IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF IOWA
WESTERN DIVISION
RIVERFRONT BROADCASTING, LLC, a South Dakota Limited Liability Company, and Case No. 15-cv-4042-MWB
RIVERFRONT BROADCASTING OF IOWA, LLC, a South Dakota Limited Liability Company, COMPLAINT Plaintiffs, vs.
MAIN STREET BROADCASTING, INC, a Minnesota Corporation, d/b/a KORN COUNTRY 92.1, and
Lynn Kettelson, an individual,
Defendants.
The Plaintiffs, Riverfront Broadcasting, LLC, ("Riverfront Broadcasting"), and Riverfront Broadcasting of Iowa, LLC ("Riverfront of Iowa")( collectively "Riverfront"), for their Complaint against the Defendant, Main Street Broadcasting, Inc., d/b/a KORN Country 92.1, state as follows:
THE PARTIES
1. Riverfront Broadcasting and Riverfront of Iowa are corporations organized and exiting under the laws of South Dakota, with their principal place of business yankton, South Dakota. Riverfront collectively owns a number of regional radio stations in South Dakota and Iowa, including KORN News Radio 1490, located in Mitchell, South Dakota. (See Exhibit A.)
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Riverfront's other stations are KCCR-AM 1240, Pierre, South Dakota; KDAM-FM 94.3,
Yankton, South Dakota; KKYA-FM, 93.1, Yankton, South Dakota; KLXS-FM 95.3, Pierre,
South Dakota; KYNT-AM 1450, Yankton, South Dakota; KQRN-FM 107.3, Mitchell, South
Dakota; KHBT-FM 97.7, Humboldt, Iowa; KWBG-AM 1590, Boone, Iowa; KQWC-AM 1570,
Webster City, Iowa; KQWC-FM 95.7, Webster City, Iowa; KLGA-FM 92.7, Algona, Iowa; and
KLGZ-AM 1600, Algona, Iowa.
2. KORN Country 92.1 is, upon information and belief, a "d/b/a" designation employed by Main Street Broadcasting, Inc., (hereinafter "KORN Country 92.1 "), a corporation organized and existing under the laws of Minnesota, with its principal place of business in
Owatonna, Minnesota. KORN Country 92.1 is a radio station, but its true call sign, issued by the Federal Communications Commission ("FCC"), is KKOR, not KORN. (See Exhibit B.)
3. Lynn Kettelson is a resident of Minnesota, an equity owner in Main Street, and a personal and individual actor as further alleged below.
JURISDICTION AND VENUE
4. This Court has jurisdiction over KORN Country 92.1 and Kettelson, because
KORN Country 92.1 and Kettelson have had and continue to have systematic and continuous contact with the State of Iowa, and have regularly done business and continue to regularly do business in this District. Specifically, according to documents attached hereto as Exhibit C,
KORN Country 92.1 's broadcast territory extends well into the Northern District oflowa; and
Kettelson's individual actions alleged below have been on behalf ofKORN Country 92.1.
5. This Court further has jurisdiction over KORN Country 92.1 and Kettelson in that a substantial part of their acts giving rise to this action occurred in Iowa.
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6. Venue is proper in this district and that a substantial part ofKORN Country's and
Kettelson's acts giving rise to this action occurred in this district and KORN Country 92.1 is
deemed to reside in this district under 28 U.S.C. § 1391(b)(c).
7. This is a civil action for trademark infringement and dilution in interstate
commerce, arising under the laws of United States, in particular, the Lanham Act. This Court
has jurisdiction over these claims under 28 U.S.C. §§ 1331 and 1338(a).
8. This is also a civil action for unfair competition in violation of Riverfront's state
and common law trademark rights joined with substantial and related claims under the Lanham
Act. This Court has jurisdiction over these claims under 28 U.S.C. § 1338(b).
COMMON FACTS
9. Riverfront and its predecessors in interest have used the service mark and call-
sign "KORN" as well as the designation "KORN Radio" in advertising and otherwise
promoting its radio and radio advertising services, including its radio station broadcasting from
Mitchell, South Dakota, news radio 1490 KORN AM.
10. In 1950, after the call letters "KORN" were surrendered by another station in
Freemont, Nebraska, Riverfront's predecessors in interest obtained the call sign "KORN," and
these call letters and license to use them were assigned to Riverfront's predecessors by the FCC.
11. Riverfront and its predecessors have since continuously used the KORN call
letters via FCC license.
12. Riverfront purchased KORN AM 1490 and the rights to use in commerce of the
KORN call letters in February 2008.
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13. KORN broadcasts locally throughout southeast South Dakota and over the
internet.
14. KORN has become a very popular station in the Upper Midwest. For instance, in
May 2006 KORN received awards in the commercial radio division of the South Dakota
Associated Press Broadcaster's Association news contest. In 2015, KORN Radio's sports
director, Steve Morgan, received the South Dakota High School Coaches Association
Sportscaster of the Year Award. In 2015, KORN News Radio morning-show host Clayton
Mick received a 1st Place award in the talk/public affairs category from the Midwest Broadcast
Journalists' Association.
15. The designations "KORN" and "KORN Radio" have further become uniquely
identified with this particular radio station for decades. For example, in the 1970's, the popular television show "Hee-Haw" introduced a segment called "KORN Radio," a spoof of
Midwestern radio content. KORN Radio 1490 in Mitchell was so well known that the
producers of"Hee-Haw" contacted Riverfront's predecessors to obtain permission to use that
call sign and designation during these episodes of"Hee-Haw." The producers ofthe "Hee-
Haw" program also flew the then-general manager ofKORN Radio 1490 to the set of the show to appear on an episode of the program.
16. Riverfront and its predecessors have used the designations "KORN" and "KORN
Radio" as a service mark continuously in commerce for the purposes of identifying their services and distinguishing them from other radio broadcasters with great commercial success and consumer recognition since at least as early as 1950. The "KORN" and "KORN Radio"
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designations have become famous, distinctive, and widely known as identifying the high-quality
services provided by Riverfront and its predecessors.
17. Riverfront promotes the fact that it owns multiple stations, including KORN AM
1490, and Riverfront's consumers and listeners are aware of this fact.
18. KORN Country 92.1, like Riverfront, provides radio broadcasting services in the .
Upper Midwest, particularly in southern Minnesota and northern Iowa, and also broadcasts over
the internet.
19. KORN Country 92.1 's broadcast territory overlaps with at least one of
Riverfront's radio station's broadcast territory. (C.f Exhibit C with Exhibit D.)
20. KORN Country 92.1 has a call sign assigned by the FCC, but it is not "KORN."
Its designated call sign is KKOR. (See Exhibit B.)
21. KORN Country 92.1 is aware ofRiverfront Broadcasting, ofRiverfront's use of
the "KORN" call sign, and of Riverfront's rights in the designations "KORN" and "KORN
Radio." In fact, Lynn Kettelson previously approached Riverfront and expressed interest in
purchasing the call sign "KORN" for use on an FM station, but Riverfront declined because it
wanted to retain the ability to use the "KORN" and "KORN Radio" marks in conjunction with
an FM station.
22. Nevertheless, Kettelson's entity, KORN Country 92.1 is now using Riverfront's
"KORN" call sign, and the confusingly-similar designation "KORN Country" on its regular and
internet broadcasts, and in conjunction with promotion of its radio services, including on
billboards, at public events, on vehicles, on web pages, and other public forums and internet
sources, such as on its Facebook page, on its Twitter account, on Pintrest, and in conjunction
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with two smart phone apps (one for Apple iPhone users, and one for Android-compatible
devices) that smartphone users may download to livestream KORN Country 92.1 's broadcast.
(Exhibit E.)
23. Indeed, even though KORN Country 92.1 is not really "KORN" but instead has
the call sign "KKOR," KORN Country 92.1 regularly uses the "KORN" designation as a call
sign, spelling the name out "K-0-R-N Country 92.1" during broadcasts.
