Federal Communications Commission FCC 17-171
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.