Federal Communications Commission	FCC 23-98


Before the
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554

In the Matter of

Matthew Bowen
Brooklyn, New York
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File No.: EB-FIELDNER-22-00034507 NAL/Acct No.: 202432010002
FRN: 0034392332


NOTICE OF APPARENT LIABILITY FOR FORFEITURE

Adopted:  November 15, 2023	Released:  November 16, 2023

By the Commission: Chairwoman Rosenworcel issuing a statement.

I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (NAL), we propose a penalty of $1,780,000 against Matthew Bowen (Bowen) for operating an unauthorized radio station on 99.9 MHz in Brooklyn, New York, by which he apparently willfully and knowingly did or caused pirate radio broadcasting during the period from November 21, 2022 to February 18, 2023, resulting in a minimum of 89 days of apparent violations.  Bowen appears to have engaged in the illicit operation of an unauthorized radio station known as “Triple9HD.”  Operating an unauthorized, or pirate, radio station is illegal under the Communications Act of 1934, as amended (Communications Act or Act). 47 U.S.C. § 511.
  Pirate radio stations undermine the Commission’s primary mission to manage radio spectrum.  Such illegal operations can interfere with licensed communications, including authorized broadcasts and communications by public safety entities.  Moreover, such illegal operations pose a danger to the public because they interfere with licensed stations that inform their listeners of important public safety messages, including Emergency Alert System transmissions that provide vital information regarding weather events and other dangers to the public. See Amendment of Part 11 of the Commission’s Rules Regarding the Emergency Alert System, Report and Order, PS Docket No. 15-94, FCC 22-75, para. 3 (rel. Sept. 30, 2022).
  Accordingly, Commission enforcement action in this area is essential.  
II. BACKGROUND
A. Legal Framework
2. On January 24, 2020, Congress passed the Preventing Illegal Radio Abuse Through Enforcement Act (PIRATE Act), which was subsequently codified as section 511 of the Communications Act. Preventing Illegal Radio Abuse Through Enforcement Act, Pub. L. 116-109, 134 Stat. 3 (2020) (codified at 47 U.S.C. § 511).
  Section 511 states that any person who willfully and knowingly does or causes or suffers to be done any pirate radio broadcasting shall be subject to a fine of not more than $2,000,000 and not more than $100,000 for each day during which such offense occurs. 47 U.S.C. § 511(a)-(b).  Prior to the passage of the PIRATE Act, the maximum monetary penalty for pirate radio transmissions was $151,005.  See 47 CFR §1.80(b)(9)(ii) (2019); see also Acerome Jean Charles, Notice of Apparent Liability for Forfeiture, 34 FCC Rcd 12744 (2019) (proposing a penalty of $151,005), consent decree adopted, Order 35 FCC Rcd 6878 (2020).  In 2020, that maximum limit was increased to $2,000,000.  See 47 U.S.C. § 511(a). 
  Both of these figures are subject to annual inflation adjustments. See 47 CFR § 1.80(b)(6) (setting the current inflation adjusted statutory maximum for a violation of 47 U.S.C. § 511(a) at $2,316,034 and 47 U.S.C. § 511(b) at $115,802); Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment of Civil Monetary Penalties to Reflect Inflation, Order, DA 22-1356, 2022 WL 18023008, at *5 (EB Dec. 23, 2022); see also Annual Adjustment of Civil Monetary Penalties to Reflect Inflation, 88 Fed. Reg. 783 (Jan. 5, 2023) (setting January 15, 2023, as the effective date for the increases).
  Section 511 defines pirate radio broadcasting as “the transmission of communications on spectrum frequencies between 535 and 1705 kilohertz, inclusive, or 87.7 and 108 megahertz, inclusive, without a license issued by the Federal Communications Commission (Commission), but does not include unlicensed operations in compliance with part 15 of title 47, Code of Federal Regulations.” 47 U.S.C. § 511(h).
  Part 15, among other requirements, states that unlicensed operators in the FM band must not transmit over a certain low-power limit. 47 CFR § 15.239(b) (stating that non-licensed broadcasting in the 88-108 MHz band is permitted only if the field strength of the transmission does not exceed 250 microvolts per meter at three meters).
  Moreover, under part 15, intentional radiators, such as FM transmitters, must be designed to ensure that no antenna other than that furnished by the responsible party shall be used with the device (e.g., a permanently attached antenna or an antenna that uses a unique coupling to the intentional radiator). Id. § 15.203.
  