24. Additional examples ofKORN Country 92.1 's use and marketing of the "KORN"
and "KORN Country" designations are prominently displayed at its website,
www.KORN92.com. (Exhibit E.)
25. KORN Country 92.1 'sand Kettelson's use of Riverfront's marks includes but is
not limited to, Kettelson's registration of the domain name www.KORN92.com (the "pirated
domain"). Documents from an on-line WHOIS search evidencing Kettelson's personal
registration ofthe pirated domain for KORN Country 92.1 are attached hereto and incorporated
herein as Exhibit F.
26. Riverfront has sent two cease and desist letters to KORN Country 92.1 and
Kettelson, demanding that they cease their infringing conduct. Not only have KORN Country
92.1 and Kettelson continued their infringing conduct, but neither KORN Country 92.1 nor
Kettelson have even responded to the cease and desist letters.
COUNT I FALSE DESIGNATION UNDER 15 U.S.C. § 1125(a) (THE LANHAM ACT)
27. Riverfront restates all previous allegations and incorporates them by reference.
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28. KORN Country 92.1 'sand Kettelson's use of the designations "KORN" and
"KORN Country" both on the pirated domain and in on-air and other advertising, including on
billboards, vehicles, print advertising, Facebook, Twitter and other media constitutes use in
commerce of a word, term, name, symbol, or device, and further constitutes a false designation
of origin, and false or misleading description or misrepresentation of fact.
29. KORN Country 92.1 'sand Kettelson's use ofthe designations "KORN" and
"KORN Country" are intended to and are likely to cause confusion or to cause mistake or to
deceive as to the affiliation, connection, or association of KORN Country 92.1 with Riverfront
as to the origin, sponsorship, or approval ofKORN Country 92.1 's services.
30. In fact, KORN Country 92.1 'sand Kettelson's use of the designations "KORN"
and "KORN Country" has caused actual confusion among potential listeners. Some of
Riverfront's listeners, familiar with Riverfront's KORN-AM 1490 station in Mitchell, and
familiar with the fact that Riverfront owns multiple radio stations in South Dakota and Iowa,
have heard KORN Country 92.1 's use ofthe "KORN" and "KORN Country" designations
during its broadcasts while traveling through KORN Country 92.1 's broadcast territory, and
have communicated to Riverfront that they thought KORN Country 92.1 was affiliated with
Riverfront.
31. KORN Country 92.1 'sand Kettelson's use of the "KORN" and "KORN Country"
designations is causing irreparable harm to Riverfront's business and goodwill, as well as the
consuming public, and will continue to cause such irreparable harm absent injunctive relief. For
example, as the owner of the call letters "KORN," Riverfront could use that call sign on any of
its FM stations, including Riverfront's Algona, Iowa, FM station (located in Kossuth County,
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Iowa, the U.S. county that leads the nation in com production), but is limited in its ability to do
so because Riverfront's Algona, Iowa station and KORN Country 92.1 have overlapping
broadcast territories.
32. KORN Country 92.1 'sand Kettelson's wrongful use of these designations has
caused damages in terms of lost profits, diversions of sales, diversion of listeners, and loss of
goodwill.
33. KORN Country 92.1 'sand Kettelson's wrongful use of these designations has
also resulted in benefits wrongly inuring to KORN 92.1 that would not have been realized but
for its unlawful i11fringement.
34. KORN Country 92.1 'sand Kettelson's wrongful use of these designations is
willful, and has been in bad faith, making this an exceptional case as defined by the Lanham
Act. Riverfront is entitled to attorney fees and multiple damages.
COUNT II DILUTION UNDER 15 U.S.C. § 1125(c) (THE LANHAM ACT)
35. Riverfront restates all previous allegations and incorporates them herein by
reference.
36. Riverfront's "KORN" and "KORN Radio" designations are famous and
distinctive, and have long been associated specifically with Riverfront's and its predecessors-in-
interests' radio station in Mitchell, South Dakota, as evidenced by the facts discussed above,
including, but not limited to, a famous nationally-syndicated television show asking Riverfront's
predecessors-in-interest for permission to use the "KORN" and "KORN Radio" designations in
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"KORN" and "KORN Radio" designations to Kettelson and/or KORN Country 92.1.
37. Riverfront and its predecessors have used the "KORN" and "KORN Radio" designations in commerce since at least as early 1950.
38. KORN Country 92.1 'sand Kettelson's use of the "KORN" and "KORN Country" designations commenced long after Riverfront's and its predecessors' designations became famous.
39. KORN Country 92.1 'sand Kettelson's improper use of the "KORN" and "KORN
Country" designations is likely to cause association arising from the similarity between KORN
Country 92.1 's designations and Riverfront's "KORN" and "KORN Radio" designations, which will impair the distinctiveness of Riverfront's mark.
40. KORN Country 92.1 'sand Kettelson's use of the "KORN" and "KORN Country" designations is causing irreparable harm to Riverfront's business and goodwill, as well as the consuming public, and will continue to cause such irreparable harm absent injunctive relief.
41. KORN Country 92.1 's and Kettelson' s wrongful use of these designations is willful, and has been in bad faith, making this an exceptional case as defined by the Lanham Act.
Riverfront is entitled to attorney fees and multiple damages.
COUNT III CYBERSQUATTING UNDER 15 U.S.C. § 1125(d) (ANTI-CYBERSQUATTING AND CONSUMER PROTECTION ACT)
42. Riverfront restates all previous allegations and incorporates them by reference.
43. Riverfront's designations "KORN" and "KORN Radio" were famous and/or distinctive at the time that Kettelson registered the domain www.KORN92.com.
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44. The pirated domain is identical, dilutive, and/or confusingly similar to
Riverfront's designations, in that the pirated domain wholly incorporates Riverfront's FCC-
licensed call sign "KORN."
45. KORN Country 92.1 and Kettelson had and continue to have a bad-faith intent to
profit from, or to interfere with, Riverfront's distinctive marks, and to damage Riverfront's reputation. As evidence ofKORN 92.1 's bad faith: (a) KORN 92.1 owns no trademark or other
intellectual property rights to the designation "KORN" or any mark similar to it, as evidenced by
Kettelson's previous attempt to purchase the right to use that designation from Riverfront; (b) the
domain in question does not consist of KORN 92.1 's legal name or any other name by which
KORN 92.1 is legally known; in fact, KORN 92.1 has its own FCC-issued call sign, "KKOR;"
(c) KORN 92.1 has never made any good faith or fair use of the "KORN" designation on its
domain or otherwise, but instead uses the "KORN" and "KORN Radio" designations as call
letters that do not belong to it.
46. Riverfront is entitled to a judgment compelling KORN 92.1 and/or Kettelson to
transfer all ownership in the domain www.KORN92.com pursuant to 15 U.S.C. § 1125(d)(1)(c).
47. Riverfront is also entitled to a preliminary and permanent injunction enjoining
KORN 92.1 or Kettelson from further use of this domain pursuant to 15 U.S.C. § 1116(a).
48. Riverfront is further entitled to a judgment awarding it all damages caused by
KORN Country 92.1 and Kettelson, or in the alternative, statutory damages in the amount of
$100,000 regarding the domain www.KORN92.com pursuant to 15 U.S.C. § 1117(a) and (d).
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COUNT IV UNFAIR COMPETITION
49. Riverfront restates all previous allegations and incorporates them by reference.
50. KORN 92.1 'sand Kettelson's conduct constitutes unfair competition and
wrongful confusion of source.
51. For example, KORN Country 92.1 has represented to the public that its call-sign
is "KORN" and that it is commonly known as "KORN Country" when this representation is
false. Kettelson has registered domain name that makes it appear as ifKORN Country 92.1 's
call1etters are "KORN" when that is not true.
52. KORN Country 92.1 'sand Kettelson's representations were and are likely to
deceive or mislead prospective customers or purchasers, and have deceived and misled
prospective customers and purchasers.
53. These representations tended to, and did in fact, cause the mistaken belief that
KORN Country 92.1 is affiliated with Riverfront and its stations including KORN News Radio
1490.
