cancellation of the proposed forfeiture.
13. 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 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 by wire transfer may be made to ABA Number 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).  Laser Technologies shall also send electronic notification on the date said payment 
is made to Johnny.Drake@fcc.gov.  Requests for full payment under an installment plan should be sent 
to: Chief Financial Officer -- Financial Operations, 445 12th Street, SW, 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.  
14. The response, if any, must be mailed both to: Marlene H. Dortch, Secretary, Federal 
Communications Commission, 445 12th Street, SW, Washington, DC 20554, ATTN:  Enforcement 
Bureau – Telecommunications Consumers Division; and to Richard A. Hindman, 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.  Documents sent by overnight mail (other than United States Postal Service Express Mail) must 
be addressed to: Marlene H. Dortch, Secretary, Federal Communications Commission, Office of the 
Secretary, 9300 East Hampton Drive, Capitol Heights, MD 20743.  Hand or messenger-delivered mail 
should be directed, without envelopes, to Marlene H. Dortch, Secretary, Federal Communications 
Commission, Office of the Secretary, 445 12th Street, SW, Washington, DC 20554 (deliveries accepted 
Monday through Friday 8:00 a.m. to 7:00 p.m. only).  See www.fcc.gov/osec/guidelines.html for further 
instructions on FCC filing addresses.
15. 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.
  
21 47 C.F.R. § 1.80.
Federal Communications Commission FCC 11-112 
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16. 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 First Class mail to Laser 
Technologies dba Laser Tech, 11693 San Vincente Boulevard, Suite 388, Los Angeles, CA 90049, 
Attention: Pablo Ciolfi.   
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
Federal Communications Commission FCC 11-112 
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APPENDIX
Complainants and Apparent Violation Dates
Complainant received facsimile solicitations Violation Date(s)
Ashley-Wurtmann, B. 10/11/10
Berg, D. 8/12/10
Botti, D. 10/5/10
Carman, P. 9/5/10
Ervin, A. 7/21/10
Holmes, J. 8/11/10, 12/15/10, 1/17/11, 1/26/11
Lasdon, A. 7/20/10
Latta, R. 8/18/10
Maone, J. 10/5/10
Marquis, T. 7/28/10
Messir, L. 12/2/10
McDaniel, D. 8/11/10, 8/19/10, 9/2/10, 10/6/10, 10/11/10, 
10/20/10, 12/15/10
Pavia-Zawacki, A. 10/21/10
Person, A. 12/10/10
Piechota, J. 11/4/10
Shorten, T. 1/26/11
Sparks, S. 10/11/10
Spurrier, A. 8/23/10
Stinnett, C. 8/19/10, 10/21/10
Taddei, R. 1/27/11
Taylor, T. 9/16/10
Walton, E. 7/20/10, 8/11/10
Zelik, J. 7/28/10
Zeigler, D. 9/23/10, 11/18/10
Complainant received facsimile solicitations 
after requesting no more be sent
Violation Date(s)
McDonald, S. 9/29/10
Phillips, P. 10/13/10
Roberts, B. 10/14/10
Skoniecke, J. 7/22/10