Federal Communications Commission FCC 17-171 
Before the 
Federal Communications Commission 
Washington, D.C. 20554 
In the Matter of 
Sinclair Broadcast Group, Inc. 
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File No.:  EB-IHD-16-00021748 
NAL/Acct. No.:  201732080006 
FRN No.: 0004331096  
NOTICE OF APPARENT LIABILITY FOR FORFEITURE 
Adopted:  December 13, 2017 Released:  December 21, 2017 
By the Commission:  Chairman Pai and Commissioners O’Rielly and Carr issuing separate statements; 
Commissioners Clyburn and Rosenworcel dissenting and issuing separate statements. 
I. INTRODUCTION 
1. We propose a penalty of $13,376,200 against Sinclair Broadcast Group, Inc. (identified
herein, including its wholly owned subsidiaries on Attachment A and Sinclair Television Group, Inc., as 
Sinclair) for apparently engaging in repeated violations of the Communications Act of 1934, as amended 
(Act), and Federal Communications Commission (FCC or Commission) rules (Rules) regarding paid-for 
broadcast programming.1  Our rules require a broadcaster airing a paid program to include an 
announcement stating that the program has been paid to air and identifying the program sponsor 
(collectively, sponsorship identification announcements or disclosures).  After receiving an anonymous 
complaint (Complaint), the Commission’s Enforcement Bureau (Bureau) gathered evidence that revealed 
that Sinclair apparently was paid to broadcast sponsored programming, including programming in the 
form of news segments that aired during the local news.  Sinclair apparently broadcast such programming 
at 64 of its stations—collectively more than 1,400 times—without airing the required sponsorship 
identification announcements.  The Bureau’s investigation also showed Sinclair apparently provided the 
paid programming to 13 non-Sinclair stations more than 280 times without advising those licensees that 
the programming was sponsored or who sponsored it.  Then, the non-Sinclair stations apparently 
broadcast such programming without informing viewers that the programming was paid for by a third 
party or clearly identifying the third party.  These apparent actions violate the Act and the Rules.   
2. Our action today advances the Commission’s longstanding goals of protecting consumers
by ensuring they know who is attempting to persuade them and protecting broadcasters and sponsors from 
unfair competitors that fail to abide by our disclosure rules.  When a broadcast licensee fails to disclose 
the sponsor of paid programming, it may mislead the public into believing the paid broadcast material is a 
station’s independently generated news or editorial content.  In addition, enforcement of the sponsorship 
identification requirements protects competition by preventing sponsors from gaining an unfair advantage 
by paying stations to present commercial material as news or editorial content, while their competitors’ 
paid programming is properly disclosed as sponsored material.   
II. BACKGROUND
3. On April 11, 2016, the Commission received a Complaint alleging Sinclair had aired
“compensated stories as news content” about Huntsman Cancer Institute (HCI) on behalf of the Huntsman 
Cancer Foundation (Huntsman Foundation or HCF) but failed to disclose that HCF paid for those stories 
1 Attachment A also identifies the Sinclair and non-Sinclair stations that broadcast the programming discussed 
herein. 
 Federal Communications Commission FCC 17-171 
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to air.2  On July 26, 2016, the Bureau issued a letter of inquiry (LOI) to Sinclair, seeking more 
information about the HCI programming.3  The LOI included a copy of the Complaint.4  On September 
30, 2016, Sinclair responded to the LOI by providing a narrative statement and responsive documents 
(LOI Response).5  The Bureau thereafter issued additional inquiries to Sinclair, to which Sinclair 
responded.6 
4. As described below, although Sinclair disputes the inferences we draw from the facts, 
there are few, if any, actual disputes about the key facts associated with the apparent violations.7  Sinclair 
and the Huntsman Foundation entered into an agreement (Huntsman Agreement) to promote HCF and 
                                                     
2 Letter from anonymous complainant to Jeffrey J. Gee, Chief, Investigations and Hearings Division, FCC 
Enforcement Bureau (Mar. 31, 2016) (on file in EB-IHD-16-00021748).   
3 Letter from Matthew L. Conaty, Deputy Chief, Investigations and Hearings Division, FCC Enforcement Bureau, to 
Barry M. Faber, Esq., Executive Vice President and General Counsel, Sinclair Broadcast Group, Inc. (July 26, 2016) 
(on file in EB-IHD-16-00021748).      
4 Id. at 1, Attachment. 
5 Letter from Miles S. Mason, Esq., Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman 
LLP, to Marlene H. Dortch, Secretary, FCC, et al. (Sept. 30, 2016) (on file in EB-IHD-16-00021748) (LOI 
Response).  Sinclair acknowledged receipt of the Complaint and discussed it in its LOI Response.  Id. at 2 n.2. 
6 E-mail from Matthew L. Conaty, Deputy Chief, Investigations and Hearings Division, FCC Enforcement Bureau, 
to Miles S. Mason, Esq., Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP (Oct. 25, 
2016, 17:04 EST) (on file in EB-IHD-16-00021748) (Supplemental LOI); Letter from Miles S. Mason, Esq., 
Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, 
FCC, et al. (Nov. 4, 2016) (on file in EB-IHD-16-00021748); E-mail from Miles S. Mason, Esq., Counsel to Sinclair 
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Matthew L. Conaty, Deputy Chief, Investigations 
and Hearings Division, FCC Enforcement Bureau, et al. (Nov. 15, 2016, 16:27 EST) (on file in EB-IHD-16-
00021748) (collectively, Supplemental LOI Response); Letter from Miles S. Mason, Esq., Counsel to Sinclair 
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, FCC, et al. (Apr. 4, 
2017) (on file in EB-IHD-16-00021748) (Second Supplemental Response); Letter from Miles S. Mason, Esq., 
Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, 
FCC, et al. (May 12, 2017) (on file in EB-IHD-16-00021748) (Third Supplemental Response).  
7 Sinclair requested, pursuant to 47 CFR § 0.459, that the Commission afford confidential treatment of its entire LOI 
Response.  See LOI Response at 19.  The Bureau thereafter provided Sinclair the opportunity to supplement and 
amend its request to conform to the requirements of Section 0.459.  Letter from Matthew L. Conaty, Deputy Chief, 
Investigations and Hearings Division, FCC Enforcement Bureau, to Miles S. Mason, Esq., Counsel to Sinclair 
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP (Apr. 28, 2017) (on file in EB-IHD-16-00021748); E-
mail from Matthew L. Conaty, Deputy Chief, Investigations and Hearings Division, FCC Enforcement Bureau, to 
Miles S. Mason, Esq., Counsel to Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP (May 15, 
2017, 16:13 EDT) (on file in EB-IHD-16-00021748).  Sinclair subsequently amended and narrowed the scope of its 
request, following discussions with Commission staff.  Letter from Miles S. Mason, Esq., Counsel to Sinclair 
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, FCC, et al. (May 
17, 2017) (on file in EB-IHD-16-00021748) (rescinding request to keep confidential Exhibit D to the Supplemental 
LOI Request and pages 5-40 of the Second Supplemental Response); Letter from Miles S. Mason, Esq., Counsel to 
Sinclair Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, FCC, et al. 
(May 12, 2017) (on file in EB-IHD-16-00021748) (withdrawing request for confidentiality with respect to LOI 
Response Exhibits 1, 2, 3, 4, 5, 8, 11, 12, 15, 18 & 19); Letter from Miles S. Mason, Esq., Counsel to Sinclair 
Broadcast Group, Inc., Pillsbury Winthrop Shaw Pittman LLP, to Marlene H. Dortch, Secretary, FCC, et al. (May 3, 
2017) (on file in EB-IHD-16-00021748).  This NAL does not disclose material identified as confidential under 
Sinclair’s amended request; we defer ruling on the amended request unless and until necessary.  See 47 CFR § 
0.459(d)(3) (the Commission may defer acting on requests for confidential treatment of materials submitted to the 
Commission until a request for inspection has been made pursuant to § 0.460 or § 0.461; such materials will be 
accorded confidential treatment until the Commission acts on the confidentiality request and all subsequent appeal 
and stay proceedings have been exhausted).   
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HCI through programming broadcast on Sinclair stations and on stations to which Sinclair provided 
programming under various agreements (we refer collectively to these non-Sinclair stations as Agreement 
Stations).8  The Huntsman Agreement provided for a multi-market campaign including:  (a) 60-90 second 
sponsored stories about HCI made to look like independently generated news stories (on-air stories)9 and 
(b) 30-minute paid programs about HCI (long-form programs).10  KUTV, Sinclair’s station in Salt Lake 
City, Utah, produced the on-air stories and long-form programs and transmitted them to other stations for 
broadcast.11  According to Sinclair, “[d]espite repeated written and oral direction from Sinclair’s 
executive and legal staff to include proper sponsorship identification,” certain broadcasts containing paid 
programming aired without the required sponsorship identification announcements.12  Sinclair attributes 
this to alleged miscommunications and “misunderstanding[s]” concerning the process for inserting 
sponsorship identifications, as well as “automation of the process” which “resulted in subsequent 
omissions of the [sponsorship] identification at some stations.”13   
5. More specifically, Sinclair identified 1,644 instances in which it, and the Agreement 
Stations to which Sinclair provided the programming without the necessary disclosures, apparently failed 
to air the requisite announcements.14  Notwithstanding Sinclair’s admissions and the record evidence, 
however, and as discussed further herein, Sinclair argues that it was not legally required to make the 
sponsorship identification disclosures required under the Huntsman Agreement.15  In addition, the record 
indicates that in 79 instances, Sinclair stations and the Agreement Stations aired long-form programs with 
sponsorship announcements that failed to clearly identify HCF as the sponsor.  Overall, our review of the 
record indicates that the majority of the broadcasts of the paid on-air stories were aired without the 
required sponsorship identification announcements.16 
                                                     