3. The PIRATE Act, among other provisions, codified the definition of pirate radio, increased fines for pirate radio operators, and granted the Commission new enforcement authority to assess forfeitures against any person who permits the operation of pirate radio broadcasting, such as the property owners whose property is used for pirate radio broadcasting. See 47 U.S.C. § 511.
   
B. Factual Background
4. The Enforcement Bureau (Bureau) first became aware of Bowen’s pirate radio station (Station) on November 21, 2022.  On that date, and in response to complaints of interference with a licensed station in the area, field agents (Agents) from the Bureau’s New York Field Office traced the source of radio transmissions on 99.9 MHz to a multi-family dwelling located at 890 Rockaway Avenue in Brooklyn, New York (Rockaway Site).  The Agents took field strength measurements of the Station’s signal and determined that it exceeded the limits for operation under part 15 of the Commission’s rules. See 47 CFR § 15.239(b).  
  They also took photographs of the building and a broadcast antenna mounted on its roof and made an audio recording of the unlicensed broadcast, during which an announcer identified the Station as “Triple9HD.”  Commission records indicated no authorization for any FM broadcast station to operate at or near the Rockaway Site on any frequency.  
5. Returning to the Rockaway Site on December 13, 2022, the Agents observed the same rooftop broadcast antenna first seen on November 21, 2022.  During their building inspection the next day (December 14, 2022), the Agents took close-up photographs of the broadcast antenna and determined that it used a standard coaxial connector and was not compliant with the part 15 rules. Id. § 15.203 (“[T]he use of a standard antenna jack or electrical connector is prohibited.”).  
  The Agents advised the building owner and his representative that the broadcasting activity was illegal and should be halted immediately. 
6. On February 18, 2023, Agents conducted a follow-up investigation and again detected broadcast activity on 99.9 MHz from a station identifying itself as “Triple9HD.”  Utilizing direction-finding techniques, the agents traced the source of the transmissions to the Rockaway Site.  The Agents took additional photographs of the antenna used to broadcast the signal and determined that it was the same part 15 non-compliant antenna used to broadcast the signal since November 21, 2022. See id.
  After confirming the Rockaway Site as the origin of the Triple9HD signal, the Agents measured the Station’s signal strength and determined that it was in excess of part 15 limits.  Commission records reflect no authorization for any FM broadcast station to operate at or near the Rockaway Site on any frequency.         
7. Through an online search, which included social media platforms, Agents discovered the Triple9HD website, which features a distinctive logo with “999FM Triple9HD” and palm trees in the background (Station Logo). See Triple9HD Radio website, https://streamdb5web.securenetsystems.net/cirrusencore/triple9 (last visited May 24, 2023) (on file in EB-FIELDNER-22-00034507).
  Agents also discovered the Station’s Facebook page, which includes the Station Logo and states: “99.9FM/Triple9Radio known as a family station is the #1 Caribbean station in New York, Tri-State & Wor[ld.].” See Triple9HD, Facebook, https://www.facebook.com/Triple9hd (last visited May 24, 2023) (on file in EB-FIELDNER-22-00034507).
  
