'IAltilP&ffifrT[.'ffilu Beforethe FederalCommunications Commission Washington,DC 20554
In the Matterof:
MPSMedia of GainesvilleLicensee, LLP, Licenseeof StationWNBW-DT, CSR- Gainesville,Florida
For Waiverof $$76.92(f)& 76.106(a) of the RECEIVED- FCC Commission'sRules -5 sU1 Z01Z To: Chief,Media Bureau FedsralCommunications Commission Bureau/ 0fflce
PETITION FOR WAIVER OF SECTIONS 76.92(f)AND 76.106(a)OF THE COMMISSION'S RULES
MPSMedia of GainesvilleLicensee, LLP, licenseeof TelevisionStation WNBW-DT,
Gainesville,Florida (Facility ID No. 83965),by counsel,files this Petitionfor Waiver,pursuant to Section76.7 of theCommission's Rules, and requests a waiverof the "significantlyviewed" exceptionto the networknon-duplication rule, 47 CFR S 76.92(t),and the syndicatedexclusivity rule,47CFR $ 76.106(a).This will allow WNBW-DTto exerciseits networknon-duplication andsyndicated exclusivity rights with respectto StationsWESH(DT), Daytona Beach, Florida;
WJXT(DT),Jacksonville, Florida; and WTLV(DT), Jacksonville, Florida (the "Stations"), in the areasin the Gainesville,Florida Designated Market Area ("DMA") outsideof the city limits of
Gainesvilleserved by Cox Cable.l
t In WGFLLicense Corp.,22FCC Rcd 1708(2007),the Bureau waived the significantly viewedexception with respectto the samethree stations for 'othecommunity of Gainesville, Florida." Althoughthe viewing datasubmitted in thatproceeding included all areasof the GainesvilleDMA, Cox Cablehas asserted that the Bureau'sunopposed ruling thereonly applies to areasit serveswithin the city limits of Gainesville.The instantpetition showsthat the The Bureau should grant this Petition becausethe distant signals from WESH, WJXT and
WTLV are no longer significantly viewed in any part of the Gainesville DMA servedby Cox
Cable, and they are thus no longer eligible for the exceptionsto the network non-duplication and
syndicatedexclusivity rules. A Nielsen study showsthat the Stationshave failed to achieveany ratings in the Gainesville DMA communities servedby Cox Cable, and thus, are far from being significantly viewed. The Bureau should, therefore,grant this Petition.
The Applicable Standard
Once a television station notifies a cable systemlocated in whole or in part in the station's protectedgeographic zone that it holds the exclusiveright to distribute network and syndicatedprograms, the cable systemis generally baned from carrying thoseprograms as broadcastby any other television station.' Cablesystems, however, may continue to carry network or syndicatedprogramming of stationsthat are "significantly viewed" in a particular community.3 A station is deemedto be "significantly viewed" in a county if it was listed as such by the Commissioninl9T2 and in communitiesthat havebeen added to that list in the intervening y.ats.o
Although the Commission has not deletedstations from its 1972list of significantly viewed signals,it has establishedstandards for waivers when a station demonstratesthat another station is no longer significantly viewed in a particular community or communities. See KCST-
Stationsare not significantly viewed in all communitieswithin the Gainesville DMA, both inside and outsideof the Gainesvillecity limits, that are servedby Cox Cable;the Commissionis requestedonly to rule that Cox can no longer rely on the significantly viewed exception in areas it has claimed were not addressedin WGFL License Coro. 2 47 cFR $$ 79.92(a),76.tot. 3 Id. $$ 76.92(0;76.r06(a). 4 Id. g 76.5a(a).