54. These representations were material, in that they were likely to, and in fact did,
affect the conduct of prospective purchasers and listeners.
55. These representations were material in that there is a reasonable basis for
believing that the representations have caused, or are likely to cause, a diversion of trade or
listeners from Riverfront to KORN Country 92.1.
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56. These representations were made in bad faith and in reckless disregard for the rights of Riverfront in that Kettelson and KORN Country 92.1 made the representations with the intent of trading upon Riverfront's goodwill at Riverfront's expense.
WHEREFORE, Riverfront prays for judgment against KORN Country 92.1 and
Kettelson as follows:
1. That KORN Country 92.1 and Kettelson be preliminary and permanently enjoined and restrained from the wrongful conduct described above, particularly the use of Riverfront's call sign "KORN" or any confusingly similar variation thereof, and specifically the use of
"KORN" and "KORN Country" in any form of advertising or media, including on broadcasts, in print media, on billboards, on Facebook, on Twitter, or in iPhone or Android applications;
2. That KORN Country 92.1 and Kettelson be ordered to disgorge to Riverfront all profits derived from and/or compensate Riverfront for all damages resulting by reason of KORN
Country 92.1 'sand Kettelson's wrongful use of the designation "KORN;"
3. That KORN Country 92.1 and/or Kettelson be ordered to transfer the domain www.Kom92.com to Riverfront;
4. That Riverfront be awarded all recoverable damages, including any statutory, punitive, and multiple damages as provided by statute or other law;
5. That Riverfront be awarded it costs, disbursements, including reasonable attorneys' fees and expenses; and
6. That Riverfront receive such other and further relief as the Court deems appropriate.
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Dated this~ay of May, 2015.
JOHNSON, MINER, MARLOW, WOODWARD & HUFF
Steven K. Huff Post Office Box 667 Yankton, South Dakota 57078 (605) 665-5009 Attorneys for Plaintiff Email: [email protected]
WOODS, FULLER, SHULTZ & SMITH P.C. Ryan W. Snell 300 South Phillips Avenue, Suite 300 Post Office Box 5027 Sioux Falls, South Dakota 57117-5027 (605) 336-3890 Email: [email protected]
ATTORNEYS FOR PLAINTIFF
PLAINTIFF DEMANDS A TRIAL BY JURY ON ALL ISSUES
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LICENSE RENEWAL AUTHORIZATION
THIS IS TO NOTIFY YOU THAT YOUR APPLICATION FOR RENEWAL OF LICENSE, BR-20121130BAN, WAS GRANTED ON 03/22/2013 FOR A TERM EXPIRING ON 04/01/2021 .
THIS IS YOUR LICENSE RENEWAL AUTHORIZATION FOR STATION KORN .
FACILITY ID: 35420 RIVERFRONT BROADCASTING LLC LOCATION: MITCHELL, SD 3008 MULLIGAN DR YANKTON, SD 57078 THIS CARD MUST BE POSTED WITH THE STATION'S LICENSE CERTIFICATE AND ANY SUBSEQUENT MODIFICATIONS.
Case 5:15-cv-04042-MWB Document 2-2 Filed 05/28/15 Page 1 of 8 Federal Communications Commission Approved by OM13 FOR FCC USE ONLY Washington, D.C. 20554 3060-00 I 0 (June 20 I 4) FCC 323 FOR COMMISSION USE ONLY OWNERSHIP REPORT FOR FILE NO. BOS-20141016AAO COMMERCIAL BROADCAST STATIONS
SectiOn I- General InformatiOn . ,-'---'---, . ·- I. · Legal Name of the Respondent RIVERFRONT BROADCASTING LLC -- . -· -· . ... !Street Address (I) ~008 MULLIGAN DR . . . .. !Street Address (2)
.. f'ty ~r Country (if foreign address) !ZIP Code Y~NKTON 0 . 57078- Telephone Number (include area code) ~-Mail Address (if available) 6052600793 [email protected] !FCC Registration Number: fall Sign 'Facility ID Number · 0016909616 KZKK 15267 ·r---, . . . 2. Contact Representative 'Firm or Company Name DAVID OXENFORD WILKINSON BARKER KNAUER, LLP .. Street Address (I) 2300 N STREET, NW !Street Address (2) SUITE 700
IC'ty ~~tate or Country (if foreign address) IZIP Code DC 20037 - ~ASHINGTON . . .. Telephone Number (include area code) ~E-Mail Address (if available) 2027834141 DOXENFORD@WBKLA W.COM N•tuco of R"pondoot (Seo I n"ruotion' fo' definitio"') r o@ Licensee · 0 Pennittee 0 Entity with an attributable interest . If this application has been submitted without a fee, indicate reason for fee exemption (see 47 C.F.R. Section 1.1114): r 0 Governmental Entity 0 Fee-exempt Report 0 Other Other ON!A (Fee Required) . All ofthe infocm•tion fumi,hed in thi' Report i' '"""''"of 10101/2014 r. (Date entered must (I) be Oct. I of the filing year when filing a Biennial Ownership Report (or Nov. I, 2009 in the case ofthe initial filing); or (2) be no more than 60 days prior to the date offiling when filing a non- biennial Ownership Report.) . . 6. jPurpose: This Report is filed for: (choose one) . . . . /a. C' Biennial b. C Validation and Resubmission of a previously filed Biennial Report (certifying no change from previous Report)
Case 5:15-cv-04042-MWB Document 2-2 Filed 05/28/15 Page 2 of 8 c. € •Transfer of Control or Assignment of License/Permit d. 0 Report by Permittee filing within 30 days after the grant of a construction permit for a new commercial AM, FM or full power television broadcast station. e. 0 Update I certification of accuracy of an initial Ownership Report filed by Permittee (filing in conjunction with Permittee's application for a station license) lr. c-~mendment to apreviously filed Ownership Report I File Number: -
Station List
This Report is filed for the following stations: !Copy I Call Sign r:-~~:rDI . Location (City/State) . . I Class of service
~~.---'--K-K-'-'-Y'-A--~~ YAN~~~OT~OUTHI'- --FM-S-ta-ti-on__ _
. ~r KYNT 16o8571 YANKTON, souTH 1 AM Station I I I DAKOTA ~~ KLXS-FM I 60860 I PIERRE, SOUTH DAKOTA 'I_ __F_M_S-ta-ti-on ___ _ ~~ KCCR I 60858 I PIERRE, SOUTH DAKOTA I AM Station 5. ~QRN r5503 r MITCHELL, SOUTH''----' -F-M- S-ta-tt-.o-n _ _ _ DAKOTA .. AM Station ~ KORN r MITC~;i~T~OUTH 1 1 1 ~~ KDAM I 183348 I HARTINGTON , NEBRASKA .-I- --F-'-M-St--'-at-io-n---:
~~ KZKK I 15267 I HURON, SOUTH DAKOTA I FM Station
~~ KCCR-FM I 190370 I BLUNT, SOUTH DAKOTA .-J---FM-S-ta-tio_n ___ , ~--~------~---'~--~------.------,------~~------Validate §ubform l §ave Subform I ,-----, . 8. !Respondent Is: 0 Sole Proprietorship ONot-for-profit G Limited partnership corporation 0 For-profit corporation G General partnership 0Qther If "Other," describe nature of the Respondent in an Exhibit. ~[Exhibit 2 ]
Section II-A- Non-Biennial Ownership Information r-1 . .