8 LOI Response at 3-4, 7-9 & n.7, Answer Nos. 8 & 9, Exh. 9; Supplemental LOI Response at 5, Answer No. 4(b); 
Third Supplemental Response, Exhs. 3 & 5.  Sinclair Television Group, Inc., a Sinclair subsidiary, is the party to the 
Huntsman Agreement.  LOI Response at 9, Exh. 9.  
9 “The on-air stories [we]re separately produced . . . for distribution to the stations for inclusion in their morning 
and/or evening news programs,” LOI Response at 4, thus making them difficult to distinguish from the actual news.   
10 LOI Response at 7 & n.7, Answer No. 9, Exh. 9.  The Huntsman Agreement also contemplated the production and 
dissemination of “commercials,” which are not at issue in this matter.   See 47 CFR § 73.1212(f) (“In the case of 
broadcast matter advertising commercial products or services, an announcement stating the sponsor’s corporate or 
trade name, or the name of the sponsor’s product, when it is clear that the mention of the name of the product 
constitutes a sponsorship identification, shall be deemed sufficient for the purpose of this section and only one such 
announcement need be made at any time during the course of the broadcast.”). 
11 LOI Response at 4.   
12 Id.; Second Supplemental Response at 5-40 (listing stations, types of programs, dates, and times on which 
programming aired without a sponsorship identification announcement). 
13 LOI Response at 4.  Sinclair stations received various inquiries about the HCI programming, apparently from the 
public, but none of these inquiries seems to have resulted in discovery of the issue.  Id. at 6-7, Answer No. 7. 
14 Second Supplemental Response at 5-40.  Specifically, as set forth herein, a total of 1,366 paid programs aired on 
Sinclair stations and a total of 278 paid programs aired on Agreement Stations, representing 1,644 instances in 
which such paid programming aired without a sponsorship announcement.  See infra para. 6.   
15 LOI Response at 11-12, Answer No. 11; Supplemental LOI Response at 4, Answer No. 3(a).  
16 Third Supplemental Response, Exh. 5; Second Supplemental Response at 5-40.      
 Federal Communications Commission FCC 17-171 
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6. The following table summarizes the evidence regarding the programming broadcast by 
the Sinclair stations: 
Program Sinclair Stations 
On-air stories and long-form programs broadcast without any identification 1,36617 
Long-form programs that identified the programming as paid but failed to 
clearly identify the sponsors  71 
Total 1,437 
 
7. The following table summarizes the evidence regarding Sinclair’s failure to provide 
disclosures to the Agreement Stations and the related non-compliant broadcasts: 
Program Agreement Stations 
On-air stories and long-form programs provided to Agreement Stations 
without any identification  27818 
Long-form programs provided to Agreement Stations that identified the 
programming as paid but failed to clearly identify the sponsors 8 
Total 286  
 
III. DISCUSSION 
8. We find that Sinclair apparently willfully and repeatedly violated Section 317(a)(1) of the 
Act and Section 73.1212(a) of the Rules by broadcasting on 64 of its stations (a) 1,366 on-air stories and 
long-form programs about HCI without an announcement disclosing that the programming was 
sponsored, and (b) 71 long-form programs with deficient announcements—i.e., announcements that 
identified the programming as paid but failed to clearly identify the sponsor of the paid program.  Also, 
we find that Sinclair apparently violated the reporting obligations in Section 507 of the Act by failing to 
notify Agreement Stations in 286 instances that the Huntsman Foundation paid Sinclair to air the HCI 
programming, which resulted in programs being aired without fully compliant disclosures.19  We propose 
a forfeiture of $13,376,200 against Sinclair based on its apparent violations of the Act and the Rules.   
A.  Sinclair Apparently Violated Section 317 of the Act and Section 73.1212 of the Rules 
9. When programming is sponsored, Section 317 of the Act and Section 73.1212(a) of the 
Rules require the broadcaster to announce to viewers at the time the program is aired that the broadcaster 
has been paid to air the programming and the identification of the sponsor.20  As discussed in detail 
below, Sinclair apparently violated these provisions.   
                                                     
17 This includes 1,357 on-air stories and nine long-form programs.  See supra note 14. 
18 Pursuant to the Huntsman Agreement, Sinclair apparently provided programming to 13 Agreement Stations over 
the course of 28 weeks.  In calculating the potential violations, we counted instances in which Sinclair provided the 
programming and the programming was aired without a sponsorship identification announcement.  Second 
Supplemental Response at 5-40 (listing stations, dates, and times on which programming aired without a 
sponsorship announcement).  We only counted one violation per on-air story or long-form program, even if the 
Agreement Station aired it multiple times, because Sinclair’s apparent violations of Section 507 occurred at the 
points that it failed to disclose to the Agreement Stations that the content it supplied was sponsored.  
19 The Bureau and Sinclair initially agreed to toll the applicable statutes of limitations for all such potential 
violations by 180 days.  See Tolling Agreement at 1-2, paras. 1-2 (Sept. 8, 2016) (on file in EB-IHD-16-00021748).  
On June 7, 2017, the Bureau and Sinclair agreed to extend tolling an additional 180 days.  See Second Tolling 
Agreement at 1-2, paras. 1-2 (June 7, 2017) (on file in EB-IHD-16-00021748).  Under these agreements, the 
applicable statutes of limitations for the apparent violations, as to Sinclair, would have expired between January 8, 
2018, and July 15, 2022.  
20 Section 317(a)(1) of the Act provides in part: 
(continued….) 



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This type of graphic also accompanied long-form programs disclosing that “the program supplier” had 
paid for the broadcast.42  These announcements, however, do not sufficiently identify the program 
sponsor.43  “A sponsorship identification announcement must state in language understandable to a 
majority of the audience that the station received consideration for the matter broadcast, and from whom 
that consideration was received.”44  Likewise, the fact that the words “Huntsman Cancer Institute” 
appeared in the program does not clearly state that the Huntsman Cancer Institute paid for the program.45  
Viewers could not be expected to identify the sponsor without additional information, because the 
program supplier may not necessarily be the entity featured in the programming.  The subject matter of 
the broadcasts was insufficient to disclose the program sponsor.  Just because the program was about 
HCI, it does not necessarily follow that HCI paid for it.  Indeed, Sinclair claims it previously aired similar 
content for free as part of its own news programming.46  The Rules require not only a statement that 
material is paid for but also a specific disclosure of the identity of the individual or entity who paid for the 
broadcast of such material.   
17. The long-form program sponsorship identification announcements therefore do not 
comply with the two-part requirement of Section 73.1212 of the Rules, which mandates that the station 
announce both that the program material was paid for and the name of the individual or entity who paid 
for the program.47  The Rules require the licensee to disclose the sponsor’s identity so that viewers are not 
burdened with deducing it.48  Based on the deficient announcements in the recordings and transcripts 
Sinclair submitted, and in the absence of the Company’s ability to demonstrate that compliant 
announcements aired for any long-form program broadcasts,49 we find that all 71 long-form programs 
                                                     
42 LOI Response at 16, Answer No. 16, Exh. 15, Recording No. 36, WLOS; Supplemental LOI Response at 3, 
Answer No. 1(g), Supplemental Exh. A.   
43 See Sonshine Family Television, Inc.; Sinclair Broadcast Group, Inc., Notice of Apparent Liability for Forfeiture, 
22 FCC Rcd 18686, 18693, paras. 14-15 & n.35 (2007) (Sonshine NAL), aff’d with reduced forfeiture, Forfeiture 
Order, 24 FCC Rcd 14830, 14833-34, paras. 11-12 (2009) (forfeiture reduced and paid) (Sonshine Forfeiture Order) 
(rejecting licensee’s assertion that the overall presentation of sponsored programming, which included identification 
of the program title participants and production company, sufficed); WTOP License Limited Partnership,  Notice of 
Apparent Liability for Forfeiture, 10 FCC Rcd 11002, 11002 (MMB 1995) (WTOP NAL) (tag line stating “the 
following is a commercial announcement” preceding a paid announcement did not suffice because the tag line failed 
to identify by whom or on whose behalf the announcement consideration was supplied), aff’d with reduced 
forfeiture, Memorandum Opinion and Order, 11 FCC Rcd 11840 (MMB 1996); Liability of WDAX, Incorporated, 
Memorandum Opinion and Order, 6 FCC Rcd 1987, 1987, paras. 2 & 4 (MMB 1991) (assessing forfeiture where the 
licensee identified a sponsored message as a “paid announcement” but failed to provide the name of the sponsor 
who paid for the message).   
44 Sonshine NAL, 22 FCC Rcd at 18693, para. 14 (footnote omitted).   
45 See Radio License Holding XI, LLC, Forfeiture Order, 29 FCC Rcd 1623, 1623-24, 1625, paras. 3, 5 (2014) 
(forfeiture paid) (Radio License Holding XI) (deeming mere mention of sponsor’s name in the course of paid 
informational program material insufficient to satisfy sponsorship identification requirements). 
46 LOI Response at 12, Answer No. 11. 
47 47 CFR § 73.1212(a)(1)-(a)(2). 
48 Cf. WPIX, Inc. (WPIX), New York, New York; Forum Communications, Inc., New York, New York, Initial Decision 
of Administrative Law Judge James F. Tierney, 68 FCC 2d 218, 327, para. 488 (1974) (“The announcement 
expected should fully and fairly disclose the true identity of the consideration source.”). 
49 See Infinity Broadcasting Corporation of Los Angeles, Memorandum Opinion and Order, 17 FCC Rcd 9892, 
9896, para. 18 (2002) (“[A] licensee may not avoid liability by claiming that he doesn’t know what did or did not go 
out over his station.”) (internal quotation marks omitted); ProActive Communications, Inc., Notice of Apparent 
Liability for Forfeiture, 23 FCC Rcd 9079, 9082-83, para. 7 (EB 2008) (forfeiture paid) (ProActive) (“[T]he 
Commission has previously ruled that a licensee may not avoid liability for a rule violation by claiming ignorance as 
to what was broadcast over its station.”).   