8. The Station’s Instagram account also included the Station Logo and advertised regularly scheduled radio programming being broadcast on 99.9 MHz each day of the week: (1) “Tiki Fever Show” is broadcast on Sundays, Tuesdays, and Wednesdays; See Triple9HD, Instagram, https://www.instagram.com/p/CbqdWfRvXs0/ (last visited July 26, 2023) (on file in EB-FIELDNER-22-00034507).
 (2) “Chinee Golden Touch Sound” is broadcast on Mondays, Wednesdays, and Saturdays; See Triple9HD, Instagram, https://www.instagram.com/p/B8PXIPXAgF4/ (last visited July 26, 2023) (on file in EB-FIELDNER-22-00034507).
 (3) “Selecta Boobie and Kumi” is broadcast on Saturdays; See Triple9HD, Instagram, https://www.instagram.com/p/B-A6iSrAhic/ (last visited July 26, 2023) (on file in EB-FIELDNER-22-00034507).
 (4) “The Vibes Unit” is broadcast on Fridays and Saturdays; See Triple9HD, Instagram, https://www.instagram.com/p/B8dDDDEAHJK/ (last visited July 26, 2023) (on file in EB-FIELDNER-22-00034507).
 (5) “Dred Solo” is broadcast on Wednesdays; See Triple9HD, Instagram, https://www.instagram.com/p/B8wsBGjAt0x/ (last visited July 26, 2023) (on file in EB-FIELDNER-22-00034507).
 and (6) “DJ X Rated” is broadcast on Mondays, Wednesdays, and Thursdays. See Triple9HD, Instagram, https://www.instagram.com/p/B8e18v2hUiM/ (last visited July 26, 2023) (on file in EB-FIELDNER-22-00034507).
  This program advertising continued for at least the twelve-plus weeks between the observations on November 21, 2022 (a Sunday) and February 18, 2023 (a Saturday); this period of advertised Station operation totaled eighty-nine (89) days. 
9. Further investigation uncovered more information regarding a regular program host on the Station with the alias “Chinee Goldentouch” (Goldentouch), who appears to be the principal “face” and most prominent and prodigious broadcaster on the Station.  He is featured on the Station’s Facebook page, which includes 31 videos of his shows—almost 100 hours’ worth—posted during a three-month period from November 2022 through January 2023, See Triple9HD, Facebook, https://www.facebook.com/Triple9hd/videos (last visited May 24, 2023) (on file in EB-FIELDNER-22-00034507). Seventeen hours of those videos prominently display the Triple9HD 99.9 FM logo.
 Goldentouch is the only operator of the Station with any videos posted on Triple9HD’s Facebook page in the last four years. See id.

10. Using the telephone number provided by Goldentouch in his videos and social media, Agents were able to identify him as Matthew Bowen.  Bowen maintains several different social media accounts under his Goldentouch alias, and videos of him on those accounts confirm that it is the same person shown broadcasting on-air on Triple9HD. See https://linktr.ee/Chineegoldentouch (last visited June 22, 2023), which provides a list of links to Bowen’s accounts, including Facebook Fan Page (https://www.facebook.com/chineepublicfigure/videos/1726320977764053/,     Instagram (https://www.instagram.com/chineegoldentouch/), Twitch (https://www.twitch.tv/chineegoldentouch), YouTube (https://www.youtube.com/channel/UCb8WJ2UcUwm-azb0OtwSk2Q), and Twitter (https://twitter.com/GoldenTouchsnds).

III. DISCUSSION
11. We find that Bowen apparently willfully and knowingly violated section 511 of the Act 47 U.S.C. § 511.
 by operating a pirate radio station on 99.9 MHz from November 21, 2022 to February 18, 2023.  On both of those dates, Agents observed Bowen’s Station, Triple9HD, operating at the Rockaway Site on 99.9 MHz.  Agents performed field strength measurements and determined that these transmissions exceeded the limits for operation under part 15 of the Commission’s rules.  Based upon the evidence gathered, Bowen appears to have a close connection to the Station; he is the Station’s principal “face” and its most prominent and prodigious host. See supra para. 9.  
  In addition, Bowen advertised on social media that Triple9HD programming was being broadcast on 99.9 MHz each day of the week during the more than twelve weeks between November 21, 2022, and February 18, 2023, totaling at least eighty-seven (87) additional apparent violations. See supra para. 8.
  Agents determined that the antenna used to broadcast Triple9HD from the Rockaway Site during this more than twelve-week period was not compliant with the part 15 requirements. See 47 CFR § 15.203; see also supra para. 1.
  Therefore, all transmissions from the Rockaway Site during this more than twelve-week period failed to comply with part 15 of the Commission’s rules. See 47 CFR § 15.203; see also 47 U.S.C. § 511(h) (stating that pirate radio broadcasting “does not include unlicensed operations in compliance with part 15 of title 47, Code of Federal Regulations”).
  Commission records indicate no authorization for any FM broadcast station to operate at or near the Rockaway Site at any time relevant to the apparent violations discussed in this NAL.  
12. Considering the totality of the circumstances and facts before us, including the two separate observed violations, the advertised weekly programming demonstrating dozens of additional apparent violations, the part 15 non-compliant antenna used to broadcast the Triple9HD signal, and Bowen’s prominent connection to Triple9HD’s operations, we find that Bowen operated a pirate radio station and apparently willfully and knowingly did or caused pirate radio broadcasting during the period from November 21, 2022 to February 18, 2023, resulting in a minimum of 89 days of apparent violations.  Accordingly, the Commission finds that Bowen’s actions constituted pirate radio broadcasting in apparent violation of section 511 of the Act. 47 U.S.C. § 511(a), (h).
  