Case 5:15-cv-04042-MWB Document 2-2 Filed 05/28/15 Page 3 of 8 -'-- I. Contract Information. List all contracts and other instruments required to be filed by 47 C.F.R. Section 73.3613. (Only Licensees, Permittees, or Respondents with a majority interest in or that otherwise exercise de facto control over the subject Licensee or Permittee shall respond. Other Respondents should select "Not Applicable" in response to this question.) If the agreement is a local marketing agreement (LMA) or a joint sales agreement (JSA), or if the agreement is a network affiliation agreement, check the appropriate box; otherwise, select "Other" for non-LMA/JSA or network affiliation agreements. 0Not Applicable
· [Enter Contract Information]
Contract Information
Add Copy I I I I
,--- 2. Capitalization (Only Licensees, Permittees, or entities with a majority interest in or that otherwise exercises de facto control over the subject Licensee shall respond.) 0.Not Applicable
[Enter Capitalization Information]
Capitalization Information
r Add Copy Delete §elected I (Check/ ! I Uncheck All) I Validate §ubform I §ave Subform I ,....:...,--- 3. (a.) Ownership Interests. This Question requires Respondents to enter detailed information about ownership interests by generating a series of subforms. Answer each question on each sub form. The first sub form listing should be for the Respondent itself. If the Respondent is not a natural person, also list each of the officers, directors, stockholders, noninsulated partners, members and otl:er persons or entities with a direct attributable interest in the Respondent. (A "direct" interest is one that is not held through any intervening companies or entities.) In the case of vertical or indirect ownership structures, report only those interests in the Respondent that also represent an attributable interest in the Licensee or Permittee for which the Report is being submitted.
List each person or entity with a direct attributable interest in the Respondent separately. Entities that are part of an organizational structure that includes holding companies or other forms of indirect ownership must file separate ownership reports. In such a structure do not report or file separate reports for persons or entities that do not have an attributable interest in the Licensee or Permittee for which the report is being submitted.
I Ownership Interests Information I _j
Case 5:15-cv-04042-MWB Document 2-2 Filed 05/28/15 Page 4 of 8 ,....--~ ~. -. . . lj Copy !Name !DOYLE BECKER r 1. Address Street 3008 MULLIGAN DR
City/State YANKTON , SOUTH DAKOTA Postal/ZIP Code 57078- Country (if not U.S.) ~Listing Type C!'! Respondent 0 Other Interest Holder Relationship to ()Licensee/Permittee (or Officer/Director of Licensee/Permittee Licensee/Permittee) 0 Person with attributable interest 0 Entity with attributable interest Positional Interest . Dofficer (Check all that Dnirector apply) 0 General Partner 0 Limited Partner RJ LC/LLC/PLLC Member 0 Owner 0 Stockholder 0 Attributable Creditor 0 Attributable Investor 0 Other (please specify): FCC Registration 10019524453 Number !!Percentage of votes 149.0% I ~ P"'"""g' of tom I 149.0% assets · ~ (equity debt plus) ~I . Copy !Name ' [CAROLYN BECKER r 2 . · · Address Street 3008 MULLIGAN DR
City/State YANKTON , SOUTH DAKOTA I Postal/ZIP Code 57078- Country (if not U.S .) ~Listing Type 0 Respondent ~·Other Interest Holder I
------Case 5:15-cv-04042-MWB Document 2-2 Filed 05/28/15 Page 5 of 8 r~m===~~~~~~~~~~~~~~~~~~~~~======~i Relationship to 0 Licensee/Permittee (or Officer/Director of Licensee/Permittee Licensee/Permittee)
~,(b.) Rospondent oert;fios the! eny equ;; ood fin'"d'l ;ntms~ not ~ported;" cosponse to Gyes CNo Question 3(a) are non-attributable. Exhibit 31[ Exhibit 3] If"No," submit as an Exhibit an explanation. . (c.) Does the Respondent or any person/entity with an attributable interest in the Respondent also hold an attributable interest in any other broadcast station, or in any newspaper entities in the same market, as defined in 47 C.F.R. Section 73.3555?
If "Yes", provide information describing the interest(s), using EITHER the sub form OR the spreadsheet option below for the applicable type of interest (broadcast or newspaper). Respondents with a large number (50 or more) of entries to submit should use the spreadsheet option. NOTE: Spreadsheets must be submitted in a speciai"XML Spreadsheet" format with the appropriate structure that is specified in the documentation. For instructions on how to use the spreadsheet option to complete this question (including templates to start with), please Click Here.
[Broadcast Interests Subform] Broadcast Interest Information · ~
Case 5:15-cv-04042-MWB Document 2-2 Filed 05/28/15 Page 6 of 8 r- -, I Add Copy I ~lete ~elected I Validate ~ubform I ~ave S~bform I
[Newspaper Interests Subform]
Newspaper Interest Information
Add Copy I ~Jete ~elected I I .- . - ~1 Valid~te ~ubform I ~ave Subform J r- (d.) Are any of the individuals listed in response to Question 3(a) married, related as parent-
If "Yes", complete the information describing the relationship.
Familial Relationships
fopy JName tarenU Child ~~Siblings DOYLE BECKER 0 ® 0 ~I I I -I f2. I CAROLYN BECKER I 0 I €• I 0 ,....--- (e.) Is Respondent seeking an attribution exemption for any officer or director with duties Dyes GiNo tmrelated to the Licensee or Permittee ? - If"Yes", complete the information in the required fields and submit an Exhibit fully describing that individual's duties and responsibilities, and explaining why that individual should not be attributed an interest.
[Enter Attribution Exemption Information]
Exemption Information List
' Add Copy ~Jete Selected I I n (Check/ Uncheck All) :- ~~~~ ~~;~ · ;~~~:~ - -r -~:~~~:~~~;;r-~
------Case 5:15-cv-04042-MWB Document 2-2 Filed 05/28/15 Page 7 of 8 .[
SECTION III- CERTIFICATION
I certify that I am DOYLE BECKER
(Official Title)
of RIVERFRONT BROADCASTING LLC
(Exact legal title or name of Respondent)
and that I have examined this Report and that to the best of my knowledge and belief, all statements in this Report are true, correct and complete.
(Date of the signature below must ( 1) be no earlier than Oct. I of the filing year when filing a Biennial Ownership Report (and no earlier than Nov. 1, 2009 in the case of the initial filing); or (2) be no more than 60 days prior to the date of filing when filing a non-biennial Ownership Report.)
Signature !DOYLE BECKER lfelephone Number ofRespondent (Include area code) 6056613160
WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE. TITLE 18, SECTION I 00 I). AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 3!2(a)(l )), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).
Exhibits Validate I §ave I Edit FRN 111/ienu
------Case 5:15-cv-04042-MWB Document 2-2 Filed 05/28/15 Page 8 of 8 United States of America FEDERAL COMMUNICATIONS COMMISSION FM BROADCAST STATION LICENSE
Authorizing Official:
Otficial Mailing Address:
MAIN STREET BROADCASTING, INC . Penelope A. Dade ATTN: LYNN KETELSEN Supervisory Analyst 255 CEDARDALE DRIVE Audio Division OWATONNA MN 55060 Media Bureau Grant Date: April 26, 2011 Facility Id: 7 0 93 0 This license expires 3:00a.m. Call Sign: KKOR local time, April 01, 2013. License File Number: BMLH-20110414ABA
This license modifies license no.: BLH-20020625AAQ
subject to the provisions of the Communications Act of 1934, subsequent acts and treaties, and all regulations heretofore or hereafter made by this Commission, and further subject to the conditions set forth in this license, the licensee is hereby authorized to use and operate the radio transmitting apparatus herein described.
This license is issued on the licensee's representation that the statements contained in licensee's application are true and that the undertakings therein contained so far as they are consistent herewith, will be carried out in good faith. The licensee shall, during the term of this license, render such broadcasting service as will serve the public interest, convenience, or necessity to the full extent of the privileges herein conferred.
This license shall not vest in the licensee any right to operate the station nor any right in the use of the frequency designated in the license beyond the term hereof, nor in any other manner than authorized herein. Neither the license nor the right granted here·mder shall be assigned or otherwise transferred in viola~ion of the Communications Act of 1934. This license is subject to the right of use or control by the Government of the United States conferred by Section 606 of the Communications Act of 1934.
FCC Form 351 B October 21, 1985 Page 1 of 2
Case 5:15-cv-04042-MWB Document 2-3 Filed 05/28/15 Page 1 of 5 Callsign: KKOR License No.: BMLH-20110414ABA Name of Licensee: MAIN STREET BROADCASTING, INC.