2- TV,I03 FCC 2d 407(1986).s To obtain a waiver of the significantlyviewed exception, petitioners must submit a showing "from an independentprofessional audience survey of over- the-air television homesthat covers at least two weekly periods separatedby at least thirty (30) days but no more than one of which shall be a week betweenthe months of April and
September."6If two surveysare taken, "they . . . fmust] include samplessufficient to assurethat the combined surveysresult in an averagefigure at least one standarderror abovethe required viewing level."7
In applying this standard,the Bureau has recognizedthat:
Over time, The Nielsen Company ("Nielsen") becamethe primary surveying organizationthrough which a petitioner could obtain televisionsurveys. Nielsen,which routinely surueystelevision marketsto obtain television stations' viewership, conductsfour- week audiencesurveys four times ayear (i.e.,February, May, July and November "sweep periods"). The Bureau has found that replacing eachweek required under KCST-TV with a sweepperiod is acceptableand, if anything, addsto the accuracyof the audience statisticsbecause of the increasedsample size. Accordingly, a petitioner may submit the results from two sweepperiods in each year."
As shown below, the Bureau should concludethat eachof the Stations is no longer significantly viewed in the communitiesin the Gainesville DMA servedby Cox Cable. To avoid any doubt, the result would be that Cox Cable would not be able to rely on the significantly viewed exception for its systemsserving any areaswithin the Gainesville DMA, both outside and inside the Gainesvillecity limits.
' Seealso KCST-TV. Inc. v. FCC, 699F.2d 1185, I 192n.l3 (D.C.Cir. 1983)("ifa station's viewership. . . fallsto nearlyzero .. . it is obviouslyillogical for the Commissionto deemthe stationsignifi cantly viewed"). 6 47 cFR $ 76.s4(b). 7 Id. 8 WUPWBroadcasting, LLC,25FCC Rcd 2678, 2679-50 (2010).
-?- Argument
WNBW-DT is the NBC affiliate licensedto Gainesville, Florida and serving the
GainesvilleDMA. The GainesvilleDMA consistsof four Florida counties- Alachua"Dixie"
Gilchrist and Levy.
WESH is an NBC affiliate licensedto Orlando,Florida and servesthe OrlandoDMA.
WESH is listed in the Commission'sSignificantly Viewed Stationslist as significantlyviewed in all four of the countiesin the Gainesville DMA, which may reflect the fact that, at the time of the 1972survey on which the SignificantlyViewed Stationslist is based,Gainesville did not have its own NBC affiliate.
WTLV is an NBC affiliate licensedto Jacksonville,Florida and servesthe Jacksonville
DMA. WTLV is listed in the Commission'sSignificantly Viewed Stationslist as significantly viewed in Alachua, Dixie and Gilchrist counties. Again, much of this historic viewing may have been due to the absenceof an NBC affiliate in Gainesville in 1972.
WJXT is an independentstation licensed to Jacksonville,Florida and servesthe
JacksonvilleDMA. WJXT broadcastssyndicated programming which is alsobroadcast on
WNBW and to which WNBW has exclusiverights in the GainesvilleDMA. WJXT is listed in the Commission'sSignificantly Viewed Stationslist as significantly viewed in Alachua,Dixie,
Gilchrist and Levy Counties.
To obtain a waiver of the significantly viewed exception to the network non-duplication and syndicatedexclusivity rules, WNBW must demonstratethat WESH and WTLV no longer achieve a three percent (3%) shareof weekly viewing hours and a net weekly circulation of 25 percent.e Since WJXT is not a full or parlialnetwork station, WNBW must demonstratethat it
47CFR $ 76.5(i).
-4- doesnot achievea two percent (2%o)share of weekly viewing hours and a net weekly circulation
of five percent(5%).to
Attachedis a system-specificSignificant Viewing Study conductedby NielsenMedia
Research(the "Nielsen Study") which demonstratesthat the Stationsare no longer significantly viewed in the communities in the GainesvilleDMA - both inside and outsidethe Gainesville city limits - servedby Cox Cable.lr In fact, the Nielsen Study,which examinedover-the-air viewing
in July 2010,November 20l0,May 20Il andNovember 2011, showsthat the threestations failed to achieveany measurableover-the-air viewing in the areasin the Gainesville DMA servedby Cox Cable.