A. Proposed Forfeiture
13. Section 511 of the Act authorizes the Commission to impose a forfeiture against any person “who willfully and knowingly does or causes or suffers to be done any pirate radio broadcasting.” Id. § 511(a).
  In exercising our forfeiture authority, we consider the “nature, circumstances, extent and gravity of the violations and, with respect to the violator, the degree of culpability, any history of prior offenses, ability to pay, and such other matters as justice may require.” Call Identification Trust Anchor, 18 Fed Reg 40096, 40116 (June 21, 2023) (amending 47 CFR § 1.80 by redesignating paragraphs (b)(9) through (11) as paragraphs (b)(10) through (12)) (to be codified at 47 CFR § 1.80 (b)(11)).
  We may adjust a forfeiture downward for minor violations, good faith or voluntary disclosure, a history of overall compliance, or an inability to pay. Id.

14. Section 511 of the Act and section 1.80 of the Commission’s rules authorize enhanced penalties for pirate radio broadcasting. 47 U.S.C. § 511; 47 CFR § 1.80(b)(6).
  Under these sections, any person who willfully and knowingly does or causes or suffers to be done any pirate radio broadcasting shall be subject to a fine of not more than $115,802 for each day during which the offense occurs, but not more than $2,316,034 in total. 47 U.S.C. § 511(a)-(b); see 47 CFR § 1.80(b)(6) (setting the current inflation adjusted statutory maximum for a violation of 47 U.S.C. § 511(a) at $2,316,034 and 47 U.S.C. § 511(b) at $115,802); Amendment of Section 1.80(b) of the Commission's Rules, Adjustment of Civil Monetary Penalties to Reflect Inflation, supra note 5, at *5 (EB Dec. 23, 2022); see also Annual Adjustment of Civil Monetary Penalties to Reflect Inflation, supra note 5, at 783 (Jan. 5, 2023) (setting January 15, 2023, as the effective date for the increases).
     
15. The primary intent of the PIRATE Act is to increase financial penalties for pirate radio broadcasting. See S. Rep. No. 116-178, 1 (2019) (“The purpose of S. 1228, the Preventing Illegal Radio Abuse Through Enforcement Act or PIRATE Act, is to increase the financial penalties for pirate radio broadcasting.”).
  Accordingly, as explained in two recent notices of apparent liability for forfeiture under the PIRATE Act, we impose a base forfeiture of $20,000 The Commission first used this base forfeiture amount in two prior Notices of Apparent Liability for Forfeiture. See César Ayora and Luis Angel Ayora, Queens, New York, Notice of Apparent Liability for Forfeiture 2023 WL 2560017, at *5 (Mar. 15, 2023); Thomas Barnes, La Grande, Oregon, Notice of Apparent Liability for Forfeiture 2023 WL 2560016, at *4 (Mar. 15, 2023).
 for each of the eighty-nine (89) days that Bowen apparently willfully and knowingly violated section 511 of the Act, for a total proposed base forfeiture of $1,780,000. See 47 U.S.C. § 511.
 