Station Location: MN-WASECA
Frequency (MHz) : 92.1
Channel: 221
Class: C3
Hours of Operation:unlimited
Transmitter: Type Accepted. See Sections 73.1660, 73.1665 and 73.1670 of the Commission's Rules.
Transmitter output power: 4.0 kW
Antenna type:Non-Directional Description:ERI FML-6E Antenna Coordinates: North Latitude: 44 deg 02 min 44 sec
West Longitude: 93 deg 23 min 02 sec
Horizontally Vertically Polarized Polarized Antenna Antenna
Effective radiated power in the Horizontal Plane (kW): 9.8 9 . 8
Height of radiation center above ground (Meters) : 168 168
Height of radiation center above mean sea level (Meters): 515 515
Height of radiation center above average terrain (Meters): 162 162
Antenna structure registration number: 1030901
Overall height of antenna structure above ground (including obstruction lighting if any) see the registration for this antenna structure .
Special operating conditions or restrictions:
1 The permittee/licens< ~e \ n coordination with other users of the site must reduce power or cease operation as necessary to protect persons having access to the site, tower or antenna from radiofrequency electromagnetic fields in excess of FCC guidelines.
*** END OF AUTHORIZATION ***
FCC Form 351 B October 21, 1985 Page 2 of 2
Case 5:15-cv-04042-MWB Document 2-3 Filed 05/28/15 Page 2 of 5 ,.FCClnto Results Page 1 of 3
FCCI nfo on GooQ!e Earth FAQ FCC/nfo.com Privacv Statement A Service of Cavell, Mertz & Disclaimer Associates, Inc. (855) FCC-INFO About Cavell. Mertz & Associates, Inc.
KKOR I New Search I (FM) 92.1 Waseca,MN Call Sign History I Search Results I KKOR from 06/05/2012 MHz I Map It I KRUE from 04/01/1993 KOWO-FM from08nOtl984 KQDE-FM from 11/30/1979
KKOR Channel: 221C3 92.1 MHz Waseca. Minnesota Service: FM - A full-service FM station or application. Facility ID; 70930 Fac. Service: FM KKOR License Expires: 04/01/2021
Status: License Application Accepted: 04/15/2011 Application Granted: 04/26/2011 File Number: BMLH-20110414ABA KKOR License Expires: 04/01/2021 !Sf License Prefix Type: This is a modification of a license for a o CP commecial FM station 0 Application Application Type: Modification ofLicense 0 Allocation FCC Web Links: This Application Other KKOR Applications Including Superseded Applications Facility Type: FM STATION \ Class: C3, A Zone II station; with 6kW-25kW ERP and a class contour distance 28km-39km
Site Location: 44-02-44.0 N 93-23-02.0 W (NAD 27) Site Location: 44-02-43.9 N 93-23-02.8 W (Converted to NAD 83) Effective Radiated Power: 9.8 kW Transmitter Output Power: 4 kW Antenna Center HAAT: 162m Antenna Center AMSL: 515 m Antenna Center HAG: 168m
Site Elevation: 347m. Height Overall*: 209.4 m.
------http://www.fccinfo.com/CMDProEngineCase 5:15-cv-04042-MWB.php?sCurrentService=FM&tal5Search'fype Document 2-3 Filed 05/28/15 Page- Appl 3 of-... -5 5111120 15--- .FCCinfo Results Page 2 of3
(*As Filed In This Application, may differ from ASR Data, Below.)
Omni-Directional Antenna Anterma Make/Model: Electronics Research Inc. FML-6E .Antenna ID: 0 Polarization:
Structure Information KKOR(FM) Licensee BMLH-20110414ABA Information Applicant Information Structure Registration Number 1030901 MAIN STREET (As of2011, date ofthis [ASR Heights Differ from KKOR BROADCASTING. INC. License Application) Application] Attn: Lynn Ketelsen Structure Type: Structure Type: 255 Cedardale Drive LYNN C. KETELSEN TOWER Owatorma, MN 55060 Title: President Registered To: Phone: 000-000-0000 Date: 04/13/2011 BLOOMING PRAIRIE FARM Licensee Application Certifier RADIO INC= KOWZ-FM + KRUE JOHNS. NEELY, ESQ. Structure Address: Miller And Neely, P.c. 2 Mi S Of Meriden Nr _ . Phone: 301-986-4160 Waseca,MN E-Mail: ASR Issued: 05/27/2011 i olmsnee I y(@vahoo.com Date Built: 01101/1994 Contact Representative Site Elevation: 347.4m. Structure Height: 209.4m. MAIN STREET Height Overall: 210.3m. BROADCASTING, INC. Overall Height AMSL: 557.7m. Attn: Lyrm Ketelsen FAA Determination: 05/26/2011 25 5 Cedardale Drive FAA Study#: 2011-AGL-2683- Owatorma, MN 55060 0E Phone: 000-000-0000 FAA Circular#: 70/7460-1 H Applicant Paint & Light FAA Chapters: 3, 4, 5, 13 GARRETT G L YSIAK, PE Owl Engineering, Inc 44-02-43.9 N 93-23-02.7 W (NAD 83) 5844 Hamline Ave N 44-02-44.0 N 93-23-01 .9 W Shoreview, MN 55126 (Converted to NAD 27) Phone: 651-784-7445 E-Mail: gg](aJ. o-vvleiH!.com Title: Consulting Engineer Date: 04/11/2011 Certifying Engineer
Associated Land Mobile Licenses Associated Microwave Licenses ------·------(No Records Found) (No Records Found)
------==--..,.. http://www.fccinfo.com/ClviDProEnCase 5:15-cv-04042-MWBgine.php?sCurrentServic Document 2-3 e =FNf&tabSeaFiled 05/28/15reliT yPagepe=Ap 4p l..of. 55111 12fJ1 ,__ ___ F,CCinfo Results Page 3 of3
Study Date: 5/1112015; Study Duration: 0.0702 Seconds. Database Sources: 5/1112015 FCC COBS, 51512015 FCC ASR, 5/5/2015 FCC ULS Microwave, and 515120 I 5 FCC ULS Broadcast Land Mobile.