The Nielsen Study conforms to the Commission's standardsregarding significantly viewed surveys. The Nielsen Studycontains Nielsen's detailed explanation of the methodology usedto obtainthe audiencedata. The NielsenStudy presents a retabulationof Nielsen's routinely obtained audiencedata. It includesan explanation of how the relevant diaries were selectedfrom Nielsen's databaseas well as the weighting proceduresNielsen used,the standard error calculation applied, and other statisticalmethods Nielsen used to derive the audience estimatesand associatedstandard error calculations.The Nielsen Studydescribes how Nielsen's routinely-collecteddata were used to provide a representativesample demonstratingthat the ro Id. rr WNBW notified Cox Cable and all other required parties that it intendedto commission Nielsen to preparea significantly viewed audiencesurvey using Nielsen viewing data. The notice complied with the requirementsof Section 76.54(c) of the Rules and was servedon potentially affectedparties as required by that rule. The Commission has agreedthat "[w]e would not read the advancenotice provisions of Section 76.54(c) (advancenotice of survey methodologyto other interestedparties) as precluding use of data already collected basedon methodologypreviously approvedby the Commission. In such cases,notice to other interested parties prior to purchaseof data would suffice." Amendmentof Parts I , 63 and 76 of the Commission'sRules,3 FCC Rcd2617,2620n.23 (1988). WNBW did not receiveany commentson or objections to its proposedstudy.
-5 Stations' over-the-airviewing in the communities servedby Cox Cable in the Gainesville DMA no longermeet the significantviewing standard.12
The Nielsen Study usescommercially-accepted audience data and tabulatesviewing patternsin non-cable/non-ADShouseholds based on zip codesassociated with the Cox Cable serviceareas in the GainesvilleDMA. The Commissionhas consistentlyaccepted such surveys for purposesof demonstratingthat a station is no longer significantly viewed, including the use of zip codesto identify the householdsin aparticular community.t3 The samplesource for the
Nielsen Studyconsisted of usablediaries from non-cable/non-ADShouseholds in zip codesin the Cox Cable serviceareas in the Gainesville DMA, both in and out of the Gainesville city ta limits, during the monthsof July andNovember 2010 and May andNovember 2011.
As shown below, the Nielsen Study confirms that the Stationsare no longer significantly viewed. For eachof the Stations,the Nielsen Study shows that they had no measurableviewing in the householdsample. Each Station, therefore,had a zero shareof weekly viewing and zero
12 SimilarNielsen studies were the basis of grantingpetitions for waiversof the significantlyviewed exception in SagaBroadcasting, LLC,26 FCCRcd 16851(2011); WUPW Broadcasting,LLC,25 FCC Rcd 2678, 2688-89 (2010); KGAN Licensee, LLC,23 FCC Rcd 9534(2008); Meredith Corp., 22FCCPtcd12932 (2007); Barrington Broadcasting Flint Corp., 19FCC Rcd22046 (200D; andMMM LicenseLLC,17 FCCRcd 20875(2002). 13 See,e.g., Gulf-Catifurnia Broadcast Co.,23 FCC Rcd 7406, 7409 (2008)("Nielsen re- tabulatesthe over-the-airdata that it collectsfor its routineaudience sweep periods, selecting in- tab diariesfrom its databasefrom the . . . individualcable community [based on zip code]".); KSWB,Inc.,13 FCC Rcd 15470 (1998). t4 TheNielsen Study included ll7 in-tabdiaries for eachof the four monthsstudied. That numberis well abovethe rangeof samplesizes in studieson which the Commissionhas previouslyrelied. See WUPW Broodcasting,25 FCC Rcd at2682,2689 (samples of 86 and79); TribuneTelevision Co.,24 FCC Rcd 1622(2009)(sample sizes of 9, 19,2,4 and2);KGAN Licensee,LLC,23 FCCRcd 9534(2008)(sample sizes of 20 and2I); Il'yomediaCorp., 17 FCC Rcd20348 (2002)(sample sizes of 32,34,30 and26). As requiredin Saga,26FCCRcd at 16853,WNBW is submittingthe results for eachof theindividual sweeps periods.
-6- percentof the averageweekly circulation. Since no measurableviewing was shown, the standarderror calculation was also zero."
The Nielsen Study shows that, for all four sweepsperiods, the Stationswere not significantlyviewed in the communitiesin the GainesvilleDMA servedby Cox Cable. Their viewing levels of zero fall far short of the standardsfor being consideredsignificantly viewed.