16. We further find no applicable factors that would dictate an upward or downward adjustment of the base forfeiture amount.  After applying section 1.80 of the Commission’s rules and the statutory factors, and consistent with the Forfeiture Policy Statement, See The Commission's Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087, 17101, para. 27 (1997) (Forfeiture Policy Statement), recons. denied, Memorandum Opinion and Order, 15 FCC Rcd 303 (1999); 47 CFR § 1.80(b)(11).
 Bowen is apparently liable for a proposed total monetary forfeiture of $1,780,000. Any entity that is a “Small Business Concern” as defined in the Small Business Act (Pub. L. 85-536, as amended) may avail itself of rights set forth in that Act, including rights set forth in 15 U.S.C. § 657, “Oversight of Regulatory Enforcement,” in addition to other rights set forth herein.
  
IV. CONCLUSION
17. We have determined that Matthew Bowen apparently willfully and knowingly did or caused pirate radio broadcasting in violation of section 511 of the Act.  As such, Matthew Bowen is apparently liable for a forfeiture of $1,780,000. 
V. ORDERING CLAUSES
18. Accordingly, IT IS ORDERED that, pursuant to section 511 of the Communications Act of 1934, as amended, 47 U.S.C. § 511, and section 1.80 of the Commission’s rules, 47 CFR § 1.80, Matthew Bowen is hereby NOTIFIED of this APPARENT LIABILITY FOR A FORFEITURE in the amount of one million seven hundred eighty thousand dollars ($1,780,000) for willful and knowing violations of section 511 of the Act. 47 U.S.C. § 511.
 
19. IT IS FURTHER ORDERED that, pursuant to section 1.80 of the Commission’s rules, 47 CFR § 1.80, within thirty (30) calendar days of the release date of this Notice of Apparent Liability for Forfeiture, Matthew Bowen 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 23.
20. In order for Matthew Bowen to pay the proposed forfeiture, he shall notify the Office of the Field Director at field@fcc.gov of his intent to pay, whereupon an invoice will be posted in the Commission’s Registration System (CORES) at https://apps.fcc.gov/cores/userLogin.do.  Upon payment, Bowen shall send electronic notification of payment to the Office of the Field Director, Enforcement Bureau, Federal Communications Commission, at field@fcc.gov on the date said payment is made.  Payment of the forfeiture must be made by credit card using CORES at https://apps.fcc.gov/cores/‌userLogin.do, ACH (Automated Clearing House) debit from a bank account, or by wire transfer from a bank account.  The Commission no longer accepts Civil Penalty payments by check or money order.  Below are instructions that payors should follow based on the form of payment selected: For questions regarding payment procedures, please contact the Financial Operations Group Help Desk by phone at 1-877-480-3201 (option #1).