© 2015 Cavell Mertz & Associates, Inc. Manassas, Vitginia
http://www.fccinfo.com/C:MDProEngine.pilp?sCurrentService=FM&tabSearchType-ApplCase 5:15-cv-04042-MWB Document 2-3 Filed 05/28/15 Page 5 of-:-:-:- 55/11/2015 -- - "':,~-~ !j~{'
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Take Your Tima- Sam Hunt Zac Brown Band's Jekyll+ Hyde Is Nation's No.1 4. Homegrowl\. Zac Brown Band Album 5. Slppln' On Fire. Florida Georgia Line 6. Like a Wrecking Ball . Eric Church ,., Blake Shelton Get"$ A Three-Peat on Top 20 7. Smoke. A Thousand Horses Branlloy Gilbert, Tim McGraw on CMT Hot 20 8. Don't It · Billy Currington Countdown 9. A Guy Walks Into a Bar~ Tyler Farr 10. Tonight Looks Good On You· Jason Eloven Years or Miranda Lambert and Mason Jars Aldaan 11 . Love You Like That. Canaan Smith CMT Crossroads: Lynyrd Skynyrd and Brantley 46° Gilbert Airing June 27 12. Love Me Like You Mean II - Kelsea Ballerinl Cloudy Frankie Ballard Goes to Hollywood With " Drinky 13. Drinking Class. Lee Brice 87S Drink" 14. Crash and Bum. Thomas Rhett 15. Raise 'Em Up (feat. Eric Church)· Can Tim McGraw Be the Bad Guy? Kellh Urban Go Hlgh·Tech at Your Wedding, Save Money 16. Little Toy Guns .. Carrie Underwood 17. Buy Me a Boat. Chris Janson Last-Minute Presents for Mom 18. Say You Do. Olsrl .EXHIBIT .6 Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 1 of 22 http://korn92.com/ 5/11/201-s- Kom Country 92.1 FM - Southe •.. ,_vfinnesota's NEW Country station Page 2 of2 I KORN Country 92 t,),'tro.m ..-r•!'rl ~,.l Like , KQBt. KORN Country 92 ~ . -~ ,;z May 8 al 6:48am Way to go Joel chambers .. he knew it was Chase Rica! Enjoy lree town Joel form all of us at Korn Country and thanks everyone for playing. Comment Share ,.,, •"'"'"• , Tra d iltons.. ~ Jl:QB~ KORN Country 92 o('J)'a~enille iJ.,;...,.,-.,t May 8 at 4:34am -.!.} Its frldaylll We stand on the brink 8 MORRIS &SONS iu ~~2,'~/!lo U.. MJ,.I 1,853 peop\elil I J What Is YOUR brand? Not sure? KORN Country 92.1 can help! EXCLUSIVE SAVINGS AT LOCAL BUSINESSES UP TO 50% OFF RETAIL PRICES! RANTS• ENTERTAirlMENT• GIFTS• GROCER HOME•GAS•AUTO•FARM & PET• RETAIL• GOLF LAWN & GARDEN• PERSONAL CARE•SERVICES • .>i. Southern Minnesota's home For todav's-1 NEW COUIIIrV is KORN COUNTRY 92.!_j Home I Schedule 1 On-Air Staff I Morning Show with Don White 1 Middays with Brad Kubat 1 Arter noon Drive with Molly Penny Sports Calendar 1 WEM Sports I NRHEG Sports 1 Big Deals 1 Contests I News J Weather 1 Sports 1 Advertise 1 Station Info 1 Contact Address: 255 Cedardale Drive, Owatonna Minnesota 55060 Fax line: 507-444-9080 Telephone: Owatonna- 507-444-9224 1 Waseca- 507-835-5555 Studio Email: booth@)korn92.com Copyright CD KOWZ & KORN Radio. Website designed by Owatonna Web Design. -,----~~--~ http://kom92.com/ Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 2 of 225/1112015- - ·Korn Country 92.1 FM Page 1 of 1 --> ~j· KORN Home Morning Show BIG Deals WEM Sports NRHEG S Country 92.1 00:03 VOL CIRRUS• l. 5/1 V20t5 -- http :1/radio. Case seeurenetsystems.net/v5/K 5:15-cv-04042-MWB0 RNFM Document 2-6 Filed 05/28/15 Page 3 of 22 f.\.pple - iTunes - Affiliates - Do, _oad iTunes Page 1 of 1 Download iTunes Free You're just a few steps away from downloading music, HD TV shows, movies, and more from the iTunes Store. To download i OOO . · ..: ~:. ~'> ~ ·); ~ .. _,...... _ Matthew Ketelsen's ··--·-·------_j ~~~ KORN KORN 92.1, you ~ ... ~ · ~Counlry92:1 need to have fi:ffi1£'lA . t~-;ii! iTunes. Jmtr::'- ~~ "/1..1~1 ~ ' · ~I W::."!Ul . " . [ . i iTunes M..,_TohAtt-... ~0.\tnr..W ...... Oo,..,.R*ba_ Free download For Mac+ PC • .;~·-... ··:x~ I '-·"" . I ...... I ; ~~.: -'>" ----- ... £ ...fi'OM,_,.Io....., .. ""-~"'f'MjVfe ...... ,...... ,rl_ ... ..,t ... .. ' r~l .(' : Using a 64-bit edition of Windows? J On a Mac? System Requirements> To le;~rn how Apple sareguards your personAl information. please review the Apple Customer Privacy policy. iluncs is licensed for rcproduccion of noncopyrighted materials or matNials the USN is legally pNmittcd 10 reproduce. Purchases from the iTunes Store arc av.1ili\ble only in Albania. Algeria, Angola. Anguilla, Antigua & Barbuda. Argentina. Armenia. Australia, Austria, Alerbaijan, The Bahamas, B~hrain. Barbados, Bel Mus . Belgium. Belize, Benin. Bermuda, Dhuti'ln , Bolivia, Botswana, Brazil. British Virgin Islands, Brunei. Bulgari;a, Bu rki nil Faso, Cambodia. (,1uada., Cilpe Verde. Cayman Islands, Chad, Chile, China. Colombia, Costa Rica. Croatia.. Cyprus. Czech Republic. Denmark, Dominic.l. Dominican Republic, Ecuador, Egypt, El Salv I, http://vvww.appCase e.coffilttuneshtffihatesf Categories Home Top Charts New Releases KORN 92.l Similar KOWZ, KORN, & KRUE Rodio Music & Audio ff~KORN ~Country 92.1 Add to Wi~hll!il lnslnll More from d KORN Country 92.1 FM is Southern Minnesota's home for today's best new country! ADDITIONAL INFORMATION Updated Size Installs January 21. 2015 3.1M 50·100 Current Version Requires Android Content Rating 6.23 4.1 and up Lew Maturity Permissions Report Offered By View details Flag as inappropriAte KOWZ, KORN, & KRUE Radio De-btoper Visit Wobslt~ Email [email protected] 255 Cedardale Drive Owatonna, MN 55060 https://playCase.google 5:15-cv-04042-MWB.corn!store/apps/details?id-com Document.kornfm 2-6.player Filed 05/28/15 Page 5 of 22511T/20t .KORN 92.1 - Android Apps orl.. 1ogle Play Page 2 of2 C>201 5 Google Site Terms of Service Devices Tern1s of Sale Privacy Policy Oevelopcus Artists Aboul Google https://play.google.com/store/apps/detarls?rCase 5:15-cv-04042-MWB Document-com.lCo:r:ntm.p 2-6 ayer Filed 05/28/15 Page 6 of 22511112o-J s~-- ~ ORN Coun~ 92 1 Fa cebook is on Facebook. To connect with KORN Country 92, sign up for Facebook today. · ~~)~ KOR" ~Country 92 About Photos Videos PEOPLE > U KORN Country 92 ~ 22m1n:. ..~ 1,848 lik es Way to go Joel chambers .. he knew it was Chase Rice! Enjoy tree town Joel ABOUT > form all of us at Korn Country and thanks everyone for playing. hltp://korn92.com/ PHOTOS > ~~2~ij ~.~,~~' Country 92 Its friday!!! We stand on the brink of another great southern minnesota weekend. Looks like the weather will be hit and miss so get out and enjoy when you can. We will ... See More 0 View 36 more comments ~ Heidi Ellis Yay Joel Cha mbers! Have funl ~ 20mins r:1£l Joel Chambers Yay! OMG I'm so jacked. biliJ I 2 mins r.::J ~ Don it is Wednesday .. ..lo l you ke ep saying th at it is Thursday. Llkfr Comment Share https://www .facebook.com/KORNCountry92(5/8/ 20 15 9: 11 :45 AM 1----- Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 7 of 22 KORN Country 92 I Facebook ~~ Jessl Morrow l t ~ At.: r,) 24 at 1 .J Cp: n ~;'\ ~ ·' THANK YOU FOR PLAYING A TRUE VARIETYIIIII heard Travis Tritt, Randy ... See More Like · Comment Share Jenao Perry <~nd Wild Ride : .. ;)·,! I S .n :t ~ l I :•H'· {' Thanks to Brad and Lori at KORN COUNTRY for having us in this momin ... See More Like Comment Share !6 2 CJ 1 =.n;.J,Ish (US) Ptt\'3G.,' · r·HmS C ~ ~~~ ~ i'~S .1\d•:-;w:J<;rqq · nd C l:ntC0$. (~~ ~A 0rc ~ F;:u:dlinoK '?.