Accordingly,MPS Media of GainesvilleLicensee, LLC requeststhat the Commission waive the significantly viewed exceptionto the network non-duplication and syndicated exclusivity rules so that WNBW can assertits important program exclusivity rights in all areasof its local marketof Gainesville"Florida" served bv Cox Cable.
Respectfullysubmitted,
Law Officesof JackN Goodman 1200New HampshireAve., NW Suite800 Washington,DC 20036 202-776-204s
CounselforMPS Media of Gainesville Licensee,LLC
July5,2012
15 Similar results have been held to support a waiver of the significantly viewed exception. ln WUPWBroadcasting, where someof the studiesalso showed no measurableviewing and the resulting standarderror was calculatedas zero)the Commission understood,"[i]t does not necessarilymean that not one householdviewed WJBK, but rather that when the reported viewing is convertedto an audienceshare, the result is below Nielsen'sreporting minimum." 25 FCC Rcd at2689 n.96. Seealso KSWB,Inc.,13 FCC Rcd at 15476(accepting zero viewing, averageweekly circulation and standarderror calculations of zero).
.I VERIFICATION
Theurrdersigned certilies that he has read the Petition for Waivelof Sections7692(f) and76, I 06(a)of theConunission's Rules prepared for MPSMedia of GainesvilleLicensee,
LLC, andto thebest of his knowledge,information and belief formed after reasonable inquiry, it is well grnrndedin fact,is wauantedby existittglaw, and it is not interposedfor anyimprcper puryose.
ToddSenter GeneralManager WNBW.DT 1703Nw Sorl'Blvd, Gainesville,FL 32606
July5,2012 niclscrl
Theattached report provides audience net weekly circulation (cume) and share information amongnon-cable/non-ADS households for WESH,WJXT and WTLV duringthe Nielsen Station Index(NSI) survey conducted over four week periods during the July 2010, November 201 0, May 2011and November 2011 measurement periods. The report is basedon seriesof Zip code group.Households will maintainthe reported Nielsen Viewers in Profile(VIP) weights used to projectin-tab sample households to universeestimates for theirrespective measurement periods. Thisstudy measures non-cable/non-ADS household viewing between 7AM-1AM, Monday to Sunday.
The samplesource for this surveyconsisted of non-cable/non-ADSTV householdsreturning usabletelevision viewing diaries. NSI procedureswere used for distributingdiaries and for compilingthe estimatedaudience projections in this report.Average quafter hour projections werecomputed by summingweights for quafterhours in the daypartfor the non-cable/non-ADS in-tabhouseholds and dividing by thenumber of quarterhours in thedaypart. The weights which wereused for projectionsare those used to projectin-tab sample households to universe estimatesin theregular Nielsen Viewers in Profileanalysis. Share and cume estimates as well as theirrespective standard errors are computed for eachof the geographiesas follows:
Sharesof totalviewing are computed by dividingaverage quafter hour M-Su 7AM-lAM projectionsof a givenstation for thenon-cable/non-ADS in-tab households by theaverage quarterhour M-Su 7AM-lAM projectionsin non-cable/non-ADShouseholds across all stations. The associatedstandard error is calculatedusing the acceptedformula for computingthe standarderror of a ratio estimateand is shownbelow:
The averageweekly circulation (cume) is an averageof the four weeksof the measurement period.The cume was computed by summingthe weights for all non-cable/non-ADShouseholds tuningat leastone quarter hour to a givenstation within the cycle during the M-Su 7AM-1AM daypartand dividing by thesum of all non-cable/non-ADSweights within the given measurementperiod for eachweek. The cumefor eachweek in the measurementperiod is then summedand divided by the numberof weeksin the measurementperiod to computethe average weeklycume. The associatedstandard error for the averageweekly cume is calculatedusing the acceptedformula for computingthe standarderror of a ratioestimate. This standarderror is the errorof the averageweekly cume; it is not an averageof the weeklystandard error. The formulasused are shown below:
Share
-a' L@* Qhrs(s)) - Slnte= , Qhrs(t)) T,r-
ShareStandard Error nielscn aaaaaaaaa
wheren : numberof intabhouseholds wherew: householdweight whereQhrs(s) : total quarterhours tuned to stationof interestby household whereQhrs(t) : total quarterhours tuned by household
AverageWeekly Cume
* Zwn weishtx AverageWeeklyCum, =! I z Lnn weight I
AverageWeekly Cume Standard Error
I (x-Week Cume)*HH Weight Std Error = Lun weisht I
wherez : numberof weeksin analysis(with non-zerointabs) wheren : numberof intabhouseholds in week wherex : 0 if householddid not tunestation of interest wherex : I if householddid tunestation of interest
Theattached report is representativeof the viewingpatterns of the non-cable/non-ADS householdsofthe geographicarea surveyed. Petitionfiled for "SYSTEMOF".. Petitionfiled for the followingstations on the "SignificantlyViewed" list in the GainesvilleDMA. GainesvilleDMA
DMA SignificantlyViewed Counties StationsListed bv FCG
Alachua WJXT-Jacksonville(lND) WTLV-Jacksonville(NBC) WESH-Orlando(NBC)
Dixie WJXT-Jacksonville(lND) WTLV-Jacksonville(N BC) WESH-Orlando(NBC) WCW-Tallahassee(CBS) WTSP-St.Petersburg (CBS)
Gllchrist WJXT-Jacksonville(lND) WTLV-Jacksonville(NBC) WESH-Orlando(NBC)
Levy WESH-Orlando(NBC) WJXT-Jacksonville(lND) WTSP-St.Petersburg(CBS) WTW-Tampa(FOX) zlP Mailing County Code Name State Name CableCompany SignificantlyViewed Stations
32625 CedarKev FL house WESH,WJXT, WTSP, WTW
32618 Archer FL Alachua Comcast WESH,WJXT, WTLV, WTSP, WTW 32631. Earleton FL Alachua Comcast WESH,WJXT, WTLV, WTSP, WTW 32694 Waldo FL Alachua Comcast WESH,WJXT, WTLV, WTSP, WTW 32693 Trenton FL Gilchrist Comcast WESH,WJXT, WTLV, WTSP, WTW 32693 FanningSprings FL Gilchrist Comcast WESH,WJXT, WTLV, WTSP, WTW 32696 Williston FL Levy Comcast WESH,WJXT, WTLV, WTSP, WTW 34449 Inglis FL Levy Comcast WESH,WJXT, WTLV, WTsP, WTW 34498 Yankeetown FL Comcast WESH,WJXT, WTLV, WTSP, WTW
32675 Alachua FL Alachua Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTVT 326L6 Alachua FL Alachua Communicom WESH,WJXT, WTLV, WCry, WTSP,WTW 32640 Hawthorne FL Alachua Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTW 32643 HighSprings FL Alachua Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTVT 32555 HighSprings FL Alachua Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTVT 32667 Micanopy FL Alachua Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTVT 32628 CrossCity FL Dixie Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTW 32692 Suwannee FL Dixie Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTW 32626 Chiefland FL Levy Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTVI 32644 Chiefland FL Communicom WESH,WJXT, WTLV, WCTV, WTSP, WTVT Page2 Mailing County Code Name Cable ViewedStations 32615 Alachua FL Alachua Cox WESH,WJXT, WTLV 326t6 Alachua FL Alachua Cox WESH,WJXT, WTLV 3260L Gainesville FL Alachua Cox WESH,WJXT, WTLV 32602 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32603 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32604 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32605 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32606 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32607 