 Federal Communications Commission FCC 17-171 
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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, substantial economic gain, and such other matters 
as justice may require.61  We have discretion to upwardly or downwardly adjust from the base forfeiture, 
taking into account the particular facts of each individual case.62   
24. Section 1.80(b) of the Rules sets a base forfeiture of $4,000 for violations of the 
Commission’s sponsorship identification rules for each violation or each day of a continuing violation.63  
We apply the $4,000 base forfeiture to each of Sinclair’s apparent violations of the sponsorship 
identification requirements, including the apparent violations of Section 317 of the Act and Section 
73.1212 of the Rules (1,437 instances of apparently airing programs without the requisite disclosures), 
and the apparent violations of the reporting obligations of Section 507 of the Act (286 instances of 
apparently failing to provide the requisite disclosures to Agreement Stations, which then apparently failed 
to air the required disclosures).64  Thus, the aggregate base forfeiture amount for the violations at issue 
here is $6,892,000. 65   
(Continued from previous page)                                                            
Office of Mgmt. & Budget, Exec. Office of the President, Memorandum for the Heads of Executive Departments 
and Agencies re Implementation of the 2017 annual adjustment pursuant to the Federal Civil Penalties Inflation 
Adjustment Act Improvements Act of 2015, M-17-11, Dec. 16, 2016, at 1.  The Bureau released the order making 
the 2017 annual adjustment on December 30, 2016.  See Amendment of Section 1.80(b) of the Commission’s Rules, 
Adjustment of Civil Monetary Penalties to Reflect Inflation, Order, DA 16-1453 (EB 2016), 2016 WL 7492481; see 
also Annual Adjustment of Civil Monetary Penalties to Reflect Inflation, 82 Fed. Reg. 8170 (Jan. 24, 2017) (setting 
January 24, 2017, as the effective date for the increases).  The 2015 Inflation Adjustment Act provides that the new 
penalty levels shall apply to penalties assessed after the effective date of the increase, “including [penalties] whose 
associated violation predated such increase.”  See 28 U.S.C. § 2461 note, citing the Federal Civil Penalties Inflation 
Adjustment Act, as amended, § 6.   
61 47 U.S.C. § 503(b)(2)(E); 47 CFR § 1.80(b)(8), Note § II (articulating criteria for upward adjustments (egregious 
misconduct, ability to pay/relative disincentive, intentional violation, substantial harm, prior violations of any FCC 
requirements, substantial economic gain, and repeated or continuous violation) and downward adjustments (minor 
violation, good faith or voluntary disclosure, history of overall compliance, and inability to pay)). 
62 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, 17098-99, para. 22 (1997) (1997 Forfeiture Policy 
Statement) (noting that “[a]lthough we have adopted the base forfeiture amounts as guidelines to provide a measure 
of predictability to the forfeiture process, we retain our discretion to depart from the guidelines and issue forfeitures 
on a case-by-case basis, under our general forfeiture authority contained in Section 503 of the Act”), recons. denied, 
Memorandum Opinion and Order, 15 FCC Rcd 303 (1999). 
63 47 CFR § 1.80(b).   
64 Section 1.80 lists a base forfeiture of $4,000 per violation for “sponsorship identification requirements.”  The 
Commission has previously assessed forfeitures consistent with this listing in instances involving violations of 
sponsorship identification requirements under Section 317 of the Act and Section 73.1212 of the Commission’s 
rules.  See Radio License Holding XI, LLC, 29 FCC Rcd at 1628, 1630-31, paras. 1, 12, 17 (2014).  To the extent 
necessary for purposes of this proceeding, we find this to be persuasive precedent for purposes of support for these 
requirements as well as for violations of Section 507 of the Act given the similarities in conduct proscribed and 
public interest involved.  The requirements at issue relate to adequate sponsorship identification so that the public 
may know who seeks to persuade it. 
65 In Radio License Holding XI, we observed that “[i]n more recent cases . . . [we have] imposed significantly higher 
forfeiture amounts and ha[ve] calculated the forfeiture by multiplying the base forfeiture by the number of violations 
. . . . We are following here the approach we used in Sonshine, and we intend that the Commission and the Bureau 
will generally take this approach to calculating forfeiture amounts for sponsorship identification violations in the 
future.”  Radio License Holding XI, LLC, 29 FCC Rcd at 1628, para. 12.  Although the Commission has deviated 
from a per-instance standard occasionally in other areas, see, e.g., STi Telecom, Inc., Forfeiture Order, 30 FCC Rcd 
11742, 11756, para. 30 (2015), in this case, no excessive penalties will result if we follow the guidance in Radio 
License Holding XI, LLC; thus, we see no reason to deviate from that approach here. 
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25. In this case, given the totality of the circumstances, and consistent with the 1997 
Forfeiture Policy Statement, we conclude that a significant upward adjustment is warranted.  This 
adjustment is justified by multiple statutory factors, beginning with the nature, circumstances, extent, and 
gravity of the violations.66  As a result of Sinclair’s conduct detailed above, in more than 1,700 instances 
during a seven-month period, HCI on-air stories and long-form programs apparently were broadcast 
without the required sponsorship identification announcements on 77 stations, including 64 Sinclair 
stations and 13 non-Sinclair Agreement Stations, and potentially reached a large national audience of 
viewers.67  The violations at issue were not isolated either geographically or temporally.68  Most of the 
apparent violations involved paid programming that aired without any sponsorship identification 
announcements and could have misled the audience into believing the content was independently 
generated news originated without regard to third-party influence.  Although some of the apparent 
violations provided incomplete disclosures—that the programming was paid but not by whom—such 
violations accounted for only a small number of all violations.  That said, we do not upwardly adjust to 
the same extent for such violations as we do for violations where there was no disclosure.   
26. In addition, Sinclair has a prior history of violating other FCC rules governing 
commercial messages.69  Over the past decade, Sinclair has repeatedly violated the commercial limits 
component of the Children’s Television Rules, 47 CFR § 73.670.70   
27. That an upward adjustment is warranted also is confirmed by other factors.  The 
Huntsman Agreement generated significant revenue, requiring payments of $275,000 per month to 
Sinclair in consideration for these broadcasts, for an expected total compensation package of $ .71  
Moreover, Sinclair, a sophisticated broadcaster with national reach, reported 2016 revenues in excess of 
$2.7 billion.72  As we have previously noted and “as Congress has stated, for a forfeiture to be an effective 
                                                     
66 47 U.S.C. § 503(b)(2)(E). 
67 See Viacom, Inc., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 2548, 2566, para. 38 (2014) aff’d sub 
nom. Viacom Inc. ESPN Inc., Forfeiture Order, 30 FCC Rcd 797, 805, para. 21 (2015) (forfeitures paid) (Viacom) 
(assessing forfeitures of $1,120,000 against Viacom and ESPN, based, in pertinent part, upon companies’ networks’ 
substantial audience reach); Behringer USA, Inc., Forfeiture Order, 22 FCC Rcd 10451, 10457-58, para. 16 (2007) 
(forfeiture paid) (nature and extent of violations justify an upward adjustment); see also Capstar TX Limited 
Partnership, Notice of Apparent Liability for Forfeiture, 23 FCC Rcd 10464, 10467-68, paras. 8-9 (EB 2008) 
(forfeiture paid) (applying upward adjustment of the base forfeiture from $4,000 to $12,000); Multicultural Radio 
Broadcasting Licensee, LLC, Notice of Apparent Liability for Forfeiture, 22 FCC Rcd 21555, 21561-62, para. 15 
(EB 2007) (forfeiture paid) (applying an upward adjustment from the base forfeiture of $4,000 to $12,000 based in 
part on an egregious violation); Citicasters Licenses, L.P., Notice of Apparent Liability for Forfeiture, 22 FCC Rcd 
1633, 1635-36, paras. 9-10 (EB 2007) (forfeiture paid) (applying upward adjustment of the base forfeiture from 
$4,000 to $10,000).  
68 We have not upwardly adjusted based on the number of incidents to avoid any double counting against Sinclair. 
69 See Forfeiture Policy Statement, 12 FCC Rcd at 17116 (including “[p]rior violations of any FCC requirements” as 
an upward adjustment factor).  
70 Channel 33, Inc., Letter and Admonishment, 29 FCC Rcd 12609 (MB 2014); WLOS Licensee, LLC, Notice of 
Apparent Liability for Forfeiture, 25 FCC Rcd 4598 (MB 2010) (forfeiture paid); San Antonio (KRRT-TV) Licensee, 
Inc., Forfeiture Order, 25 FCC Rcd 3747 (MB 2010) (forfeiture paid); WVTV Licensee, Inc., Forfeiture Order, 25 
FCC Rcd 3741 (MB 2010) (forfeiture paid); KLGT Licensee, LLC, Notice of Apparent Liability for Forfeiture, 24 
FCC Rcd 949 (MB 2009) (forfeiture paid); WLFL Licensee LLC, Notice of Apparent Liability for Forfeiture, 23 
FCC Rcd 8182 (MB 2008) (forfeiture paid); WUXP Licensee, LLC, Notice of Apparent Liability for Forfeiture, 23 
FCC Rcd 6397 (MB 2008) (forfeiture paid). 
71 LOI Response at 11, Answer No. 10; Exh. 9. 
72 Sinclair Broadcast Group, Inc., Annual Report (Form 10-K) at 5-10, 34-35 (Feb. 28, 2017), 
https://www.sec.gov/Archives/edgar/data/912752/000091275217000006/sbgi-20161231x10k htm (describing 
national scope of and annual revenues realized from Sinclair’s broadcast operations).  
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deterrent . . . [it] must be issued at a high level . . . to guarantee that forfeitures issued against large or 
highly profitable entities are not considered merely an affordable cost of doing business.”73   
28. In applying the applicable statutory factors, we also consider whether there is any basis 
for a downward adjustment of the proposed forfeiture.  Here, we find none.   
29. The purported fact that Sinclair intended to comply with the law does not warrant a 
downward adjustment.  Although Sinclair now contends no sponsorship identification disclosures were 
required, Sinclair nonetheless claims its “senior corporate executives and legal staff always intended that 
the stories would include sponsorship identification, and many stations did, in fact, include such 
identification.”74  Even if true, this would not support a downward adjustment; the relevant precedent is to 
the contrary.75   
30. We also are cognizant of certain corrective measures Sinclair took, but it did so only after 
receiving the Bureau’s LOI.76  Under the circumstances of this case, Radio License Holding XI and other 
Commission precedent do not support a downward adjustment for such corrective action.77   
31. Moreover, we find no basis for a downward adjustment based on the purported public 
interest benefits of the HCI programming.  Viewers are entitled to the protections of our laws and must be 
                                                     