> 20 15 Like C c~: r6 Brianna Lynn Skalicky likes this. r,:::] KORN Country 92 ~ rv'lay 6 fl~ ~ 50:vn ...... congrats to savanna mahlum today .. she knew the answer was Shania twains' album "come on over". That album has sold over 20 million copies to date .. amazing. Enjoy dinner and a show ... See More t6 Joel Chambers, Brianna Lynn Skalicky and Heather Breyer like this. Jennl Williams How do you guys pick when there are so many with the right answer? I've been trying for months but never get picked. Not complaining just trying to understand the logistics r6 1 May :, al G co~' " '+ View previous replies ~ KORN Country 92 We always draw names randomly from most times, a pretty lengthy list. Thanks for your inquiry! '+ View more replies Good Morning and welcome to wednesday from Don White and the morning show. Another cloudy day with chances of rain so do your best to enjoy. I promised ... See More https:/f www .facebook.com/KORNCCaseounf ry5:15-cv-04042-MWB92[5/B/2015-9: 11:45 AM] ____ Document 2-6 Filed 05/28/15 Page 8 of 22 KORN Coun~ 92 I Facebook r6 Becky Hoffman and Adam Simon like this. 0 View previous comments ~ Karl Matson· Franezyk "Shanla Twain ·come on ove~· alt time #1 ~ country album. Sold over 40 million nation wide. Its her 3rd album produced in 1997. R ~In~ Wl~lund Shania Twain, Come on Over ~ ,;, t :war~t ; . . 1.Jm I{O~N CountnJ 92 shared Breonna Bachman Band's K! post. MCly 5 at 2.50pm · ··."'~ A HUGE thanks to THE BREONNA BACHMAN BAND for stopping into KORN Country 92.1 today for a fun interview!! Special thanks to Breonna, Nolan and Hamid!!https://;vww.facebook.com/breonnabachmanband/posts/163006444 3904704?_mref=message_bubbte Sreonna Bachman Sand ac.:~;;,d 8 new photos- wrfl Nolan Bachman and 2 others. Thank you so much to Brad at KORN Country 92 for inviting us on today! Was great ! to meet you & be on the air! Thanks for being the 1st radio station to play a song from our new album! You rock!' Like Comrneni t6 Brlanna Lynn Skalicky, Holly Larson and 2 others like this. r-.:-;\1 Breonn:. Bachmon Band Thanks so much for having us today and for ~ being the first station to play a song from our new album! You guys rock! a.:? 1 May 5 at 3·02pm r.::J KORN Country 92 shared KOWZ & KORN lvlinnesota ~ Tractor Ride's event. May 5 ~t D:.:! 2i'H' \ · ::dited · ":"':! https:/fwww.facebook:com/KORNeountry92(5/8/l015 9:1-¥.45 AM f------Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 9 of 22 KORN Country 92 I Facebook Bring your tractor and some f ''\OWZ & KORN Minne~ Saturday, June 13 at 8:00am in 13 people are going Good morning from Don Whit the morning show. I do have change in the giveaways this on KOrn Country. I mentione< yesterday we would have tick See More r6 Deborah Southworth, Nicole S· l_liQBi •toRN Country 92 J,""ru.'" May 4 .:lt -3 . 5~.21Hl · \~ Hope you had a great weeke from Don White and the morr show. i want to say congrats the Waseca choir departmen they put on their variety frida· See More li~~ Comment r6 Landi Elizabeth, Ruth Hines, ~ ~ ~ ~~ij ~~~~ ~~~~~tr; 92 Congratulations to tricia Mor~ the answer was Wildcountry. tricia!!! We will give away twc to winstock next week. Goin~ Waseca high school choir va See More Like Con~ m~n~ r6 Andrea Montemayor likes this. Its friday facebook friends an ttps://J'!Ww.fa_cebook.com/KQE._NCouo.t_ry.J2(5/mo15 9:11:45 AM]_ Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 10 of 22 KORN Country 92 I Facebook Bring your tractor and some friends and get ready for a fun filled day!! '{OWZ & KORN Minnesota Tractor Ride Saturday, June 13 at 8:00am in COT 13 people are going Loio:e Cor :1 r.-~o:1nt Shar\:: Good morning from Don White and the morning show. I do have one change in the giveaways this week . on KOrn Country. I mentioned yesterday we would have tickets .. . See More Like · Comment {J Deborah Southworth, Nicole Sublet, Pam Hameister and 13 others like this. 'KQB! ltORN Country 92 l•O!'U"'".l'"' May 4 .::rt ~.5Ga:n · \.~ Hope you had a great weekend from Don White and the morning show. i want to say congrats to the Waseca choir department, they put on their variety friday ... See More Li ~"'e Cornmem 16 Landi Elizabeth, Ruth Hines, Meg Miller and 6 others like this. Q ~toRN Country 92 ~ May 1 at fJ ::o .~r : l · ':' Congratulations to tricia Morgan, she knew the answer was Wildcountry .. enjoy Winstock tricia!!! We will give away two more tickets to winstock next week. Going to be at the Waseca high school choir variety show ... See More !6 Andrea Montemayor likes this. ~~~ij :~~~ ~3~~ ~~tr~ 92 Its friday facebook friends and it ____ https://www.facebook.com/KORNCountry92(5/8/20 LS 9: 11:45_AJ1)1 Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 11 of 22 KC. r looks like a decent one with the weather.. tomorrow looks just spectacular, make some plans. The Wild back on the ice tonight... See More L1 ke CommP.II\ r6 Heidi Ellis, Andrew Grunwald-Schnorenberg, Becky Hoffman and 4 olhers like this. Q Vi ew 41 more comments r;M Randy Kotek wildcountry L...1I!J May 1 at C. ::7on·. r.::J KORN Country 92 TriciD Morgan way to go tricla you were correct! you E:J can pick up your passes at our studios at 255 cedardale in Owatonna. Enjoy the show. ~~-PJ\.~ ~'~~ ~~a ~;~,~ ~~~y ..~2 Congrats to Reva Graves today .. she knew the answer was my childhood sports hero and Hall of farner Fran Tarkenton ... enjoy the movies. Tomorrow we give away two tickets ... See More r::J KORN Country _92 ~ April 30 at •1.30am · •:' Good morning facebook friends it is thursday and more importantly day one of the NFL draft! All football fans everywhere look forward to this day, and did you know the ... See fvlore r6 Heather Breyer, Heidi Ellis, Cherie Wyant and 3 others like this. Q V1ew 46 more comments ~ ~:r~·~:y, ~:7:~son Fran Tarkenton r.::J KORN Country 92 Reva Grave~ congrats reva .. you were correct.;> ick up 8 your movie passes at our studios at 255 cedardale In owatonna April 30 at 6 ·l5am W KORN Country 92 ~ April 29 at 6:13am · ·.'- Hi facebook friends from don white and the Korn morning show! We have some fun things coming up the next couple days. Tomorrow we will be giving away two passes ... See More r6 Heather Breyer; Amy Williams, Muriel Jo re and 12 others like this. https://www.facebook,com/KORNCountry92.