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32608 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32609 Gainesville FL Alachua Cox WESH,WJXT, WTLV 326t0 Gainesville FL Alachua Cox WESH,WJXT, WTLV 326tL Gainesville FL Alachua Cox WESH,WJXT. WTLV 32672 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32613 Gainesville FL Alachua Cox WESH,WJXT, WTLV 326L4 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32627 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32635 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32641, Gainesville FL Alachua Cox WESH,WJXT, WTLV 32653 Gainesville FL Alachua Cox WESH,WJXT, WTLV 32669 FL Alachua Cox WESH,WJXT, WTLV
32640 Hawthorne FL Alachua FIoTidaCab|e WESH,WJXT, WTLV, WTSP, WTW 32693 FanningSprings FL Gilchrist Florida Cable WESH,WJXT, w[LV, wTsP,\ rryT 3262L Bronson FL FIoTidaCable WESH,WJKT, WTLV, WTSP, WTW E ? o e2sl Ect J F B cd Y o ul 3 - r- O o rri(J I r-rrl E Certificateof Service I, JackN. Goodman,hereby certify that I have,this 5thday of July,201,2,causedto be sentby mail, first-classU.S. postage prepaid, copies of the foregoing"Petition for Waiverof Section76.92(f) and76.l06(a) of theCommission's Rules" to thefollowing: Division of CorporationsCable and/or Video Franchising PostOffrce Box 5678 Tallahassee,Florida 32314 GeneralManager WOGX 4739NW 52 Avenue#B Gainesville,FL32653 DaleT'apley COX Communications 2205La Vista Avenue Pensacola,FL 32504 GeneralManager WJXT 4 BroadcastPlace Jacksonville,FL32207 CarolynBarnett WCJB 6220NW 43'dStreet Gainesville,FL32653 GeneralManager WTLV 1070East Adams Street Jacksonville"FL32202 FCC:Success:Form 159 - PRINTABLE VERSION Page 1 of 1 Agency Tracking ID:PGC2168470 Authorization Number:06075C Successful Authorization -- Date Paid: 7/25/12 FILE COPY ONLY!! READ INSTRUCTIONS FEDERAL COMMUNICATIONS COMMISSION APPROVED BY OMB CAREFULLY BEFORE REMITTANCE ADVICE 3060-059 PROCEEDING FORM 159 PAGE NO 1 OF 1 SPECIAL USE (1) LOCKBOX #979089 FCC USE ONLY SECTION A - Payer Information (3) TOTAL AMOUNT PAID (dollars and cents) (2) PAYER NAME (if paying by credit card, enter name exactly as it appears on your card) Law Offices of Jack N. Goodman $1355.00 (4) STREET ADDRESS LINE NO. 1 1200 New Hampshire Ave, NW (5) STREET ADDRESS LINE NO. 2 Suite 800 (6) CITY (7) STATE (8) ZIP CODE Washington DC 20036 (9) DAYTIME TELEPHONE NUMBER (INCLUDING AREA CODE) (10) COUNTRY CODE (IF NOT IN U.S.A.) 202-7762045 US FCC REGISTRATION NUMBER (FRN) AND TAX IDENTIFICATION NUMBER (TIN) REQUIRED (11) PAYER (FRN) (12) FCC USE ONLY 0020858528 IF PAYER NAME AND THE APPLICANT NAME ARE DIFFERENT, COMPLETE SECTION B IF MORE THAN ONE APPLICANT, USE CONTINUATION SHEETS (FORM 159-C) (13) APPLICANT NAME Law Offices of Jack N. Goodman (14) STREET ADDRESS LINE NO. 1 1200 New Hampshire Ave, NW (15) STREET ADDRESS LINE NO. 2 Suite 800 (16) CITY (17) STATE (18) ZIP CODE Washington DC 20036 (19) DAYTIME TELEPHONE NUMBER (INCLUDING AREA CODE) (20) COUNTRY CODE (IF NOT IN U.S.A.) 202-7762045 US FCC REGISTRATION NUMBER (FRN) AND TAX IDENTIFICATION NUMBER (TIN) REQUIRED (21) APPLICANT (FRN) (22) FCC USE ONLY 0020858528 COMPLETE SECTION C FOR EACH SERVICE, IF MORE BOXES ARE NEEDED, USE CONTINUATION SHEET (23A) FCC Call Sign/Other ID (24A) Payment Type Code(PTC) (25A) Quantity WNBW-DT TQC 1 (26A) Fee Due for (PTC) (27A) Total Fee FCC Use Only $1,355.00 $1355.00 (28A) FCC CODE 1 (29A) FCC CODE 2 Gainesville X (23B) FCC Call Sign/Other ID (24B) Payment Type Code(PTC) (25B) Quantity (26B) Fee Due for (PTC) (27B) Total Fee FCC Use Only (28B) FCC CODE 1 (29B) FCC CODE 2 https://pay.fcc.gov/ElectronicForm159/success_159_html/printed159_success.cfm 7/25/2012