73 Forfeiture Policy Statement, 12 FCC Rcd at 17099-100, para. 24.  See Viacom, 30 FCC Rcd at 797-98, 805-06, 
paras. 2, 22 (noting that an upward adjustment is appropriate in light of Viacom’s reported annual revenues and the 
revenues of ESPN’s parent); Union Oil Company of California, Notice of Apparent Liability for Forfeiture, 27 FCC 
Rcd 13806, 13810, para. 10 (2012) (forfeiture paid) (proposing an upward adjustment of the base forfeiture from 
$26,000 to $96,200 for unauthorized operation of private land mobile radio stations after license expiration based in 
part on recognition that Union Oil’s parent company, Chevron, is a multibillion dollar global enterprise and to 
ensure that forfeiture liability is a deterrence and not a cost of doing business); SBC Communications Inc., Order on 
Review, 17 FCC Rcd 4043, 4052, para. 20 (2002) (forfeiture paid) (“[A] large and highly profitable company . . . 
should expect . . . that the forfeiture amount” may “be above, or even well above, the relevant base amount.”) 
(internal quotation marks omitted; second set of alterations in original).  
74 LOI Response at 4.     
75 See Unipoint Technologies, Inc. d/b/a Comfi.com d/b/a Masterbell.com d/b/a Pushline.com a/k/a Communications 
Fidelity, Forfeiture Order, 29 FCC Rcd 1633, 1640, para. 21 (2014) (“It is immaterial whether [the licensee’s] 
violations were inadvertent, the result of ignorance of the law, or the product of administrative oversight.”), default 
judgment entered, United States v. Unipoint Technologies, Inc., No. 14-12020-LTS, 2016 WL 8902575, at *1-2 (D. 
Mass. Apr. 27, 2016); Texas Soaring Association, Inc. Midlothian, Texas, Forfeiture Order, 28 FCC Rcd 10740, 
10743-44, para. 7 (EB 2013) (forfeiture paid) (“Even if administrative oversight, inadvertence, or a lack of 
familiarity with the Rules may have contributed to the violation, they do not . . . mitigate liability arising therefrom”) 
(footnotes omitted); Cascade Access, L.L.C., Forfeiture Order, 28 FCC Rcd 141, 145, para. 9 (EB 2013) (forfeiture 
paid) (rejecting argument that the unintentional nature of the violation justifies mitigation of the forfeiture amount), 
recon. denied, Memorandum Opinion and Order, 30 FCC Rcd 14018 (EB 2015); América Móvil, S.A.B. de C.V. 
Parent of Puerto Rico Telephone Company, Inc., Notice of Apparent Liability for Forfeiture, 26 FCC Rcd 8672, 
8676, para. 11 (EB 2011) (forfeiture paid) (“While América Móvil claimed that the violation was a result of an 
inadvertent oversight, it is well established that administrative oversight or inadvertence is not a mitigating factor 
warranting a downward adjustment of a forfeiture.”).  
76 See LOI Response at 4, 12-13, Answer No. 12 & Exh. 10; Supplemental LOI Response at 7, Answer No. 5(b) & 
Supplemental Exh. D.   
77 See Radio License Holding XI, 29 FCC Rcd at 1629-30, para. 15 (declining to reduce a per-broadcast forfeiture 
even when the licensee took certain corrective action prior to receiving the Bureau’s letter of inquiry, but did not 
also notify listeners of the violative announcements and did not voluntarily disclose its conduct to the Commission); 
Union Broadcasting, Inc., Forfeiture Order, 19 FCC Rcd 18588, 18590, para. 10 (EB 2004) (forfeiture paid) 
(specifying that “‘corrective action taken to come into compliance with Commission rules or policy is expected, and 
does not nullify or mitigate any prior forfeitures or violations’”), quoting Seawest Yacht Brokers d/b/a San Juan 
Marina Friday Harbor, Washington, Forfeiture Order, 9 FCC Rcd 6099, para. 7 (1994). 
 Federal Communications Commission FCC 17-171 
 14
informed of whether a third party is paying to influence them, and who that third party is, through their 
local broadcasters regardless of the content of the programming.78 
32. Finally, while we have taken into account that Sinclair made incomplete disclosures in a 
small number of instances, we do not think the balance of considerations warrants downward adjustment 
of the proposed base forfeiture where such incomplete disclosures were made—identifying the 
programming as paid but not clearly identifying the sponsor.  As set forth above and below, we have 
already applied a lower upward adjustment to the incomplete disclosures.79 
33. Neither the language of the Act nor the Rules suggests that an incomplete disclosure is 
sufficient to enable consumers to know “that they are being persuaded and by whom they are being 
persuaded”—the fundamental purpose of the sponsorship identification rules.  Section 317 of the Act and 
Section 73.1212 of the Rules clearly require broadcasters “to inform the audience of two things:  that [the 
audience] is hearing or viewing matter which has been paid for, and the identity of the message 
sponsor.”80    
34. As the Commission long ago explained:  “In all cases, the public is entitled to know the 
name of the company it is being asked to deal with;” speaking specifically of Section 317 of the Act: “its  
plain intent is to prevent a fraud being perpetrated on the listening public by letting the public know the 
people with whom they are dealing.”81  An incomplete disclosure that fails to identify the sponsor does 
not inform the public of who seeks to persuade them and does not provide viewers with facts they may 
find crucial in evaluating the credibility of the programming.82  Because the plain objective of the Act, 
then, is fully frustrated by an incomplete disclosure, a full forfeiture is warranted.  Moreover, we are 
concerned that downward adjusting the forfeiture amount for such incomplete disclosures under the facts 
                                                     
78 See, e.g., Fox Television Stations, Inc., Notice of Apparent Liability for Forfeiture, 26 FCC Rcd 3964, 3970-71, 
paras. 15-17 (EB 2011) (sponsorship identification requirements are content-neutral disclosure requirements, and 
any penalty adjustment, whether upward or downward, based on an evaluation of the value of the sponsored content 
would potentially raise constitutional issues under the First Amendment), aff’d, Forfeiture Order, 26 FCC Rcd 9485 
(EB 2011) (forfeiture paid) (Fox Television Stations).  The Commission’s role is limited to determining whether the 
licensee disclosed the programming was sponsored or paid for and by whom or on whose behalf such payment or 
consideration was supplied; under the First Amendment and Section 326 of the Act, “the Commission must avoid 
intrusion on a broadcaster’s editorial judgments.”  Fox Television Stations, 26 FCC Rcd at 3971, para. 17.  See 47 
U.S.C. § 326; cf. Nat’l Ass’n for Better Broad. v. FCC, 830 F.2d 270, 277 (D.C. Cir. 1987) (sponsorship 
identification law must “be given its normal operative force even though the program in question might not be 
regarded as entirely commercial in content”); Carolina Rays, LLC, Forfeiture Order, 28 FCC Rcd 10068, 10071, 
para. 11 (MB 2013) (forfeiture paid) (rejecting licensee’s argument that forfeiture should be reduced or mitigated 
based upon service to the community and significant local programming).  
79 See supra para. 25 and infra para. 36.   
80 Commission Reminds Broadcast Licensees and Cable Operators of Sponsorship Identification Requirements 
Applicable to Paid-For “Public Service Messages,” Public Notice, 6 FCC Rcd 5861 (1991) (emphasis added).  See 
Radio License Holding XI, 29 FCC Rcd at 1627, para. 9, quoting Commission Reminds Broadcast Licensees, Cable 
Operators and Others of Requirements Applicable to Video News Releases and Seeks Comment on the Use of Video 
News Releases by Broadcast Licensees and Cable Operators, Public Notice, 20 FCC Rcd 8593, 8593-94 (2005); 
Applicability of Sponsorship Identification Rules, Public Notice, 40 FCC 141, 141 (1963) (subsequent history 
omitted) (“[A]s far back as the Radio Act of 1927 and continuing with Section 317 of the Communications Act of 
1934 there has been an unvarying requirement that all matter broadcast by any station for a valuable consideration is 
to be announced as paid for or furnished, and by whom.”).   
81 Identification on Broadcast Station, Public Notice, 40 FCC 2 (1950).   
82 The identity of a sponsor may substantially impact the credibility of the message.  For example, a viewer may 
attach different meaning to the same content where the content was generated by an organization that stands to gain 
a financial benefit from the program, as compared to content generated by an organization with no similar pecuniary 
interest.   
 Federal Communications Commission FCC 17-171 
 15
of this case may send the wrong message about the level of care required of broadcasters and thus 
inadvertently incentivize broadcasters to invest fewer resources towards ensuring full compliance. 
35. In certain limited situations, some cases have applied downward adjustments where there 
were incomplete disclosures.  However, those decisions are non-binding83 or distinguishable.84   
Moreover, more recently in the Sonshine NAL, the Commission declined to reduce a forfeiture based on 
the licensee’s argument of a purported “good faith” attempt to comply with sponsorship identification 
requirements.85  According to the record in this case, Sinclair was manifestly aware of the need to include 
fully compliant sponsorship identification disclosures in its paid programming,86 and effectuating the 
                                                     