(5/8/2.015 9:11:45 AM ].._.,______Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 12 of 22 KvKN Countty 92 I Facebook ~ ~:,: ~ua,~~'~:~ , :at time will your interview aire with Mike? ~ -~JJ!i ~o1R~ ~~~~~:~~~:y 1 ~~-,~~40am Congratulations to Bryan Kuhns ... he knew the answer was AI Paclno. Have a great weekend from Don white and the Morning show!! D Bryan Kuhns. Kim Murphy and Heidi Ellis like this. Good morning facebook friends its friday!! If you have big weekend plans looks a little wet today and early tomorrow but after that pretty good. Lots of proms taking place in the ... See More Llk.u · Cc: 'i m~a n : D Pam Hameister. Brianna Lynn Skalicky and Kelly Patee like this. Q View 41 more comments ~ Jennifer Schiller Hoffman Robert di Nero ~ Apn/ 24 m 6'43arn r.::J KORN Country 92 Bryan Kuhns congrats bryant !..it was AI Pacino. You I!.:'.::J can pick up your movie passes at our studios at 25 cedardale In Owatonna April 24 a/ 6:53am U KORN Country 92 ~ April 23 at 1·t:2Bum · Edited .._., Register to WIN a pair of NASCAR tickets NOW! Contest ends Monday! Go to www.lwrn92.com KORN Country 92.1 FM and Kansas Speedway are giving away tickets to the SpongeBob SquarePants 400 NASCAR race Sunday, May 9th, at Kansas Speedway! ... See More Win Kansas Speedway tickets! - Korn Country 92.1 FM https:/fwww.facebook~€om/KORNEountry92(5/8/2015-9 :11:45 AM]--- Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 13 of 22 KJRN' Count'ly 92. I Facebook KORN Country 92.1 FM and Kansas Speedway are giving away tickets to the SpongeBob SquarePants 400 NASCAR race Sunday, May 9th, at Kansas Speedway! KC;-!N"'.' .::<:-:.1 i:J Julie Overgaard Werner, Beth Schuler, Brittiny Lynn and 11 others like this. ¢1 share 0 View 8 more comments ... Brenda Hansen Stacy Barbeau ~ Rob Barbeau ElJ 1 r\j.J ,II .£tl ... •l t: :.~Cptl i a ~;,::~::.t~~ r;:~~ Country thank you so much Ill Super excited Hey facebook friends from Don White and the morning show. Just a quick reminder we will give away a couple movie passes to Northwoods cinema in Owatonna tomorrow mornlng .. check ... See More i:J Laurie Johnson, Sara Allen Wildeman, Colleen Walburn and 3 others like this. In .lenni Williams Yay no flying away with the wind, and no dirt in the eyes l1tJI fromtl April :!:; at 0:35CJt-:1 ~~~ -~~~ ~~ o ~Jo~:~\:2 Congrats to Helen Joy Sell from The morning show .. she knew the answer was of course the lovely Jana Kramer. Enjoy Winstock Helen ... and we will give away another set next week .... Se e More i:J Alexandra Stevens, Holly Lysne, Vanessa Knickrehm and 8 <.:!hers like this. 0 View 2 more comments 1m Tiffany Grunwald you brat helen 1M Apnl 22 at ·tz·osflm lt\l Helen .Joy Sell @ ~ Apnl 22 at ·12 24pm Good morning fellow facebookers from Don White and the morning show on Korn Country. Looks like we get to see the sun today which is nice, but still chilly, cant... https://wwwcfacebook.com/KORNCountry92.(5/ 8/-2.0 15 9: 1-1:45 AM]- Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 14 of 22 Kt..K.N 'countl'y 92 I Facebook See More r6 Cherie Wyant, Becky Hoffman and 2 others like this. 0 View previous comments m~~:~~;.; :~e4 ~~: Jana Kramer D KORN Country 92 Helen Joy Sell congratulations you are the winner of ~ two passes to Winstocklll you can pick them up at our studios at 255 cedardale in Owatonna. Have a great timel .·'\p(,J 22 : ,~ ~,.i ~ U t.Hi• Sign lJr Log In Messenger l·lloble F1nd 1=nends Badges People Pages Plac:es Games Lcr..ations About Create Ad f,r-.ate Page De \'elope•rs Careers P1ivucy Cook1es Ad Choices D> Terms He,lp Facebook © 2015 English (US) ~. https:/fwww .facebook.com/KORNCountry92[5/8/2015-9.:11:45 AM ] ___ Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 15 of 22 KOWZo~line . tbm- KOWZ FM, KRUE 1170, and KORN COUmR. _.t http:/ /kowzonline.com/[5/7 /2015-11:36:09 AM] Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page 16 of 22 / - i· . "I / I: / 11 ,.=:,"==-=f"--·==-.:.:=:;;''="·=~I.J -· J1/ -'i! Ij! I ·•-;•·11 1 I i ~!" \ l l i \ l .! i lo,..._;.~ H-1--..-..;:..::.!: i - _,.. ; H(: , l " ! ~r I ~ -\ i "0 :•. _ \ I : § :{. l -'!? ~-p.. . .., i i i i ! ,,~(;.. i::0 i ! <; ! i i i i ! i i(D' -~-.•· . i < ..:.I~ =. i : ~0 . ~ ! q...____~·'•.o !;=\',_____l i ! I; . ' ~1 ;. NOTI:S ~ns oC'Loan.c /wcnuc. Polkr A\·aux 1111d"btl:cy Aw:nuc lobe SUBBASIN I! rcklc:a~cd. 0= 1. Sultb:uins Oc1c:nlionPondlllt-.1Ys. SMbbl'riltl II. 16 ~uJI? Clnaot bescn-cd b)· the Sub R~ion2lJl(\Cinlon PcndtO:..tP.thcrc(orc sire 'l.o·:· = DRAINAGE FLOW \! specific dc~emionpoud'DMP arc Jc:qutmi. E.,xt IIXOI.rio1111o b.: •I tl¢tcmriMd \\bid1 c:ch 1itc"1cumtnrction l"llas. ...,, .. ...:~ ... !: ' = PERCENT OF j! GRADE AND •I,, DIREC110N li Sh·~c:lHe. DATD 7-5-?0QI MA'M Case 5:15-cv-04042-MWB Document 2-6 Filed 05/28/15 Page_., 17 of 22 N:orn92.com WHOIS domain rt!.~ -tration information fi·om Network Solu . s Page 1 of5 • Search • Renew • Transfer • Features • Private Re!!istration • Protect • Forward WHOIS Results for korn92.com Available domain names similar to korn92.com Available Extensions 0 korn92.net LJ korn92.org 0 korn92.us D korn92.us.com Available Domains D k0m91.com· ILl korn92planet.com D korn924you.com Ll korn92foryou.com 10 korn92.info Ll korn92.mobi Ll korn92.biz Ll korn92.co.uk LJ korn92.pro CJ korn92.de 0 korn92site.com LJ korn924u.com Ll korn92world.com TJ allkorn92.com [J korn92store.com [] korn922u.com tl;. View more korn92.com Is this your domain name? Renew it now. Domain Name: KORN92.COM Registry Domain ID: 1716329450_DOMAIN_COM-VRSN Registrar WHOIS Server: whois.godaddy.com Registrar URL: http://www.godaddy.com http://www.rietworksolutions.corrilwhois/results.jsp?Case 5:15-cv-04042-MWB Document 6main=korn92.com 2-6 Filed 05/28/15 Page 18-- of 22Sil 112015-- kornY2.com WHOlS domain re ;ration information from Network Solut Page 2 of5 Update Date: 2013-03-19T05:14:25Z Creation Date: 2012-04-27T04:16:57Z Registrar Registration Expiration Date: 2016-04-27T04:16:57Z Registrar: GoDaddy.com, LLC Registrar !ANA ID: 146 Registrar Abuse Contact Email: [email protected] Registrar Abuse Contact Phone: +1.480-624-2505 Domain Status: clientTransferProhibited http://www.icann.org/epp#clie Domain Status: clientUpdateProhibited http://www.icann.org/epp#client Domain Status: clientRenewProhibited http://www.icann.org/epp#clientR Domain Status: clientDeleteProhibited http://www.icann.org/epp#client Registry Registrant ID: Registrant Name: Lynn Ketelsen Registrant Organization: KOWZ & KRUE Radio Registrant Street: 520 McKinley St W Registrant City: Owatonna Registrant State/Province: Minnesota Registrant Postal Code: 55060 Registrant Country: United States Registrant Phone: (507) 446-8650 Registrant Phone Ext: Registrant Fax: Registrant Fax Ext: Registrant Email: [email protected] Registry Admin ID: Admin Name: Lynn Ketelsen Admin Organization: KOWZ & KRUE Radio Admin Street: 520 McKinley St W Admin City: Owatonna Admin State/Province: Minnesota Admin Postal Code: 55060 Admin Country: United States Admin Phone: (507) 4 4 6-8650 Admin Phone Ext: Admin Fax: Admin Fax Ext: Admin Email: [email protected] Registry Tech ID: Tech Name: Lynn Ketelsen Tech Organization: KOWZ & KRUE Radio Tech Street: 520 McKinley St W Tech City: Owatonna Tech State/Province: Minnesota Tech Postal Code: 55060 Tech Country: United States Tech Phone: (507) 446-8650 Tech Phone Ext: Tech ·Fax: ; . 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