· Payment by wire transfer must be made to ABA Number 021030004, receiving bank TREAS/NYC, and Account Number 27000001.  In the OBI field, enter the FRN(s) captioned above and the letters “FORF”.  In addition, a completed Form 159 FCC Form 159 is accessible at https://www.fcc.gov/licensing-databases/fees/fcc-remittance-advice-form-159.
 or printed CORES form Information completed using the Commission’s Registration System (CORES) does not require the submission of an FCC Form 159.  CORES is accessible at https://apps.fcc.gov/cores/userLogin.do.
 must be faxed to the Federal Communications Commission at 202-418-2843 or e-mailed to RROGWireFaxes@fcc.gov on the same business day the wire transfer is initiated.  Failure to provide all required information in Form 159 or CORES may result in payment not being recognized as having been received.  When completing FCC Form 159 or CORES, enter the Account Number in block number 23A (call sign/other ID), enter the letters “FORF” in block number 24A (payment type code), and enter in block number 11 the FRN(s) captioned above (Payor FRN). Instructions for completing the form may be obtained at http://www.fcc.gov/Forms/Form159/159.pdf. 
  For additional detail and wire transfer instructions, go to https://www.fcc.gov/‌licensing-databases/fees/wire-transfer.
· Payment by credit card must be made by using CORES at https://apps.fcc.gov/cores/‌userLogin.do.  To pay by credit card, log-in using the FCC Username associated to the FRN captioned above.  If payment must be split across FRNs, complete this process for each FRN.  Next, select “Manage Existing FRNs | FRN Financial | Bills & Fees” from the CORES Menu, then select FRN Financial and the view/make payments option next to the FRN.  Select the “Open Bills” tab and find the bill number associated with the NAL Acct. No.  The bill number is the NAL Acct. No. with the first two digits excluded (e.g., NAL 1912345678 would be associated with FCC Bill Number 12345678).  After selecting the bill for payment, choose the “Pay by Credit Card” option.  Please note that there is a $24,999.99 limit on credit card transactions.
· Payment by ACH must be made by using CORES at https://apps.fcc.gov/cores/userLogin.do.  To pay by ACH, log in using the FCC Username associated to the FRN captioned above.  If payment must be split across FRNs, complete this process for each FRN.  Next, select “Manage Existing FRNs | FRN Financial | Bills & Fees” on the CORES Menu, then select FRN Financial and the view/make payments option next to the FRN. Select the “Open Bills” tab and find the bill number associated with the NAL Acct. No.  The bill number is the NAL Acct. No. with the first two digits excluded (e.g., NAL 1912345678 would be associated with FCC Bill Number 12345678).  Finally, choose the “Pay from Bank Account” option.  Please contact the appropriate financial institution to confirm the correct Routing Number and the correct account number from which payment will be made and verify with that financial institution that the designated account has authorization to accept ACH transactions.
21. Any request for making full payment over time under an installment plan should be sent to:  Chief Financial Officer—Financial Operations, Federal Communications Commission, 45 L Street, N.E., Washington, D.C. 20554. See 47 CFR § 1.1914.
  Questions regarding payment procedures should be directed to the Financial Operations Group Help Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
22. 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 sections 1.16 and 1.80(f)(3) of the Commission’s rules. Id. §§ 1.16, 1.80(f)(3).
  The written statement must be mailed to the Office of the Secretary, Federal Communications Commission, 45 L Street, N.E., Washington, D.C. 20554, ATTN:  Enforcement Bureau – Office of the Field Director, and must include the NAL/Account Number referenced in the caption.  The statement must also be e-mailed to the Office of the Field Director at field@fcc.gov. 
23. The Commission will not consider reducing or canceling a forfeiture in response to a claim of inability to pay unless the petitioner submits the following documentation:  (1) federal tax returns for the past three years; (2) financial statements for the past three years 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.  Inability to pay, however, is only one of several factors that the Commission will consider in determining the appropriate forfeiture, and we retain the discretion to decline reducing or canceling the forfeiture if other prongs of 47 CFR § 1.80(b)(10) support that result.
24. 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 Matthew Bowen at 9915 Seaview Ave., Apt. 3C, Brooklyn, New York 11236-5530. 

						FEDERAL COMMUNICATIONS COMMISSION




						Marlene H. Dortch 
Secretary
2
STATEMENT OF
CHAIRWOMAN JESSICA ROSENWORCEL

Re:	In the Matter of Matthew Bowen, Brooklyn, New York, Notice of Apparent Liability for Forfeiture, File No.: EB-FIELDNER-22-00034507 (November 15, 2023)

	At the Federal Communications Commission we are stewards of the public airwaves.  To ensure that this essential resource is broadly available, we have rules that govern its use.  And for those who fail to follow the rules, there are consequences.  

	In the PIRATE Act, Congress upped the ante.  It increased the penalties for those who transmit unauthorized signals over the FM and AM radio bands because they can compromise public trust in this service and jeopardize the broadcasting of emergency alerts.  This means higher fines and more regular enforcement sweeps in our largest radio markets.  

Here we propose fines against three unauthorized radio operators in New York that are the direct result of an enforcement sweep taken pursuant to this new law.  They add up to more than $6,412,000 in penalties.  They also demonstrate that the agency’s field agents are taking their broadcast enforcement duties under the PIRATE Act and that we are taking our responsibility as stewards of the public airwaves seriously.  

	I want to thank Representative Velazquez, Representative Rice, Representative Bilirakis, Senator Peters, and Senator Daines for their work on the PIRATE Act.  I also want to thank the Field Regional Management and Agents of our New York Field Office for their work on these investigations.  In addition, I want to share my appreciation for other staff at the agency responsible for these actions, including Reggie Breshears, Loyaan Egal, Robert Keller, Jeremy Marcus, David Marks, Ryan McDonald, and Michael Rhodes from the Enforcement Bureau; and William Dever and David Konczal from the Office of General Counsel.