83 See Comcast Corp. v. FCC, 526 F. 3d 763, 769-70 (D.C. Cir. 2008) (“an agency is not bound by the actions of its 
staff if the agency has not endorsed those actions”) (internal quotation marks omitted); Radio License Holding XI, 
29 FCC Rcd at 1628, para. 12.   
84 For example, in Jacor, a licensee broadcast a series of “60-second announcements promoting the commercial 
services and attractions of Cripple Creek, Colorado,” without specifically identifying their sponsor, the Cripple 
Creek Chamber of Commerce.  Jacor Broadcasting of Colorado, Inc., Memorandum Opinion and Order and 
Forfeiture Order, 12 FCC Rcd 9969, 9969, paras. 2 (1997) (Jacor).  The Commission rejected the licensee’s 
argument that Section 73.1212(f) applied, deeming the area services and attractions were “not obviously intertwined 
in the public mind” with the Chamber of Commerce.  Id. at 9970, para. 2.  However, the Commission recalculated 
its forfeiture from $10,000 to $4,000, because “the commercial nature of the announcements was clear to even the 
most casual listener.”  Id. at 9971, para. 6.  In contrast, Sinclair’s long-form programs were not merely 60 seconds 
long, but 30 minutes long, and could not be considered “clear” commercials as Sinclair itself claimed they were part 
of a campaign to “educate the public about cancer, available treatments, preventative measures and related issues” 
and “aimed at increasing national awareness of the Huntsman Cancer Institute’s clinical services and research 
operations.”  LOI Response at 3, 7, n.7, 9-10, Answer No. 9(b) (“[T]he Huntsman Agreement is a joint effort to 
increase awareness about the Huntsman Institute’s medical services and research initiatives and to educate the public 
about cancer, available treatments, preventive measures and related issues”).  Moreover, we already have 
determined Sinclair’s purported attempts to comply with the law, or its mistakes about the nature of the disclosures 
the law requires, do not warrant a downward adjustment.  See supra para. 29.  Older decisions on delegated 
authority to the Mass Media Bureau also have on occasion suggested that forfeiture reductions were justified by a 
“partial, albeit incomplete, sponsorship identification broadcast” or “good faith” intentions.  See, e.g., Channel 36 
Licensee Corporation, Notice of Apparent Liability for Forfeiture, 7 FCC Rcd 6541, 6541 (MMB 1992) (Channel 
36); Great Trails Broadcasting Corporation, Memorandum Opinion and Order, 8 FCC Rcd 2089, 2089, para. 5 
(MMB 1993) (construing Channel 36); WTOP NAL, 10 FCC Rcd at 11002.  To the degree that these cases suggest 
that incomplete disclosures generally warrant downward adjustments, we overrule them.  (Sonshine previously cited 
Channel 36 favorably for a different proposition, Sonshine NAL, 22 FCC Rcd at 18693, para. 15 & n.39 (citing 
Channel 36 for the proposition that “the Commission has found that the phrase ‘sponsored by’ may be used in place 
of ‘paid for,’ but no other substitute words or phrases have been specifically allowed”), and we do not disturb the 
holding of Channel 36 as to that point. Here, the evidence shows that Sinclair understood the need to fully comply 
with the disclosure obligation, and we already have determined purported attempts to comply with the laws, or its 
mistakes about the nature of the disclosures the laws require, do not warrant a downward adjustment.  See supra 
para. 29.   
85 Sonshine M&O, 24 FCC Rcd at 14834, para. 13; see Radio License Holding XI, 29 FCC Rcd at 1629, para. 14 
(rejecting licensee’s argument that inadvertent actions or omissions justified a downward adjustment of the 
forfeiture amount); Southern California Broadcasting Company, 6 FCC Rcd at 4387-88, paras. 3-4 (rejecting 
licensee’s arguments that violations were inadvertent and that it had made good faith attempts to comply with the 
sponsorship identification requirements).   
86 LOI Response, Exh. 10; see, e.g., id. at 2, 4, 9-10, 11-12, 16-17, Answer Nos. 8(e), 9(b) 11, 16, 17(d).  For 90 
years, since the inception of commercial broadcasting, broadcasters have been subject to remarkably consistent 
sponsorship identification requirements.  Section 317 of the Act was included in and has remained largely 
unchanged since the passage of the Communications Act of 1934.  In fact, Section 317 was taken nearly word-for-
word from Section 19 of the Radio Act of 1927 (Radio Act), which in turn was informed by postal policy regarding 
subsidized postage from the late 19th and early 20th centuries.  See Richard Kielbowicz and Linda Lawson, 
Unmasking Hidden Commercials in Broadcasting:  Origins of the Sponsorship Identification Regulations, 1927-
1963, 56 Fed. Comm. L.J. 329, 334-336 (2004).  
 Federal Communications Commission FCC 17-171 
 16
broadcast of fully compliant disclosures in accordance with the straightforward precepts of Section 317 of 
the Act and Section 73.1212 of the Rules should pose no challenge.  
36.  Therefore, after applying the 1997 Forfeiture Policy Statement, Section 1.80 of the 
Rules, and the statutory factors, we propose a total forfeiture of $13,376,200, for which Sinclair is 
apparently liable.  The proposed forfeiture is calculated as follows: 
Apparent Violation Number of Apparent 
Violations 
Proposed Forfeiture 
Per Apparent 
Violation 
Total 
Sinclair stations—no 
disclosures 
1,366 
 
$7,800 $10,654,800 
 
Sinclair stations—
incomplete disclosures 
71 $7,000 $497,000 
Non-Sinclair stations—
no disclosures 
278 $7,800 $2,168,400 
Non-Sinclair stations—
incomplete disclosures  
8 
 
$7,000 $56,000 
 
Total 1,723 NA $13,376,200 
 
IV. CONCLUSION 
37. We have determined that Sinclair apparently willfully and repeatedly violated Sections 
317 and 507 of the Act and Section 73.1212 of the Rules.  As such, Sinclair is apparently liable for a 
forfeiture of $13,376,200. 
V. ORDERING CLAUSES 
38. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act87 and Section 
1.80 of the Rules,88 Sinclair Broadcast Group, Inc. is hereby NOTIFIED of its APPARENT 
LIABILITY FOR A FORFEITURE in the amount of thirteen million three hundred seventy-six 
thousand two hundred dollars ($13,376,200) for willful and repeated violations of Sections 317 and 507 
of the Act89 and Section 73.1212 of the Rules.90 
39. IT IS FURTHER ORDERED that pursuant to Section 1.80 of the Rules,91 within 30 
calendar days of the release date of this Notice of Apparent Liability for Forfeiture, Sinclair Broadcast 
Group, Inc. SHALL PAY the full amount of the proposed forfeiture or SHALL FILE a written 
statement seeking reduction or cancellation of the proposed forfeiture consistent with paragraph 40 below. 
40. Payment of the forfeiture must be made by check or similar instrument, wire transfer, or 
credit card, and must include the NAL/Account Number and FRN referenced above.  Sinclair Broadcast 
Group, Inc. shall send electronic notification of payment to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, 
Matthew L. Conaty at Matthew.Conaty@fcc.gov, Luba Shur at Luba.Shur@fcc.gov, and Melanie A. 
                                                     
87 47 U.S.C. § 503(b). 
88 47 CFR § 1.80. 
89 47 U.S.C. §§ 317, 508. 
90 47 CFR § 73.1212.   
91 47 CFR § 1.80. 
 Federal Communications Commission FCC 17-171 
 17
Godschall at Melanie.Godschall@fcc.gov on the date said payment is made.  Regardless of the form of 
payment, a completed FCC Form 159 (Remittance Advice) must be submitted.92  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 that should be 
followed based on the form of payment selected:  
• 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. 
• 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. 
41. Any request for making full payment over time under an installment plan should be sent 
to:  Chief Financial Officer—Financial Operations, Federal Communications Commission, 445 12th 
Street, SW, Room 1-A625, Washington, DC 20554.93  Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by telephone, 1-877-480-3201, or by e-mail, 
ARINQUIRIES@fcc.gov. 
42. The written statement seeking reduction or cancellation of the proposed forfeiture, if any, 
must include a detailed factual statement supported by appropriate documentation and affidavits pursuant 
to Section 1.16 and 1.80(f)(3) of the Rules.94  The written statement must be mailed to the Office of the 
Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, ATTN:  
Enforcement Bureau  ?  Investigations and Hearings Division, and must include the NAL/Acct Number 
referenced in the caption.  The statement must also be e-mailed to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, 
Matthew L. Conaty at Matthew.Conaty@fcc.gov, Luba Shur at Luba.Shur@fcc.gov, and Melanie A. 
Godschall at Melanie.Godschall@fcc.gov.   
43. The Commission will not consider reducing or canceling a forfeiture in response to a 
claim of inability to pay unless Sinclair Broadcast Group, Inc. 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.   
44. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by first class mail and certified mail, return receipt requested to Barry M. Faber, 
Esq., Executive Vice President and General Counsel, Sinclair Broadcast Group, Inc., 10706 Beaver Dam 
                                                     
92 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www fcc.gov/Forms/Form159/159.pdf. 
93 47 CFR § 1.1914. 
94 47 CFR §§ 1.16, 1.80(f)(3). 
 Federal Communications Commission FCC 17-171 
 18
Road, Cockeysville, Maryland 21030, and to Miles S. Mason, Esq., Pillsbury Winthrop Shaw Pittman 
LLP, 1200 Seventeenth Street, NW, Washington, DC 20036-3006.   
             
      FEDERAL COMMUNICATIONS COMMISSION 
 
 
 
 
      Marlene H. Dortch 
      Secretary 
  19
 Federal Communications Commission  FCC 17-171 
ATTACHMENT A 
 
SINCLAIR STATIONS 
 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KABB 
Licensee, 
LLC/KABB, 
San Antonio, 
TX 0004970455 56528
  
 
  
2
6/5/2016 
7/24/2016
Sinclair 
Portland 
Licensee, 
LLC/KATU, 
Portland, OR 0023174519 
 
 
21649
 
 
27
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
 
 
 
1 6/5/2016
                                                     
1 Third Supplemental Response, Exh. 2 & 3. 
2 Third Supplemental Response, Exh. 3. 
  20
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KATV 
Licensee, 
LLC/KATV, 
Little Rock, 
AR 0023870488 
 
33543
 
3
6/3/2016 
6/10/2016 
6/24/2016 
 
 
 
 
 
 
2
6/5/2016 
7/23/2016
Sinclair 
Bakersfield 
Licensee, 
LLC/KBAK, 
Bakersfield, 
CA 0023174451 
 
4148 23
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016 
 
 
 
  
1 6/5/2016
  21
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Sinclair 
Bakersfield 
Licensee, 
LLC/KBFX-
CD, 
Bakersfield, 
CA 0023174451 51501 26
1/22/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
  
1 6/5/2016
Sinclair Boise 
Licensee, 
LLC/KBOI-
TV, Boise, ID 0023174428 
 
49760
 
27
1/15/2016 
1/22/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/24/2016
  22
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KDBC 
Licensee, 
LLC/KDBC-
TV, El Paso, 
TX 0018608257 
 
33764
 
15
4/1/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/15/2016 
7/22/2016
 
 
 
  
1 6/5/2016
KDNL 
Licensee, 
LLC/KDNL-
TV, St. Louis, 
MO 0002144459 
 
56524 21
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
  23
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Sinclair 
Yakima 
Licensee, 
LLC/KEPR-
TV, Pasco, WA 0023174543 
 
 
56029 24
1/22/2016 
2/5/2016 
2/12/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/24/2016 
4/8/2016 
4/16/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016 
 
  
Sinclair 
Yakima 
Licensee, 
LLC/KIMA-
TV, Yakima, 
WA 
 
 
0023174543 56033 24
1/22/2016 
2/5/2016 
2/12/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/24/2016 
4/8/2016 
4/16/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016 
 
  
1 6/5/2016
  24
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KEYE 
Licensee, 
LLC/KEYE-
TV, Austin, TX 0021141494 
 
33691
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/5/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
KFDM 
Licensee, 
LLC/KFDM, 
Beaumont, TX 0021268396 
 
22589
 
25
1/15/2016 
1/22/2016 
1/29/2016 
2/12/2016 
2/19/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016
 
 
  
2
6/5/2016 
7/24/2016
  25
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KFOX 
Licensee, 
LLC/KFOX-
TV, El Paso, 
TX 0022463855 
 
33716 21
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
3/4/2016 
3/11/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
  26
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KGAN 
Licensee, 
LLC/KGAN, 
Cedar Rapids, 
IA 0004970521 
 
25685 29
1/15/2016 
1/22/2016 
1/29/2016 
2/5/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/6/20163 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
 
  
 
1
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6/5/2016
KGBT 
Licensee, 
LLC/KGBT-
TV, Harlingen, 
TX 0022491526 
 
34457
 
27
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
1 6/5/2016
 
                                                     
3 The on-air story apparently aired twice on 5/6/2016, during the 6:00 a.m. hour and the 6:00 p.m. hour.  Second Supplemental Response. 
  27
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KHGI 
Licensee, 
LLC/KHGI-
TV, Kearney, 
NE; KHGI-CD, 
North Platte, 
NE; KWNB-
TV, Hayes 
Center, NE4 0009529157 
21160 
168339 
21162 21
6/10/2016 
6/10/2016 
6/10/2016 
6/17/2016 
6/17/2016 
6/17/2016 
6/24/2016 
6/24/2016 
6/24/2016 
7/1/2016 
7/1/2016 
7/1/2016 
7/8/2016 
7/8/2016
7/8/2016 
7/15/2016 
7/15/2016 
7/15/2016 
7/22/2016 
7/22/2016 
7/22/2016
 
   
KHQA 
Licensee, 
LLC/KHQA-
TV, Hannibal, 
MO 0022491609 
 
4690 
 
27
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
 
  
1
 
 
 
 
 
 
 
 
 
 
 
 
 
6/5/2016
                                                     
4 These stations all apparently aired the on-air stories on the same dates and times.  Second Supplemental Response. 
  28
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KMPH 
Licensee, 
LLC/KMPH-
TV, Visalia, 
CA 0018608273 
 
51488
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/5/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
KOKH 
Licensee, 
LLC/KOKH-
TV, Oklahoma 
City, OK 0006587109 
 
 
35388
 
24
1/29/2016 
2/4/2016 
2/12/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/24/2016
  29
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Sinclair Seattle 
Licensee, 
LLC/KOMO-
TV, Seattle, 
WA 0023174477 
 
21656
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
 
 
1 6/5/2016
KRCG 
Licensee, 
LLC/KRCG, 
Jefferson City, 
MO 0022491815 
 
41110
 
24
1/22/2016 
1/29/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
  30
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KUPN 
Licensee, 
LLC/KSNV, 
Las Vegas, NV 0004970646 
 
10179 27
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/15/2016 
4/22/2016 
4/29/2016
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/23/2016
KTUL 
Licensee, 
LLC/KTUL, 
Tulsa, OK 0023870496 
 
35685
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/22/2016
  31
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KTVL 
Licensee, 
LLC/KTVL, 
Medford, OR 0021268370 
 
22570
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/24/2016
KTVO 
Licensee, 
LLC/KTVO, 
Kirksville, MO 0022491534 
 
21251
 
6
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/4/20165 
2/12/2016
 
 
  
1 6/5/2016
                                                     
5 The on-air story apparently aired twice on 2/4/2016, during the 6:00 a.m. hour and the 10:00 p.m. hour.  Second Supplemental Response. 
  32
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KUTV 
Licensee, 
LLC/KUTV, 
Salt Lake City, 
UT 0021144076 
 
35823
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
Sinclair Eugene 
Licensee, 
LLC/KVAL-
TV, Eugene, 
OR 
 
0023174535 
 
 
49766
 
 
27
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
 
  
1 6/5/2016
  33
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
KVII Licensee, 
LLC/KVII-TV, 
Amarillo, TX 
 
0022490221 
 
40446
 
28
1/22/2016 
1/29/2016 
2/1/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
  
2
6/5/2016 
7/24/2016
WACH 
Licensee, 
LLC/WACH, 
Columbia, SC 
 
0022491450 
 
19199
 
12
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
4/1/2016 
4/8/2016
4/22/2016 
5/18/2016 
6/3/2016 
6/24/2016 
7/8/2016 
7/15/2016
 
 
  
1 6/5/2016
Chesapeake 
Television 
Licensee, 
LLC/WBFF, 
Baltimore, MD 
 
0004970679 
 
 
10758
 
 
5
2/4/2016 
2/13/2016 
4/1/2016 
4/22/2016 
6/10/2016
 
 
 
  
2
6/5/2016 
7/23/2016
 
WBMA 
Licensee, 
LLC/WBMA-
LD, 
Birmingham, 
AL 
 
0023870462 
 
60214
 
9
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
3/4/2016 
3/25/2016 
4/1/2016 
7/8/2016 
7/22/2016
 
 
  
1 6/5/2016
  34
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
 
WCHS 
Licensee, 
LLC/WCHS-
TV, 
Charleston, 
WV 
 
0002144434 
 
71280 28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/27/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/24/2016
 
WMMP 
Licensee 
L.P./WCIV, 
Charleston, SC 
 
0004970851 
 
 
9015 
 
 
28
1/15/2016 
1/22/2016 
1/28/2016 
1/29/2016 
2/4/2016 
2/8/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016
4/15/2016 
4/22/2016 
4/29/2016 
5/2/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/14/2016 
6/21/2016 
7/11/2016
 
 
  
2
6/5/2016 
7/24/2016
  35
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WEAR 
Licensee, 
LLC/WEAR-
TV, Pensacola, 
FL 0004970935 
 
71363
 
22
1/29/2016 
2/5/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
4/8/2016 
4/15/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
WFXL 
Licensee, 
LLC/WFXL, 
Albany, GA 0022490171 
 
70815
 
6
2/4/2016 
2/4/2166 
5/12/2016 
6/3/2106 
6/15/2016 
6/24/2016
 
 
   
                                                     
6 The on-air story apparently aired twice on 2/4/2016, during the 10:00 p m. hour.  Second Supplemental Response. 
  36
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WGME 
Licensee, 
LLC/WGME-
TV, Portland, 
ME 0004970950 
 
25683
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
  37
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WGXA 
Licensee, 
LLC/WGXA & 
WGXA-2, 
Macon, GA 0023568751 
 
58262 497
1/15/2016 
1/22/2016 
2/19/2016 
2/19/2016 
2/26/2016 
2/26/2016 
2/28/2016 
3/4/2016 
3/4/2016 
3/11/2016 
3/11/2016 
3/18/2106 
3/18/2016 
3/25/2016 
3/25/2016 
4/4/2016 
4/4/2016 
4/8/2016 
4/8/2016 
4/15/2016 
4/15/2016 
4/22/2016 
4/22/2016 
4/29/2016 
4/29/2016
5/6/2016 
5/6/2016 
5/13/2016 
5/13/2016 
5/20/2016 
5/20/2016 
5/27/2016 
5/27/2016 
6/3/2016 
6/3/2016 
6/10/2016 
6/10/2016 
6/17/2016 
6/17/2016 
6/24/2016 
6/24/2016 
7/1/2016 
7/1/2016 
7/8/2016 
7/8/2016 
7/15/2016 
7/15/2016 
7/22/2016 
7/22/2016  
2 6/5/2016 6/5/20168
 
 
                                                     
7 The on-air stories apparently aired on WGXA-2 on the following dates during the 6:00 a.m. hour:  2/19/2016; 2/26/2016; 3/4/2016; 3/11/2016; 3/18/2016; 
3/25/2016; 4/4/2016; 4/8/2016; 4/15/2016; 4/22/2016; 4/29/2016; 5/6/2016; 5/13/2016; 5/20/2016; 5/27/2016; 6/3/2016; 6/10/2016; 6/17/2016; 6/24/2016; 
7/1/2016; 7/8/2016; 7/15/2016; and 7/22/2016.  Second Supplemental Response. 
8 The long-form program apparently aired on 6/5/2016 on WGXA at 6:00 a m. and WGXA-2 at 5:30 a.m.  Id. 
  38
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WHP Licensee, 
LLC9/WHP-
TV, 
Harrisburg, PA 0021925789 
 
72313
 
27
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
 
  
1 6/5/2016
WICD 
Licensee, 
LLC/WICD, 
Champaign, IL 
 
0022116842 25684
 
 
 
  
1 6/5/2016
                                                     
9 On May 9, 2017, the Media Bureau granted a pro forma application for the assignment of WHP-TV’s license to Harrisburg Licensee, LLC, File No. BALCDT-
20170425AAV.  Broadcast Actions, Public Notice, Report No. 48984 (MB May 12, 2017), 2017 WL 2115643.  Sinclair subsequently consummated this license 
assignment on May 19, 2017.  Consummation Notice (May 23, 2017) (reporting the May 19, 2017 consummation of the pro forma assignment of license to 
Harrisburg Licensee, LLC), Federal Communications Commission, WHP-TV Application Search Details, Consummation Notice, https://licensing fcc.gov/cgi-
bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu hts?context=25&appn=101757567&formid=905&fac num=72313.  
  39
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WICS 
Licensee, 
LLC/WICS, 
Springfield, IL 0004970802 
 
25686
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
  40
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WJAC 
Licensee, 
LLC/WJAC-
TV, Johnstown, 
PA 0022463947 
 
73120
 
4610
1/28/2016 
1/28/2016 
2/5/2016 
2/5/2016 
2/12/2016 
2/12/2016 
2/19/2016 
2/19/2016 
2/26/2016 
2/26/2016 
3/4/2016 
3/4/2016 
3/11/2016 
3/11/2016 
3/18/2106 
3/18/2016 
3/25/2016 
3/25/2016 
4/1/2016 
4/1/2016 
4/8/2016 
4/8/2016 
4/15/2016
4/15/2016 
4/22/2016 
4/22/2016 
4/29/2016 
4/29/2016 
5/6/2016 
5/6/2016 
5/13/2016 
5/13/2016 
5/20/2016 
5/20/2016 
5/27/2016 
5/27/2016 
6/3/2016 
6/3/2016 
6/10/2016 
6/10/2016 
6/16/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016 1 6/5/2016
 
WJAR 
Licensee, 
LLC/WJAR, 
Providence, RI 0023893225 
 
50780
 
1 1/15/2016
 
 
  
1 6/5/2016
                                                     
10 The on-air stories apparently aired twice on the following dates, during the 5:00 a m. and 6:00 a m. hours:  1/28/2016; 2/5/2016; 2/12/2016; 2/19/2016; 
2/26/2016; 3/4/2016; 3/11/2016; 3/18/2016; 3/25/2016; 4/1/2016; 4/8/2016; 4/15/2016; 4/22/2016; 4/29/2016; 5/6/2016; 5/13/2016; 5/20/2016; 5/27/2016; 
6/3/2016; and 6/10/2016.  Second Supplemental Response.  
  41
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
ACC Licensee, 
LLC/WJLA-
TV, 
Washington, 
DC 0020222774 
 
1051 
 
16
1/15/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016
7/15/2016
 
  
1 6/12/2016
WKEF 
Licensee 
L.P./WKEF, 
Dayton, OH 0004970844 
 
73155 28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
  42
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WKRC 
Licensee, 
LLC/WKRC-
TV, Cincinnati, 
OH 0021925771 
 
11289
 
26
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/24/2016
WLOS 
Licensee, 
LLC/WLOS, 
Asheville, NC 0004676755 
 
56537 27
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/24/2016
  43
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WLUK 
Licensee, 
LLC/WLUK-
TV, Green 
Bay, WI 0023893233 
 
4150 
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
WNWO 
Licensee, 
LLC/WNWO-
TV, Toledo, 
OH 0022491864 
 
73354 27
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
2 
6/5/2016 
7/23/2016
  44
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WOAI 
Licensee, 
LLC/WOAI-
TV, San 
Antonio, TX 0021925763 
 
69618
 
4
2/12/2016 
3/18/2016 
4/15/2016
7/8/2016 
  
 
  
2
6/5/2016 
7/22/2016
WPBN 
Licensee, 
LLC/WPBN-
TV, Traverse 
City, MI 0022491765 
 
21253 26
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
WPDE 
Licensee, 
LLC/WPDE-
TV, Florence, 
SC 0022491583 
 
17012
 
2
1/15/2016 
3/4/2016
 
 
  
1 6/5/2016
  45
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WPEC 
Licensee, 
LLC/WPEC, 
West Palm 
Beach, FL 0021268073 
 
52527 24
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
7/15/2016 
7/22/2016
1 6/5/2016
 
WRGB 
Licensee, 
LLC/WRGB, 
Schenectady, 
NY 0021268289 
 
73942 7
1/16/2016 
2/4/2016 
2/13/2016 
2/14/2016 
2/17/2016 
2/19/2016 
2/26/2016
 
 
  
2
6/5/2016 
7/24/2016
WRLH 
Licensee, 
LLC/WRLH-
TV, Richmond, 
VA 0006551782 
 
412 
 
21
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/29/2016 
5/2/2016 
5/6/2016 
5/13/2016
5/20/2016 
5/27/2016 
6/3/2016 
6/17/2016 
6/24/2016 
6/28/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
 
  
1 6/5/2016
  46
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WSET 
Licensee, 
LLC/WSET-
TV, 
Lynchburg, VA 0023870470 
 
73988 26
1/15/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
  
2
6/5/2016 
7/23/2016
WSTQ 
Licensee, 
LLC/WSTM-
TV, Syracuse, 
NY 0022491633 
 
21252
 
6
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
3/4/2016
 
2 
6/5/2016 
7/24/2016
 
  47
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WSYX 
Licensee, 
Inc./WSYX, 
Columbus, OH 0002144608 
 
56549 24
1/22/2016 
1/29/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/22/2016
 
 
  
2
6/5/2016 
7/23/2016
WTOV 
Licensee, 
LLC/WTOV-
TV, 
Steubenville, 
OH 0022463913 
 
74122 28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
  48
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WTVC 
Licensee, 
LLC/WTVC, 
Chattanooga, 
TN 0021268313 
 
22590 28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
WWMT 
Licensee, 
LLC/WWMT, 
Kalamazoo, MI 0021268263 
 
74195 27
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
 
  
1 6/5/2016
  49
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION1 
 
FRN2 FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM PROGRAMS 
WITHOUT SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations
Broadcast Dates Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
WXLV 
Licensee, 
LLC/WXLV-
TV, Winston-
Salem, NC 0006551709 
 
414 21
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
  
1 6/5/2016
WZTV 
Licensee, 
LLC/WZTV, 
Nashville, TN 0006551758 
 
418 
 
28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
 
  
1 6/5/2016
TOTALS NA NA 1,357 9 71
 
 
 
 
 
 
  50
 Federal Communications Commission  FCC 17-171 
NON-SINCLAIR STATIONS (AGREEMENT STATIONS) 
 
LICENSEE/ 
STATION11 
 
FRN12  FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Apparent 
Violations 
Broadcast 
Dates 
 
Second Generation of 
Iowa, Ltd./KFXA, 
Cedar Rapids, IA13 0004294120 35336 28
1/15/2016 
1/22/2016 
1/29/2016 
2/5/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016
  6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
 7/1/2016 
 7/8/2016 
7/15/2016 
7/22/2016 
 
  
1
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6/5/2016
 
                                                     
11 Third Supplemental Response, Exh. 3. 
12 Id.   
13 The station also apparently broadcast additional on-air stories on 1/15/2016, 1/29/2016, 3/2/2016, 3/30/2016, 4/13/2016, 4/22/2016, 5/4/2016, 7/2/2016, 
7/9/2016, 7/16/2016, and 7/23/2016, and an additional long-form program on 7/23/2016.  Second Supplemental Response; Third Supplemental Response, Exh. 5.   
  51
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION11 
 
FRN12  FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Apparent 
Violations 
Broadcast 
Dates 
 
Waitt Broadcasting, 
Inc./KMEG, Sioux 
City, IA 0004957650 39665 27
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
    
KMTR Television, 
LLC/KMTR, Eugene, 
OR 0022745715 35189 28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
  
1 6/5/2016
  52
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION11 
 
FRN12  FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Apparent 
Violations 
Broadcast 
Dates 
 
Sierra 
Communications, 
LLC14/KRNV-DT, 
Reno, NV15 0018489757 60307 28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
  
1 6/5/2016
HSH Flint (WEYI) 
Licensee, 
LLC/WEYI-TV, 
Saginaw, MI16 0022522981 72052
 
 
  
1 6/5/2016
                                                     
14 On September 27, 2017, the Media Bureau granted an application for the assignment of KRNV-DT’s license to Reno (KRNV-TV) Licensee, Inc., File No. 
BALCDT-20131218CHO.  Broadcast Actions, Public Notice, Report No. 49079 (MB Sept. 27, 2017), 2017 WL 4342102. 
15 The station also apparently broadcast the long-form program on 7/24/2016. Third Supplemental Response, Exh. 5. 
16 The station also apparently broadcast the long-form program on 7/23/2016.  Id. 
  53
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION11 
 
FRN12  FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Apparent 
Violations 
Broadcast 
Dates 
 
New Age Media of 
Gainesville License, 
LLC/WGFL, High 
Springs, FL 0015435407 7727 20
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016 
4/29/2016 
5/6/2016
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/15/2016 
7/22/2016  
  
Deerfield Media 
(Rochester) Licensee, 
LLC/WHAM-TV, 
Rochester, NY 0022244495 73371 28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016
 
  
1 6/5/2016
  54
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION11 
 
FRN12  FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Apparent 
Violations 
Broadcast 
Dates 
 
Deerfield Media 
(Mobile) Licensee, 
LLC/WPMI-TV, 
Mobile, AL 0022238794 11906 13
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016
 
  
1 6/5/2016
Deerfield Media 
(Cincinnati) 
Licensee, 
LLC/WSTR-TV, 
Cincinnati, OH 0022238810 11204 16
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
3/18/2016 
3/25/2016 
4/8/2016
4/29/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
7/1/2016 
7/8/2016 
7/22/2016  
    
WVAH Licensee, 
LLC/WVAH-TV, 
Charleston, WV 0007283054 417 28
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/27/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
    
  55
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION11 
 
FRN12  FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Apparent 
Violations 
Broadcast 
Dates 
 
WRGT Licensee, 
LLC/WRGT-TV, 
Dayton, OH17 0007282114 411 27
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016
4/22/2016 
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/22/2016
 
  
1 6/5/2016
Columbus (WTTE-
TV) Licensee, 
Inc./WTTE, 
Columbus, OH18 0003778925 74137 26
1/22/2016 
1/29/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 
3/11/2016 
3/18/2016 
3/25/2016 
4/1/2016 
4/8/2016 
4/15/2016 
4/22/2016
4/29/2016 
5/6/2016 
5/13/2016 
5/20/2016 
5/27/2016 
6/3/2016 
6/10/2016 
6/17/2016 
6/24/2016 
7/1/2016 
7/8/2016 
7/15/2016 
7/22/2016  
  
1 6/5/2016
                                                     
17 The station also apparently aired the long-form program on 7/24/2016.  Third Supplemental Response, Exh. 5. 
18 The station also apparently aired the long-form program on 7/24/2016.  Id. 
  56
 Federal Communications Commission  FCC 17-171 
LICENSEE/ 
STATION11 
 
FRN12  FID # ON-AIR STORIES WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITHOUT 
SPONSORSHIP ID 
LONG-FORM 
PROGRAMS WITH 
INCOMPLETE 
SPONSORSHIP ID 
Apparent 
Violations 
Broadcast Dates Apparent 
Violations 
Broadcast 
Dates 
Apparent 
Violations 
Broadcast 
Dates 
 
WTVH License 
LLC/WTVH, 
Syracuse, NY 0006583298 74151 8
1/15/2016 
1/22/2016 
1/29/2016 
2/4/2016 
2/12/2016 
2/19/2016 
2/26/2016 
3/4/2016 1 6/5/2016
  
TOTALS NA NA 277   1   8   
 Federal Communications Commission FCC 17-171 
 57
STATEMENT OF 
CHAIRMAN AJIT PAI 
 
Re:     Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748. 
 
Today, the Federal Communications Commission proposes the largest forfeiture in the history of 
this agency for a violation of our sponsorship identification rules.  Indeed, the proposed forfeiture of over 
$13 million is more than three times any penalty that has ever been imposed for violating our sponsorship 
identification rules.  Among other things, because of the seriousness of these violations, we have taken 
the base forfeiture amount for each and every apparent violation of our rules at issue here and adjusted it 
upward.   
My dissenting colleagues, however, demanded that the Commission increase the amount of the 
proposed forfeiture here by over six times, to more than $82 million.  At no point, however, have they 
cited a single Commission precedent involving sponsorship identification—or any precedent from any 
other area for that matter—to justify their position.  And a brief review of the Commission’s two most 
recent sponsorship identification actions, both taken under the prior Administration, reveals how divorced 
their demand is from past practice.     
In 2016, the Enforcement Bureau and Cumulus entered into a consent decree to settle 178 
violations of the Commission’s sponsorship identification rules.  That consent decree involved a penalty 
of $540,000, or approximately $3,000 per violation.  And in 2014, the Enforcement Bureau and Journal 
Broadcast Corporation entered into a consent decree to settle 27 violations of the Commission’s 
sponsorship identification rules.  That consent decree involved a penalty of $115,000, or approximately 
$4,250 per violation.   
In this Notice of Apparent Liability, we are proposing a forfeiture of $13,376,200 for 1,723 
apparent violations of our sponsorship identification rules.  That works out to over $7,700 per violation—
a significantly higher penalty per violation than in recent cases but one that is appropriate given the 
factors spelled out in the Notice of Apparent Liability.  By contrast, my colleagues have sought to propose 
a forfeiture of $48,114 per violation, or 1,504% higher than the most recent penalty we’ve imposed.  
Their position deviates so wildly from our precedent that it will no doubt strike reasonable people as 
suspicious.  But I will leave it to others to speculate as to why they wish to punish this particular company 
in this particular way. 
 
 
 Federal Communications Commission FCC 17-171 
 58
DISSENTING STATEMENT OF 
COMMISSIONER MIGNON L. CLYBURN 
 
Re:     Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748. 
 
On first read, one might easily conclude that today’s enforcement action by the Republican-led 
FCC represents a strong stand against a company with a history of skirting FCC rules. But take a closer 
look: contrary to what the FCC majority would have you believe, the nearly $13.4 million fine levied 
against Sinclair Broadcast Group represents a mere slap on the wrist.  
Simply put, the ‘punishment does not fit the crime’ against a company that grossed more than 
$2.7 billion in revenue last year.  
What we are talking about is an egregious violation of the Commission’s rules by a company that 
knows better. Specifically, this Notice of Apparent Liability (NAL) finds that Sinclair violated the FCC’s 
sponsorship identification disclosure requirements more than 1,700 times – a well-known, well-
established rule intended to ensure viewers know the origin of the content they are viewing, including any 
paid sponsorships. What makes today’s action noteworthy is that the FCC is more than willing to propose 
fines in excess of $100 million against a single individual who may never pay. Yet when it comes to a 
multi-billion-dollar company that misleads millions of viewers, the majority levies a fine that is just one-
sixth of the statutory maximum and represents 0.5% of the company’s 2016 revenues. For context, we 
routinely fine companies between 3-8% of their gross revenues for egregious violations of our rules. Does 
this mark yet another example of special treatment by the FCC majority? You decide. 
We have seen violations of this nature before by this company. In 2007, Sinclair was fined 
$36,000 after it aired programming on nine stations without disclosing that the commentator had ties to 
the Department of Education’s No Child Left Behind program. And during the past decade and a half, 
Sinclair has been fined at least eight additional times, totaling almost $10 million for various violations, 
including of the Children’s Television Rules. In 2001 the company was fined $40,000 for illegally 
exercising control of its business partner Glencairn Ltd. Most recently, in 2016, the FCC reached a 
consent decree with Sinclair for nearly $9.5 million after it was found to have violated its obligation to 
negotiate in good faith when they engaged in prohibited joint retransmission consent negotiations. 
The facts in this case are clear: Sinclair willfully and repeatedly violated the Commission’s 
sponsorship identification rules. The NAL notes in fact, that “there are few, if any, actual disputes about 
the key facts associated with the apparent violations.” 
For all the above reasons, while I agree with the FCC acting against Sinclair for violating the 
FCC’s rules, I dissent because of such a meager fine, which fails to match the scope and egregious nature 
of the violations that were committed. 
 
 Federal Communications Commission FCC 17-171 
 59
STATEMENT OF 
COMMISSIONER MICHAEL O’RIELLY 
 
Re:     Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748. 
 
While I generally don’t comment on the Commission’s issuance of a Notice of Apparent Liability 
done via circulation, it seems appropriate and necessary to do so in this instance.   
With this item, the Commission proposes a forfeiture of more than $13 million for a violation of 
our sponsorship identification rules—the largest penalty the Commission has proposed for such a 
violation.  This figure was calculated by taking the base forfeiture amount for each apparent violation, and 
then upwardly adjusting it.  At this point in the process, this seems like stern but fitting action, as the 
Commission considered several factors and determined that they did not warrant downward adjustment, 
including the fact that it appears that the failure to disclose this information was unintentional, the content 
in question involved a cancer institute, some incomplete disclosures were provided, and Sinclair took 
corrective measures, including publicly acknowledging and apologizing for its failure to provide 
sponsorship identification through a five-week series of announcements in October 2016.   
Our action is consistent with how the Commission has assessed forfeitures for sponsorship 
identification violations in the past: by multiplying the base forfeiture by the number of violations and 
then adjusting the fine upward or downward based on the unique facts of the case.  In fact, this is 
precisely what the previous Commission did under similar circumstances.   
I look forward to reading any response from the affected party and reaching a conclusion in this 
enforcement matter.    
 Federal Communications Commission FCC 17-171 
 60
STATEMENT OF 
COMMISSIONER BRENDAN CARR 
 
Re:     Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748. 
 
The FCC’s sponsorship identification rules require every broadcaster that airs paid programming 
to include both an announcement that the broadcaster was paid to run the program and a statement that 
identifies the sponsor of the program.  These rules provide important consumer protections by ensuring 
that the public can distinguish paid programming from independently-generated content.  They also 
prevent companies from gaining a commercial advantage by purchasing sponsored content that is not 
identified as such.  Today, we advance these goals by proposing the largest fine in the history of the 
agency for a violation of our sponsorship identification rules. 
In this case, as in all matters, our obligation is to apply the law to the facts.  At this stage in our 
proceeding, the facts indicate that Sinclair failed to comply with our sponsorship identification rules when 
it aired paid programming regarding the Huntsman Cancer Institute.  While the base forfeiture in this case 
would have resulted in a proposed fine in excess of $6 million, I agree that the totality of the 
circumstances warrant a significant upward adjustment.  I therefore support the proposal to fine Sinclair 
over $13 million for these apparent violations.  Doing so is consistent with the law and the facts. 
 Federal Communications Commission FCC 17-171 
 61
DISSENTING STATEMENT OF 
COMMISSIONER JESSICA ROSENWORCEL 
 
Re:     Sinclair Broadcast Group, Inc., File No. EB-IHD-16-00021748. 
 
Take note of 1,723.  This is the extraordinary number of violations by Sinclair Broadcasting at 
issue in this enforcement action.  What this means is that over the course of roughly six months last year, 
Sinclair Broadcasting aired sponsored pay-for-play programming on 77 different stations 1,723 times.  
Some of this content was dressed up like real news but made no mention of who paid for it to be put on 
the air.  In an era where true facts too often are derided as fake news, this behavior is troubling.  
Moreover, it is a clear violation of Sections 317 and 507 of the Communications Act, as well as Section 
73.1212 of the Commission’s rules. 
The unprecedented volume of these violations deserves an unprecedented response.  But instead 
of seeking the maximum fine allowable under our rules, this notice cuts the company a break. In fact, the 
fine that is proposed amounts to only .5 percent of its revenue last year and only .3 percent of the value of 
the merger it currently has pending before this agency. 
Moreover, this is a company with a history of flouting statutory requirements under the 
Communications Act and Children’s Television Act.  These violations include a 2000 Forfeiture Order 
for Station WBFF, a 2001 Notice of Apparent Liability for Forfeiture for unauthorized transfer of control 
of several broadcast television stations, a 2007 Forfeiture Order for Station KOCB; a 2008 Forfeiture 
Order for Station WZTV, a 2009 Notice of Apparent Liability for Forfeiture for Station WUCW, a 2010 
Notice of Apparent Liability for Station WLOS, a 2010 Notice of Apparent Liability for Station KRRT-
TV, a 2010 Forfeiture Order for Station WVTV, and a 2014 Letter of Admonishment issued for Station 
KVCW.  Moreover, last year, Sinclair Broadcasting paid $9.49 million to settle investigations into the 
company’s retransmission negotiation practices and related issues, just days after they broke the rules 
they are being held accountable for today. 
In light of this substantial history of failure to comply with our policies and the sheer number of 
violations before the agency now, the immediate notice should seek the highest fines permissible under 
our rules.  But instead of doing so, we offer unreasonable and suspicious favor to a company with a clear 
record of difficulty complying with the law.  Because I think the fine here falls short of what is warranted, 
I respectfully dissent.